SUPREME COURT: COUNTY OF NASSAU STATE OF NEW YORK. THE PEOPLE OF THE STATE OF NEW YORK -against- RANDY STITH, Defendant

Similar documents
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: PART 71 THE PEOPLE OF THE STATE OF NEW YORK. -against- PEOPLE'S VOLUNTARY DISCLOSURE FORM

Packet Two: Criminal Law and Procedure Chapter 1: Background

IC 5-8 ARTICLE 8. OFFICERS' IMPEACHMENT, REMOVAL, RESIGNATION, AND DISQUALIFICATION. IC Chapter 1. Impeachment and Removal From Office

INDEPENDENT NATIONAL ELECTORAL COMMISSION

Third District Court of Appeal State of Florida

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT. Defendant

PART III - CALIFORNIA PENAL CODES

Criminal Litigation: Step-By-Step

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION

15A-903. Disclosure of evidence by the State Information subject to disclosure. (a) Upon motion of the defendant, the court must order:

S 0556 S T A T E O F R H O D E I S L A N D

Legal Supplement Part C to the Trinidad and Tobago Gazette, Vol. 40, No. 152, 14th August, 2001

Grand jury; proceedings and operation in general

The Board of Supervisors of the County of Orange, California, ordains as follows:

79th OREGON LEGISLATIVE ASSEMBLY Regular Session. Enrolled. Senate Bill 505

MONTEFIORE HEALTH SYSTEM ADMINISTRATIVE POLICY AND PROCEDURE SUBJECT: SUMMARY OF FEDERAL AND STATE NUMBER: JC31.1 FALSE CLAIMS LAWS

February 6, United States Attorneys Office 1100 Commerce Street Dallas, Texas Re: United States v. XXXXX, No. YYYY.

Criminal Litigation: Step-By-Step

Friday 30th January, 2004.

Circuit Court, D. Oregon. June 13, 1887.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Recitals. A. On February 2, 2010, the Parties entered into the Agreement for construction management services for the new Broward County Courthouse.

CHAPTER Committee Substitute for House Bill No. 1091

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Particular Crimes can be grouped under 3 headings: Crimes against people Crimes against property Crimes against business interests

CHAPTER 55 INTERFERENCE WITH GOVERNMENT OPERATIONS AND LAW ENFORCEMENT

IN THE COMMON PLEAS COURT OF FAIRFIELD COUNTY, OHIO. Plaintiff, : Case No. 11 CR 489

FILED: NEW YORK COUNTY CLERK 08/11/ :47 PM INDEX NO /2016 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 08/11/2016

AN BILLE UM RIALÁIL GNÍOMHAIREACHTAÍ FOSTAÍOCHTA 2009 EMPLOYMENT AGENCY REGULATION BILL 2009

RESTATED AND AMENDED ARTICLES OF INCORPORATION OF PINE RIDGE PROPERTY OWNERS ASSOCIATION, INC.

REGISTRATION OF PERSONS ACT

ALABAMA VICTIMS RIGHTS LAWS1

LAW AMENDING THE LAW ON INTEGRITY AND COMBAT CORRUPTION (ZIntPK-B)

Be it enacted by the General Assembly of the Commonwealth of Kentucky: Section 1. KRS is amended to read as follows:

Chapter 8. Criminal Wrongs. Civil and Criminal Law. Classification of Crimes

As Reported by the House Criminal Justice Committee. 132nd General Assembly Regular Session Sub. S. B. No

Section 2 Creating the Bill of Rights

FILED: NEW YORK COUNTY CLERK 03/15/ :24 AM INDEX NO /2016 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 03/15/2016

U.C.A Title. This chapter is known as the Utah False Claims Act.

United States Constitutional Law: Theory, Practice, and Interpretation

FILED: NEW YORK COUNTY CLERK 03/10/ :54 PM INDEX NO /2016 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/10/2016

BUSINESS LAW. Chapter 8 Criminal Law and Cyber Crimes

Vs : C.A. NO. WC ANSWER AND COUNTER-CLAIM

FEDERAL STATUTES. 10 USC 921 Article Larceny and wrongful appropriation

NC General Statutes - Chapter 14 Article 52A 1

Chapter 10 The Criminal Law and Business. Below is a table that highlights the differences between civil law and criminal law:

OHIO RULES OF CRIMINAL PROCEDURE

An Act. ENROLLED HOUSE By: Peterson, Billy, Sherrer, Hoskin and Goodwin of the House

THIRTEENTH AMENDMENT CONDOMINIUM OFFERING PLAN. THE 45 EAST 22No STREET CONDOMINIUM EAST 22No STREET NEW YORK, NEW YORK.

STATE OF OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES INSURANCE DIVISION

State of New York Supreme Court, Appellate Division Third Judicial Department

CHAPTER 12 THE NATIONAL ASSEMBLY (POWERS AND PRIVILEGES) ACT

The Constitution. Structure and Principles

CHAPTER 38:04 - FISH PROTECTION: SUBSIDIARY LEGISLATION INDEX TO SUBSIDIARY LEGISLATION FISH PROTECTION REGULATIONS. (section 3) (23rd May, 2008)

MENTAL HEALTH ACT. Act No. 45,1958.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS. Case No. PRETRIAL AND CRIMINAL CASE MANAGEMENT ORDER

GOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF CONSUMER AND REGULATORY AFFAIRS CORPORATIONS DIVISION CERTIFICATE

FILED: ONEIDA COUNTY CLERK 01/23/ :02 PM

WILLFULLY FAILING TO COMPLY WITH SEX OFFENDER REGISTRATION LAW. FELONY.

Tentative Plan of Work 26 May 2018

United States Constitution. What was the Virginia Plan?

RULES OF PROCEDURE OF THE WORLD HEALTH ASSEMBLY 1

COUNTY CRIMINAL FILINGS AND DISPOSITIONS* FY to FY

FILED: KINGS COUNTY CLERK 02/24/ /31/ :26 08:31 PM AM INDEX NO /2016 NYSCEF DOC. NO. 637 RECEIVED NYSCEF: 02/24/2017

FILED: NEW YORK COUNTY CLERK 10/28/ :04 PM INDEX NO /2016 NYSCEF DOC. NO. 55 RECEIVED NYSCEF: 10/28/2016

Chapter 2 The Forensic Accounting Legal Environment Teaching Notes

ORDINANCE NO. The Board of Supervisors of the County of Orange, California, ordains as follows: Article 5 LOBBYIST REGISTRATION AND REPORTING

FIRST AFFIRMATIVE MATTER SECOND AFFIRMATIVE MATTER. Page 1 of 6 ANSWER

SECOND REGULAR SESSION [P E R F E C T E D] SENATE BILL NO TH GENERAL ASSEMBLY INTRODUCED BY SENATOR MUNZLINGER.

Corporate Administration Detection and Prevention of Fraud and Abuse CP3030

FILED: RICHMOND COUNTY CLERK 03/30/ :14 PM INDEX NO /2016 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 03/30/2018

IN THE SUPREME COURT OF OHIO. Case No. Affiant, after being duly cautioned and sworn, states as follows:

TO: All Article 19-A Motor Carriers and Certified Examiners. SUBJECT: Chapter 189 of the Laws of New Disqualification for School Bus Drivers

APPLICATION FOR SECOND HAND DEALER LICENSE

FILED: NEW YORK COUNTY CLERK 11/04/ :40 PM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/04/2016

Rhode Island False Claims Act

IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION

AMENDED AND RESTATED CERTIFICATE OF INCORPORATION OF CHICAGO STOCK EXCHANGE, INC.

Standard Interrogatories Under Supreme Court Rule 213(j)

GEORGIA PEACE OFFICER STANDARDS AND TRAINING COUNCIL PETITION FOR MODIFICATION OF PROBATION

to redress his civil and legal rights, and alleges as follows: 1. Plaintiff, Anthony Truchan, is a resident of Nutley, New Jersey.

BOND FOR FAITHFUL PERFORMANCE

STATUTORY COMPILATION PRESENCE OF VICTIM ADVOCATE IN SEXUAL ASSAULT EXAM CURRENT AS OF MARCH 2011

Summons SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WAYNE X

Case 3:15-cr AJB Document 11 Filed 06/10/15 Page 1 of 4

Case 2:12-cv ODW-JC Document 23 Filed 12/18/12 Page 1 of 8 Page ID #:216

CHAPTER Law Enforcement Officers' Bill of Rights

FILED: SUFFOLK COUNTY CLERK 09/26/ :45 PM INDEX NO /2016 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 09/26/2016

POLICIES AND PROCEDURES FOR DETECTING AND PREVENTING FRAUD, WASTE AND ABUSE

The Bill of Rights *** The First Ten Amendments to the U.S. Constitution

SECURING EXECUTION OF DOCUMENT BY DECEPTION

State of New York Supreme Court, Appellate Division Third Judicial Department

APPENDIX A Appendix COMPACT A OF 1785 (1786 Md. Laws c. 1)

TITLE 8. EMPLOYMENT CHAPTER 1. EMPLOYEE REVIEW CODE

The Big Idea The U.S. Constitution balances the powers of the federal government among the legislative, executive, and judicial branches.

FILED: NEW YORK COUNTY CLERK 03/30/ :06 PM INDEX NO /2017 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 03/30/2017

ANTIGUA AND BARBUDA THE ELECTRONIC TRANSFER OF FUNDS CRIMES ACT, 2006 ARRANGEMENT OF SECTIONS. Part 1 - Preliminary

Legal Supplement Part A to the Trinidad and Tobago Gazette, Vol. 44, No. 167, 16th September, 2005

OFFICIAL SECRETS ACT CHAPTER 187 LAWS OF KENYA

Evidentiary Privileges

Transcription:

SUPREME COURT: COUNTY OF NASSAU STATE OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK -against- RANDY STITH, Defendant THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the defendant of the crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE, in violation of Section 170.25 of the Penal Law of the State of New York The defendant, RANDY STITH, on or about the 22nd day of April, 2015, in the County of Nassau, State of New York, with knowledge that it was forged and with intent to defraud, deceive or injure another, did utter or possess a forged instrument of a kind specified in Section 170.10 of the Penal Law which purported to be or which was calculated to become or to represent if completed a written instrument filed or requested or authorized by law to be filed in or with a public office or public servant, to wit: Randy Stith, knowing that it was forged, presented a Hose 2 recommendation letter to the Nassau County Civil Service Commission; and he offered or presented the forged Hose 2 recommendation letter with intent to defraud the Nassau County Civil Service Commission. SECOND COUNT accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the Penal Law of the State of New York committed as follows: The defendant, RANDY STITH, on or about the 22nd day of April, 2015, in the County of Nassau, State of New York, did commit the crime of falsifying business records in the second degree, and his intent to defraud included an intent to commit another crime or to aid or conceal the commission thereof, to wit: Randy Stith, made or caused a false entry in a Hose 2 recommendation letter, a business record of the Nassau County Civil Service Commission. THIRD COUNT accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE SECOND DEGREE, in violation of Section 175.05 Subdivision 1 of the Penal Law of the State of New York The defendant, RANDY STITH, on or about the 22nd day of April, 2015, in the County of Nassau, State of New York, with intent to defraud, made or caused a false entry in the business records of an enterprise, to wit: Randy Stith, made or caused a false entry in a Hose 2 recommendation letter, a business record of the Nassau County Civil Service Commission.

FOURTH COUNT THE FIRST DEGREE, in violation of Section 175.35 of the Penal Law of the State of New York The defendant, RANDY STITH, on or about the 22nd day of April, 2015, in the County false information, and with intent to defraud the state or a political subdivision thereof, offered and presented said written instrument to a public office and public servant with the knowledge and belief that said written instrument would be filed with, registered and recorded in and otherwise become a part of the records of such public office and public servant, to wit: Randy Stith, knowing that it contained a false statement or false information, offered or presented a Hose 2 recommendation letter to the Nassau County Civil Service Commission; and he offered or presented the forged Hose 2 recommendation letter with intent to defraud the Nassau County Civil Service Commission. FIFTH COUNT THE SECOND DEGREE, in violation of Section 175.30 of the Penal Law of the State of New York The defendant, RANDY STITH, on or about the 22nd day of April, 2015, in the County false information, did offer or present said written instrument to a public office and public servant with the knowledge and belief that said written instrument would be filed with, registered and recorded in and otherwise become a part of the records of such public office and public servant, to wit: Randy Stith, knowing that it contained a false statement or false information, offered or presented a Hose 2 recommendation letter to the Nassau County Civil Service Commission. SIXTH COUNT accuses the defendant of the crime of GRAND LARCENY IN THE THIRD DEGREE, in violation of Section 155.35 Subdivision 1 of the Penal Law of the State of New York The defendant, RANDY STITH, between on or about the 1st day of March, 2015, to on or about the 31st day of January, 2018, in the County of Nassau, State of New York, did steal property from Southside Hose 2 and the value of the property exceeded three thousand dollars, to wit: money belonging to Southside Hose 2. SEVENTH COUNT accuses the defendant of the crime of GRAND LARCENY IN THE FOURTH DEGREE, in violation of Section 155.30 Subdivision 1 of the Penal Law of the State of New York committed as follows:

The defendant, RANDY STITH, between on or about the 1st day of March, 2015, to on or about the 31st day of January, 2018, in the County of Nassau, State of New York, did steal property from Southside Hose 2 and the value of the property exceeded One Thousand Dollars, to wit: money belonging to Southside Hose 2. EIGHTH COUNT accuses the defendant of the crime of PETIT LARCENY, in violation of Section 155.25 of the Penal Law of the State of New York The defendant, RANDY STITH, between on or about the 1st day of March, 2015, to on or about the 31st day of January, 2018, in the County of Nassau, State of New York, did steal property from Southside Hose 2, to wit: money belonging to Southside Hose 2. NINTH COUNT accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the Penal Law of the State of New York committed as follows: of Nassau, State of New York, did commit the crime of falsifying business records in the second degree, and his intent to defraud included an intent to commit another crime or to aid or conceal the commission thereof, to wit: Randy Stith, made or caused a false entry in a financial statement, a business record of the Hempstead Volunteer Fire Department. TENTH COUNT accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE SECOND DEGREE, in violation of Section 175.05 Subdivision 1 of the Penal Law of the State of New York of Nassau, State of New York, with intent to defraud, made or caused a false entry in the business records of an enterprise, to wit: Randy Stith, made or caused a false entry in a financial statement, a business record of the Hempstead Volunteer Fire Department. ELEVENTH COUNT THE FIRST DEGREE, in violation of Section 175.35 of the Penal Law of the State of New York false information, and with intent to defraud the state or a political subdivision thereof, offered and presented said written instrument to a public office and public servant with the knowledge and

belief that said written instrument would be filed with, registered and recorded in and otherwise become a part of the records of such public office and public servant, to wit: Randy Stith, knowing that it contained a false statement or false information, offered or presented a financial statement to the Hempstead Volunteer Fire Department; and he offered or presented the financial statement with intent to defraud the Hempstead Volunteer Fire Department. TWELFTH COUNT THE SECOND DEGREE, in violation of Section 175.30 of the Penal Law of the State of New York false information, did offer or present said written instrument to a public office and public servant with the knowledge and belief that said written instrument would be filed with, registered and recorded in and otherwise become a part of the records of such public office and public servant, to wit: Randy Stith, knowing that it contained a false statement or false information, offered or presented a financial statement to the Hempstead Volunteer Fire Department. THIRTEENTH COUNT accuses the defendant of the crime of OFFICIAL MISCONDUCT, in violation of Section 195.00 Subdivision 1 of the Penal Law of the State of New York of Nassau, State of New York, with intent to obtain a benefit or to injure or deprive another person of a benefit, did commit an act relating to his office but constituting an unauthorized exercise of his official functions knowing that such an act was unauthorized, to wit: Randy Stith filed a false financial statement with the Hempstead Volunteer Fire Department; and that Randy Stith did so with the intent to obtain a benefit for himself. Dated: March 20, 2018 Mineola, New York MADELINE SINGAS District Attorney BY: Lisa Berk Assistant District Attorney

PLEASE TAKE NOTICE that in accordance with the provisions of Section 240.30 of the Criminal Procedure Law, the People hereby demand that within fifteen days of the date of service of this Demand, you disclose and make available to the District Attorney of Nassau County for inspection, photographing, copying or testing: (a) any written report of document or portion thereof, concerning a physical or mental examination, or scientific test, experiment, or comparisons, made by or at the request or direction of the defendant, if the defendant intends to introduce same at trial of this action, or if the defendant has filed a notice of intent to proffer psychiatric evidence and such report or document relates thereto, or if same was made by a person, other than the defendant, whom the defendant intends to call as a witness at trial; and (b) any photograph, drawing, tape, or other electronic recording which the defendant intends to introduce at trial. PLEASE TAKE FURTHER NOTICE that in accordance with the provisions of Section 250.20 of the Criminal Procedure Law, I hereby demand from you and each of you that if you intend upon the trial of this indictment to offer, for any purpose whatever, testimony which may tend to establish your presence elsewhere than at the scene of the crime or crimes with which you are charged, at the time of their commission, you must, within eight days from the date of service of this Demand, serve upon the District Attorney of Nassau County, and file with this court, a copy thereof, a "notice of alibi" which shall set forth in detail the place of places where you claim to have been together with the names, post office addresses, residences and places of employment and the address thereof of the witnesses upon whom you intend to rely to establish your presence elsewhere than at the scene of the crime or crimes at the time of their commission. If at the trial of this action the defendant calls such an alibi witness without having served a notice of alibi pursuant to the demand, or, if having served such a notice he calls a witness not specified therein, a motion will be made pursuant to the provisions of Section 250.20 of the Criminal Procedure Law to exclude any testimony of such witness relating to the alibi defense. PLEASE TAKE FURTHER NOTICE that pursuant to Section 710.30 of the Criminal Procedure Law, the People intend to offer at the trial of this indictment evidence of oral and/or written statement(s) made to a public servant pertaining to the charge set forth in this indictment. PLEASE TAKE FURTHER NOTICE that pursuant to Section 710.30 of the Criminal Procedure Law, during the trial of this matter, the People expect to introduce testimony identifying the defendant as a person who committed the offenses charged as set forth in this indictment, which testimony will be given by a witness (witnesses) who has (have) previously identified the defendant. PLEASE TAKE FURTHER NOTICE that pursuant to Section 220.51 of the Criminal Procedure Law, if at the time of the alleged felony crime the defendant was a public official, as defined in subdivision six of section one hundred fifty-six of the retirement and social security law, the defendant s plea of guilty and the court s acceptance thereof or conviction after trial may result in proceedings for the reduction or revocation of such defendant s pension pursuant to article three-b of the retirement and social security law. MADELINE SINGAS District Attorney Nassau County, New York

IND. NO. SUPREME COURT: COUNTY OF NASSAU: STATE OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK -against- RANDY STITH, Defendant MADELINE SINGAS District Attorney INDICTMENT FOR: CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE (TWO COUNTS) FALSIFYING BUSINESS RECORDS IN THE SECOND DEGREE (TWO COUNTS) OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE (TWO COUNTS) OFFERING A FALSE INSTRUMENT FOR FILING IN THE SECOND DEGREE (TWO COUNTS) GRAND LARCENY IN THE THIRD DEGREE GRAND LARCENY IN THE FOURTH DEGREE PETIT LARCENY OFFICIAL MISCONDUCT A TRUE BILL Foreman