Complaint # ________

STATE OF NEW YORK

TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

The People of the State of New York

FELONY
COMPLAINT

-againstKORDELL J. JACKSON
Defendant.

Investigator R.A. Kotin employed by the New York State Police, by this information makes
written accusation as follows:
That KORDELL J. JACKSON from on or before February 2, 2013, through on or about
June 22, 2013, at the premises known as Jackson Guns and Ammo, 1555 East Henrietta Road, in
the Town of Henrietta, New York, did commit the armed felony offense of Criminal Sale of a
Firearm in the first degree, a class B felony, contrary to the provisions of Section 265.13(2) of
the Penal Law of the State of New York (Penal Law).
CHARGES: A person is guilty of criminal sale of a firearm in the first degree when such person:
(2) unlawfully sells, exchanges, gives or disposes of to another person or persons a total of ten or
more firearms in a period of not more than one year.
THE FACTS ON WHICH THIS ACCUSATION IS MADE ARE OF MY OWN
KNOWLEDGE OR ON INFORMATION AND BELIEF AS FOLLOWS:
That your complainant is a police officer for the New York State Police, and is currently
assigned to the Community Narcotics Enforcement Unit. The defendant operated a business known
as Jackson Guns and Ammo located at 1555 East Henrietta Road in the Town of Henrietta, County
of Monroe, State of New York, and during the specified time period he unlawfully sold, exchanged,
gave or disposed of ten (10) or more firearms, specifically assault weapons as defined by Section
265.00(22) of the Penal Law, to persons in a period of not more than one year. On the dates
indicated below, the defendant did sell, exchange, give or dispose of the following weapons:
DATE

MANUFACTURER

MODEL

SERIAL NO.

02/02/2013
02/21/2013
02/21/2013
03/01/2013
03/06/2013
03/06/2013
03/06/2013
03/06/2013
03/06/2013
03/06/2013

American Tactical Imports

American Tactical Imports
American Tactical Imports
Smith and Wesson
Windham Weaponry
Windham Weaponry
Windham Weaponry
Windham Weaponry
Windham Weaponry
Windham Weaponry

GSG522
STG44
STG44
M&P15-22
R16M4
R16M4
R16M4
R16M4
R16M4
R16M4

A383947
A506765
A506753
DUR8250
WW074657
WW074614
WW071068
WW074792
WW074220
WW074625

03/13/2013
03/13/2013
03/29/2013
06/21/2013
06/22/2013

Smith and Wesson

Windham Weaponry
Just Right Carbine
Just Right Carbine
Just Right Carbine

M&P 15
R16M4
JRC9
JRC9
JRC9

SR45090
WW074228
JRCV039376
JRCV039855
JRCV039858

Each of the aforementioned weapons were recovered and subsequently examined by members of
the New York State Police and deemed to be operable.
The basis of this complainant is my personal knowledge, training and experience, my
conversations with other law enforcement officials, including members of the New York State
Police, the Depositions of Russell Burry, Peter Timm, Kirk Minard, Jorge Canete, Jason Yates,
James Dobbins, Matthew Privett, Michael Silla and Jon Black, as well as New York State Police
Firearms Reports, and Firearms Transaction Records, which are attached hereto and made a part
of this accusatory instrument.
I realize that false statements made in the foregoing instrument are punishable as a Class
A Misdemeanor pursuant to Section 210.45 of the Penal Law. Accordingly and with notice of
the foregoing, I hereby affirm that the foregoing statements of facts are true, this ___ day of
June, 2016.

____________________________________
Witness

______________________________
Investigator R.A. Kotin

STATE OF NEW YORK

TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

Complaint # ________

The People of the State of New York

-against-

FELONY
COMPLAINT

JOSHUA D. PERKINS

KORDELL J. JACKSON
Defendants

Investigator R.A. Kotin employed by the New York State Police, by this information makes
written accusation as follows:
That JOSHUA D. PERKINS and KORDELL J. JACKSON, acting in concert from on
or before January 24, 2013, through on or about July 26, 2013, at the premises known as Jackson
Guns and Ammo, 1555 East Henrietta Road, in the Town of Henrietta, New York, did commit
the armed felony offense of Criminal Sale of a Firearm in the first degree, a class B felony,
contrary to the provisions of Section 265.13(2) of the Penal Law of the State of New York
(Penal Law).
CHARGES: A person is guilty of criminal sale of a firearm in the first degree when such person:
(2) unlawfully sells, exchanges, gives or disposes of to another person or persons a total of ten or
more firearms in a period of not more than one year.
THE FACTS ON WHICH THIS ACCUSATION IS MADE ARE OF MY OWN
KNOWLEDGE OR ON INFORMATION AND BELIEF AS FOLLOWS:
That your complainant is a police officer for the New York State Police, and is currently
assigned to the Community Narcotics Enforcement Unit. During the aforementioned time period,
Kordell J. Jackson operated and Joshua D. Perkins was an employee of a business known as
Jackson Guns and Ammo located at 1555 East Henrietta Road in the Town of Henrietta, County of
Monroe, State of New York, and said defendants, acting in concert, unlawfully sold, exchanged,
gave or disposed of ten (10) or more firearms, specifically assault weapons as defined by Section
265.00(22) of the Penal Law, to persons in a period of not more than one year. On the dates
indicated below, the defendants did sell, exchange, give or dispose of the following weapons:
DATE

MANUFACTURER

MODEL

SERIAL NO.

01/24/2013
01/24/2013
02/15/2013
03/01/2013

Just Right Carbine

Stag Arms
Bushmaster
Armalite

JRC9
Model 2
XM15ES2
LEC15

JRXL050239
125726
LBM19279
M000282

03/07/2013
03/09/2013
03/15/2013
04/12/2013
05/09/2013
06/27/2013
07/26/2013

Windham Weaponry
Windham Weaponry
Windham Weaponry
American Tactical Imports
Diamondback
Mossberg
Mossberg

R16M4
R16M4
R16M4
GSG5
DB15
715T
715T

WW074614
WW074228
WW078568
A495047
DB1505044
ELH3467087
ELL3577361

Each of the aforementioned weapons were recovered and subsequently examined by

members of the New York State Police and deemed to be operable.
The basis of this complainant is my personal knowledge, training and experience, my
conversations with other law enforcement officials, including members of the New York State
Police, the Depositions of Russell Burry, Scott Miller, Sean Donohoe, Nathan Hahn, James
Lindsay, Jason Minns and Adam Boccardo, as well as New York State Police Firearms Reports,
and Firearms Transaction Records, which are attached hereto and made a part of this accusatory
instrument.
I realize that false statements made in the foregoing instrument are punishable as a Class
A Misdemeanor pursuant to Section 210.45 of the Penal Law. Accordingly and with notice of
the foregoing, I hereby affirm that the foregoing statements of facts are true, this ___ day of
June, 2016.

____________________________________
Witness

______________________________
Investigator R.A. Kotin

STATE OF NEW YORK

TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

Complaint # ________

The People of the State of New York

-against-

FELONY
COMPLAINT

KENNETH C. YOUNGREN
KORDELL J. JACKSON
Defendants

Investigator R.A. Kotin employed by the New York State Police, by this information makes
written accusation as follows:
That KENNETH C. YOUNGREN and KORDELL J. JACKSON, acting in concert
from on or before January 18, 2013, through on or about August 20, 2013, at the premises known
as Jackson Guns and Ammo, 1555 East Henrietta Road, in the Town of Henrietta, New York, did
commit the armed felony offense of Criminal Sale of a Firearm in the first degree, a class B
felony, contrary to the provisions of Section 265.13(2) of the Penal Law of the State of New
York (Penal Law).
CHARGES: A person is guilty of criminal sale of a firearm in the first degree when such person:
(2) unlawfully sells, exchanges, gives or disposes of to another person or persons a total of ten or
more firearms in a period of not more than one year.
THE FACTS ON WHICH THIS ACCUSATION IS MADE ARE OF MY OWN
KNOWLEDGE OR ON INFORMATION AND BELIEF AS FOLLOWS:
That your complainant is a police officer for the New York State Police, and is currently
assigned to the Community Narcotics Enforcement Unit. During the aforementioned time period,
Kordell J. Jackson operated and Kenneth C. Youngren was an employee of a business known as
Jackson Guns and Ammo located at 1555 East Henrietta Road in the Town of Henrietta, County of
Monroe, State of New York, and said defendants, acting in concert, unlawfully sold, exchanged,
gave or disposed of ten (10) or more firearms, specifically assault weapons as defined by New York
State Penal section 265.00(22), to persons in a period of not more than one year. On the dates
indicated below, the defendants did sell, exchange, give or dispose of the following weapons:
DATE

MANUFACTURER

MODEL

SERIAL NO.

01/18/2013
01/18/2013
01/21/2013
01/22/2013
01/28/2013

Bushmaster
FN
ARFCOM
DPMS
Mossberg

XM15-E25
AR
AR15
Panther
715T

L076509
319ZM03335
ARF000152
15032
ELI3482533

01/28/2013
02/01/2013
02/08/2013
02/11/2013
02/13/2013
02/15/2013
02/18/2013
02/18/2013
02/18/2013
02/19/2013
02/19/2013
02/20/2013
02/27/2013
03/06/2013
03/12/2013
03/18/2013
03/19/2013
04/30/2013
05/20/2013
07/09/2013
07/22/2013
08/20/2013

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

Model 3
M&P 15-22
715T
WASR10
Model 2
522CB
LR308
715T
715T
715T
715T
995TS
M4
R16M4CH
Sub29
AR10
M&P 15
M&P 15
4595FGTS
DB15
995
Uzi/Israel

195955
DYY6780
ELK3557669
1980KV2300
28888
A497368
7381
ELK3558107
ELK3558301
ELK3558037
ELK3558156
F16342
WW070903
WW074743
EGG65
US385862
04587
56896
R20383
DB1505042
E23551
DR005779

Each of the aforementioned weapons were recovered and subsequently examined by

members of the New York State Police and deemed to be operable.
The basis of this complainant is my personal knowledge, training and experience, my
conversations with other law enforcement officials, including members of the New York State
Police, the Depositions of John Marshall, Charles Vitale, Christian Loomis, James Nardozzi,
Fred Lennon, Alan Gerber Michael Ray, David Geraghty, William Hanifin, Steven Broutman,
John Piano, Peter Timm, Patrick Lawler, Donald Christmas, Mark Ambrose, Jorge Canete, Brian
Walker, Matthew Vaisey, as well as New York State Police Firearms Reports, and Firearms
Transaction Records, which are attached hereto and made a part of this accusatory instrument.
I realize that false statements made in the foregoing instrument are punishable as a Class
A Misdemeanor pursuant to Section 210.45 of the Penal Law. Accordingly and with notice of
the foregoing, I hereby affirm that the foregoing statements of facts are true, this ___ day of
June, 2016.

____________________________________
Witness

______________________________
Investigator R.A. Kotin

Complaint # ________
STATE OF NEW YORK
TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

The People of the State of New York

FELONY
COMPLAINT

-againstKORDELL J. JACKSON
Defendant.

Investigator R.A. Kotin employed by the New York State Police, by this information makes
written accusation as follows:
That KORDELL J. JACKSON on or about August 15, 2014, at the premises known as
Jackson Guns and Ammo, 1555 East Henrietta Road, in the Town of Henrietta, New York, did
commit the offense of Manufacture, transport, disposition and defacement of weapons and
dangerous instruments and appliances, a class D felony, contrary to the provisions of Section
265.10(3) of the Penal Law of the State of New York (Penal Law).
CHARGES: A person is guilty of Manufacture, transport, disposition and defacement of weapons
and dangerous instruments and appliances when; (3) said person disposes of any machine gun,
assault weapon, large capacity ammunition feeding device or firearm silencer.
THE FACTS ON WHICH THIS ACCUSATION IS MADE ARE OF MY OWN
KNOWLEDGE OR ON INFORMATION AND BELIEF AS FOLLOWS:
That your complainant is a police officer for the New York State Police, and is currently
assigned to the Community Narcotics Enforcement Unit. The defendant operated a business known
as Jackson Guns and Ammo located at 1555 East Henrietta Road in the Town of Henrietta, County
of Monroe, State of New York, and during the specified time period he unlawfully disposed of a
Colt Match target 5.56 caliber rifle, serial number CJC022758, specifically an assault weapon as
defined by Section 265.00(22) of the Penal Law to Matthew Evans.
The aforementioned weapon was recovered and subsequently examined by members of the New
York State Police and deemed to be operable.
The basis of this complainant is my personal knowledge, training and experience, my
conversations with other law enforcement officials, including members of the New York State
Police, New York State Police Firearms Report, and Firearms Transaction Record, which are
attached hereto and made part of the accusatory instrument.

I realize that false statements made in the foregoing instrument are punishable as a Class
A Misdemeanor pursuant to Section 210.45 of the Penal Law. Accordingly and with notice of
the foregoing, I hereby affirm that the foregoing statements of facts are true, this ___ day of
June, 2016.

____________________________________
Witness

______________________________
Investigator R.A. Kotin

STATE OF NEW YORK

TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

Complaint # ________

The People of the State of New York

-against-

FELONY
COMPLAINT

KENNETH C. YOUNGREN

KORDELL J. JACKSON
Defendants

Investigator R.A. Kotin employed by the New York State Police, by this information makes
written accusation as follows:
That KENNETH C. YOUNGREN and KORDELL J. JACKSON, acting in concert
from on or about August 5, 2014, and December 17, 2014, at the premises known as Jackson
Guns and Ammo, 1555 East Henrietta Road, in the Town of Henrietta, New York, did commit
the offense of Manufacture, transport, disposition and defacement of weapons and
dangerous instruments and appliances, a class D felony, contrary to the provisions of Section
265.10(3) of the Penal Law of the State of New York.
CHARGES: A person is guilty of Manufacture, transport, disposition and defacement of weapons
and dangerous instruments and appliances when; (3) said person disposes of any machine gun,
assault weapon, large capacity ammunition feeding device or firearm silencer.
THE FACTS ON WHICH THIS ACCUSATION IS MADE ARE OF MY OWN
KNOWLEDGE OR ON INFORMATION AND BELIEF AS FOLLOWS:
That your complainant is a police officer for the New York State Police, and is currently
assigned to the Community Narcotics Enforcement Unit. During the aforementioned time period,
Kordell J. Jackson operated and Kenneth C. Youngren was an employee of a business known as
Jackson Guns and Ammo located at 1555 East Henrietta Road in the Town of Henrietta, County of
Monroe, State of New York, and said defendants, acting in concert, unlawfully committed the
offense of commit the offense of Manufacture, transport, disposition and defacement of weapons
and dangerous instruments and appliances, as follows:
(1) On or about August 5, 2014, the defendants, acting in concert, disposed of a Bushmaster
308 caliber rifle, serial number BRD012899, specifically an assault weapon as defined by Section
265.00(22) of the Penal Law, to Gregory Mytych.
(2) On or about December 17, 2014, the defendants, acting in concert, disposed of a
Legion Saiga 410 semi-automatic shotgun, serial number H09204332L, specifically an assault
weapon as defined by Section 265.00(22) of the Penal Law, to Cory McQueen.
9

Each of the aforementioned weapons were recovered and subsequently examined by

members of the New York State Police and deemed to be operable.
The basis of this complainant is my personal knowledge, training and experience, my
conversations with other law enforcement officials, including members of the New York State
Police, the Depositions of Gregory Mytych and Cory McQueen, as well as New York State
Police Firearms Reports, and Firearms Transaction Records, which are attached hereto and made
part of the accusatory instrument.
I realize that false statements made in the foregoing instrument are punishable as a Class
A Misdemeanor pursuant to Section 210.45 of the Penal Law. Accordingly and with notice of
the foregoing, I hereby affirm that the foregoing statements of facts are true, this ___ day of
June, 2016.

____________________________________
Witness

______________________________
Investigator R.A. K

10