Sellers Indictment

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

THE PEOPLE OF THE STATE OF NEW YORK
-againstKENNY HERNANDEZ a/k/a Jay,
FELIX NUNEZ, a/k/a Jake,
OSCAR ALMONTE,
Defendants.
THE GRAND JURY OF THE COUNTY OF NEW YORK, by this

indictment, accuse defendants KENNY HERNANDEZ, a/k/a Jay, FELIX
NUNEZ, a/k/a Jake, and OSCAR ALMONTE, of the crime of CONSPIRACY
IN THE SECOND DEGREE, in violation of Penal Law 105.15, committed as
follows:
The defendants, in the County of New York, and elsewhere, during the period
from on or about June 1, 2015, to on or about the date of this indictment, with intent
that conduct constituting the crime of CRIMINAL SALE OF A CONTROLLED
SUBSTANCE IN THE SECOND DEGREE be performed, said crime being a
class A felony, agreed to engage in and cause the performance of such conduct.
OVERT ACTS
In furtherance of said conspiracy and to effect the objects thereof, from on or
about June 1, 2015, to on or about the date of this indictment, the following overt acts,
among others, were committed in New York County (unless otherwise stated):
1. On or about June 1, 2015, in a series of telephone communications, 1 a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
2. On or about June 1, 2015, in the vicinity of 18 First Avenue, defendant
HERNANDEZ sold cocaine to a police officer known to the Grand Jury.
3. On or about June 4, 2015, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
4. On or about June 4, 2015, in the vicinity of 138 Orchard Street, a co-conspirator
sold cocaine to a police officer known to the Grand Jury.
5. On or about June 16, 2015, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
6. On or about June 16, 2015, in the vicinity of 140 Orchard Street, defendant
7. On or about July 1, 2015, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
8. On or about July 1, 2015, in the vicinity of 100 Delancey Street, defendant
9. On or about July 22, 2015, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
10. On or about July 22, 2015, in the vicinity of 100 Delancey Street, defendant
NUNEZ sold cocaine to a police officer known to the Grand Jury.
11. On or about September 2, 2015, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
1
All telephone communications described herein are described in part and in substance.
12. On or about September 2, 2015, in the vicinity of 122 Ludlow Street, two coconspirators, acting together, sold cocaine to a police officer known to the
Grand Jury.
13. On or about October 6, 2015, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
14. On or about October 6, 2015, in the vicinity of 50 Avenue D, defendant
ALMONTE sold cocaine to a police officer known to the Grand Jury.
16. On or about October 13, 2015, in the vicinity of 140 Forsyth Street, defendant
18. On or about October 20, 2015, in the vicinity of 100 Delancey Street, defendant
19. On or about October 20, 2015, after the sale of cocaine to a police officer
known to the Grand Jury, defendant HERNANDEZ entered 138 Ludlow
Street.
21. On or about October 29, 2015, in the vicinity of 76 East 1st Street, a coconspirator sold cocaine to a police officer known to the Grand Jury.
22. On or about November 11, 2015, in a series of telephone communications, a
co-conspirator agreed to sell cocaine to a police officer known to the Grand
Jury.
23. On or about November 11, 2015, in the vicinity of 76 East 1st Street, a coconspirator sold cocaine to a police officer known to the Grand Jury.
24. On or about November 23, 2015, in a series of telephone communications, a

Jury.
25. On or about November 23, 2015, in the vicinity of 100 Delancey Street,
defendant HERNANDEZ sold cocaine to a police officer known to the
Grand Jury.
26. On or about December 21, 2015, in a series of telephone communications, a
co-conspirator agreed to sell more than one half of one ounce of cocaine to a
police officer known to the Grand Jury.
27. On or about December 21, 2015, in the vicinity of 100 Delancey Street,
defendant HERNANDEZ sold more than one half of one ounce of cocaine
to a police officer known to the Grand Jury.
28. On or about January 4, 2016, in a series of telephone communications, a coconspirator agreed to sell cocaine to a police officer known to the Grand Jury.
29. On or about January 4, 2016, in the vicinity of 100 Delancey Street, defendant
30. On or about January 26, 2016, in the vicinity of Second Avenue and East 32nd
Street, after a series of telephone communications during which
CHRISTOPHER DODSON ordered 2 to DUANE READE, defendant
HERNANDEZ sold cocaine to CHRISTOPHER DODSON.
31. On or about January 29, 2016, in the vicinity of 43 West 13th Street, after a series
of telephone communications during which
ordered
200 but agreed to DO 3 [TO] GET 4, defendant HERNANDEZ sold

cocaine to
32. On or about January 29, 2016, in the vicinity of Third Avenue and East 30th
Street, after a series of telephone communications during which KYLE
HOLMES
ordered
to
his
OLD
BUILDING,
defendant
HERNANDEZ sold cocaine to KYLE HOLMES.
33. On or about January 29, 2016, in the vicinity of Rivington Street, after a series
ordered FOUR BAGS OF WHITE to her hotel room and referenced
BLOW,
defendant
HERNANDEZ
sold
cocaine
to
.
34. On or about January 31, 2016, in the vicinity of Second Avenue and East 32nd
35. On or about February 2, 2016, in the vicinity of 162 Orchard Street, after a
series of telephone communications during which
ordered 100 AT WORK to WASSAIL, defendant HERNANDEZ sold
cocaine to
36. On or about February 2, 2016, in the vicinity of Second Avenue and East 32nd
37. On or about February 3, 2016, in a series of telephone calls where a customer
ordered 100 to 19th AND PARK defendant HERNANDEZ told a
customer to meet inside of a CVS pharmacy at Park Avenue and East 20th Street.
38. On or about February 3, 2016, in a series of telephone communications,
defendant HERNANDEZ agreed to sell more than one half of one ounce of
cocaine to a police officer known to the Grand Jury.
39. On or about February 3, 2016, in the vicinity of 100 Delancey Street, defendant
HERNANDEZ sold more than one-half of one ounce of cocaine to a police
officer known to the Grand Jury.
40. On or about February 3, 2016, prior to the sale of more than one half of one
ounce of cocaine a police officer known to the Grand Jury, a co-conspirator
entered and exited 138 Ludlow Street several times, after which defendant
HERNANDEZ left 138 Ludlow Street to sell cocaine, with the co-conspirator
acting as a lookout.
41. On or about February 4, 2016, after a series of telephone communications
during which a customer ordered cocaine, defendant HERNANDEZ took a
black livery cab to the vicinity of 77 Water Street to sell cocaine.
42. On or about February 4, 2016, in the vicinity of Lexington Avenue and East
100th Street, after a series of telephone communications during which
agreed
to
purchase
150
of
SOME
NICE
SHIT
[HERNANDEZ] JUST GOT, defendant HERNANDEZ sold cocaine to

.
Street, after a series of telephone communications during which AUSTIN
DODSON ordered 2, defendant HERNANDEZ sold cocaine to AUSTIN
DODSON.
45. On or about February 7, 2016, in the vicinity of Madison Avenue and East 37th
HOLMES ordered TWO and defendant HERNANDEZ told KYLE
HOLMES
he
was
IN
LITTLE
BLACK
CAR,
defendant
HERNANDEZ sold cocaine to KYLE HOLMES.
46. On or about February 8, 2016, in the vicinity of 1101 Greene Avenue, Kings
County, after a series of communications during which
ORDERED 200, defendant HERNANDEZ sold cocaine to JAMES
HULIHAN.
47. On or about February 10, 2016, in the vicinity of Avenue A and East 5th Street,
after a series of communications during which
ORDERED 100, defendant HERNANDEZ sold cocaine to JAMES
HULIHAN.
CHRISTOPHER DODSON ordered 60 to DUANE READE, a coconspirator sold cocaine to CHRISTOPHER DODSON.
49. On or about February 14, 2016, in the vicinity of 1082 Eastern Parkway, Kings
ordered 200 to [his] PLACE, defendant HERNANDEZ
sold cocaine to
50. On or about February 14, 2016, in the vicinity of Orchard Street and Rivington
ordered 100 while AT WORK, defendant HERNANDEZ
sold cocaine to
ordered 100 while STILL AT WORK, defendant HERNANDEZ sold
cocaine to
52. On or about February 14, 2016, in the vicinity of Amsterdam Avenue and West
82nd Street, after a series of telephone communications during which
ordered THREE TICKETS, defendant
HERNANDEZ sold cocaine to
53. On or about February 17, 2016, in the vicinity of Sixth Avenue and West 38th
Street, after a series of telephone communications during which CHRISTIAN
JEWETT ordered TWO AT THE AUSTRAILIAN BAR, defendant
HERNANDEZ sold cocaine to CHRISTIAN JEWETT.
54. On or about February 18, 2016, in the vicinity of 69 Fourth Avenue, Kings
County, after a series of telephone communications during which
ordered 5 FOR 200, defendant HERNANDEZ sold
cocaine to
56. On or about February 18, 2016, in the vicinity of Lexington Avenue and East
100th Street, after a series of telephone communications during which
ordered 150 TO [HIS] SPOT, defendant HERNANDEZ sold
cocaine to
57. On or about February 19, 2016, in the vicinity of Ludlow Street, after a series
referenced an 8 BALL but ordered $1400 of WHITE to her hotel to be
distributed amongst at least seven people, defendant HERNANDEZ sold
cocaine to
58. On or about February 20, 2016, in the vicinity of Allen Street and Stanton Street,
after a series of telephone communications during which
sold cocaine to
59. On or about February 20, 2016, in the vicinity of 160 West 22nd Street, after a
2 BAGS, defendant HERNANDEZ sold cocaine to
ordered
.
60. On or about February 21, 2016, in the vicinity of 315 South End Avenue, after
a series of telephone communications during which ROMAN YOFFE agreed
to purchase 4 FOR 6 inside a Gristedes supermarket, defendant
HERNANDEZ sold cocaine to ROMAN YOFFE.
CHRISTOPHER DODSON ordered THE 4 DEAL to DUANE
READE, defendant HERNANDEZ sold cocaine to CHRISTOPHER
DODSON.
series of telephone calls where defendant HERNANDEZ told a male
customer who had ordered TWO HUNDRED to meet him inside a deli,
defendant HERNANDEZ sold cocaine to a male customer.
63. On or about February 26, 2016, in the vicinity of 77 Water Street, after a series
of telephone communications during which ROMAN YOFFE agreed to
purchase 4 FOR 6 at THE OFFICE, defendant HERNANDEZ sold
cocaine to ROMAN YOFFE.
64. On or about February 28, 2016, in the vicinity of Stanton Street and Orchard
JEWETT ordered TWO, defendant HERNANDEZ sold cocaine to
CHRISTIAN JEWETT.
65. On or about March 1, 2016, in the vicinity of 77 Water Street, after a series of
telephone communications during which ROMAN YOFFE agreed to
purchase 2 at THE OFFICE, defendant HERNANDEZ sold cocaine to
ROMAN YOFFE.
66. On or about March 2, 2016, in the vicinity of Second Avenue and East 32nd
9
purchase 2 at THE OFFICE, defendant HERNANDEZ sold cocaine to
ROMAN YOFFE.
68. On or about March 2, 2016, in the vicinity of Second Avenue and East 41st
HOLMES ordered TWO AT THE DELI before heading home to
Astoria, defendant HERNANDEZ sold cocaine to KYLE HOLMES.
69. On or about March 2, 2016, in the vicinity of 39 West 27th Street, after a series
of telephone communications during which defendant HERNANDEZ agreed
to sell cocaine to a customer at a hotel, defendant HERNANDEZ entered and
exited a hotel.
70. On or about March 3, 2016, in the vicinity of 160 West 22nd Street, after a series
ordered 200,
defendant HERNANDEZ sold cocaine to
purchase 4 FOR 6 at THE OFFICE, defendant HERNANDEZ sold
cocaine to ROMAN YOFFE.
73. On or about March 4, 2016, in the vicinity of Lexington Avenue and East 58th
requested KILLER STUFF and agreed to purchase 5/4
packaged ALL TOGETHER, defendant HERNANDEZ sold cocaine to
.
10
74. On March 4, 2016, in a series of telephone communications, defendant

HERNANDEZ asked a customer, WHAT YOU NEED? to which the
customer responded, BLOW, to which defendant HERNANDEZ replied,
I KNOW THAT, HOW MUCH? and told the customer he was on his way.
75. On or about March 5, 2016, in the vicinity of Orchard Street and Rivington
sold cocaine to
76. On or about March 5, 2016, in the vicinity of Orchard Street and Rivington
ordered 150 MORE TO THE SAME PLACE, defendant
77. On or about March 5, 2016, in the vicinity of 1082 Eastern Parkway, Kings
ordered 220 FOR THE 5 while AT HOME, defendant
78. On or about March 8, 2016, in the vicinity of Second Avenue and East 5th Street,
ordered 100?2 bags, defendant HERNANDEZ sold cocaine
to
79. On or about March 8, 2016, in the vicinity of 43 West 13th Street, after a series
ordered
200 but agreed to DO 3 [to] GET 4, defendant HERNANDEZ sold

cocaine to
80. On or about March 8, 2016, in the vicinity of First Avenue and East 7th Street,
ordered 100 to a DELI ON THE CORNER, defendant HERNANDEZ
sold cocaine to
11
81. On or about March 10, 2016, in a series of telephone communications,

defendant HERNANDEZ agreed to sell cocaine to a police officer known to
the Grand Jury.
82. On or about March 10, 2016, in the vicinity of 100 Delancey Street, defendant
83. On or about March 11, 2016, in the vicinity of 637 East 6th Street, after a series
of telephone communications during which CHRISTIAN JEWETT ordered
4 FOR 5 to MY APT, defendant HERNANDEZ sold cocaine to
CHRISTIAN JEWETT.
Street, after a series of telephone communications during which defendant
HERNANDEZ told
I GOT IT LIKE YOU WANT IT
TODAY, defendant HERNANDEZ sold cocaine to
85. On or about March 11, 2016, in the vicinity of Essex Street and Delaney Street,
ordered 100 to the THE NINETY-NINE CENT STORE, defendant
87. On or about March 12, 2016, in the vicinity of Second Avenue and East 51ST
Street, after a series of telephone communications during which AUSTIN
DODSON
ordered
$120
to
RESTAURANT,
defendant
HERNANDEZ sold cocaine to AUSTIN DODSON.
12
88. On or about March 16, 2016, in a telephone conversation, a co-conspirator told

defendant HERNANDEZ, IM WAITING FOR THAT NIGGA MAN,
to which defendant HERNANDEZ responded, AND THE OTHER
ONE? and the co-conspirator replied, I DIDNT LIKE THAT SHIT THAT
HE BRING YESTERDAY. THAT SHIT WAS WET.
89. On or about March 18, 2016, in a telephone conversation, defendant
HERNANDEZ stated, MIGHT HAVE TO PUT IN WORK OVER
THERE. MY SHIT DEAD RIGHT NOW SON. YOU WANT SOME? to
which a co-conspirator responded, MY COUSIN GOT THIS NIGGA SHIT
TOO, WHICH IS BETTER, but, HE DONT TAKE SAMPLES LIKE
THAT, HE ONLY TAKES TEN GIRLS AS A SAMPLE, to which defendant
HERNANDEZ responded, IM NOT GIVING TEN GRAMS THOUGH
IN ONE NIGHT, to which the co-conspirator replied, NO, I KNOW
THAT, HE BUYS IT and defendant HERNANDEZ said, TELL HIM TO
BRING IT TO ME THEN.
90. On or about March 18, 2016, in a telephone conversation, defendant
HERNANDEZ asked a co-conspirator, HOW MUCH YOU DO FOR AN
EIGHT? and told the co-conspirator BRING ME THAT THEN.
91. On or about March 18, 2016, in a telephone conversation, a co-conspirator,
asked defendant HERNANDEZ, YOU MIND IF I HAVE LANCE
BRING
ME
WHOLE
RIGHT
NOW?
to
which
defendant
HERNANDEZ replied, I DONT CARE, TELL HIM TO SELL IT.

92. On or about March 19, 2016, in the vicinity of 162 Orchard Street, after a series
ordered 100 while AT WORK, defendant HERNANDEZ sold cocaine
to
93. On or about March 19, 2016, in a telephone conversation, a co-conspirator,

asked defendant HERNANDEZ, YOU GET THAT OR NO? to which
defendant HERNANDEZ replied, THEY ONLY HAD EIGHTS.
13
94. On or about March 20, 2016, in a series of telephone conversations, a customer

ordered 200 to Second Avenue and East 34th Street and defendant
HERNANDEZ directed the customer to meet inside of a CVS pharmacy and
told the customer in what aisle defendant HERNANDEZ would be.
95. On or about March 21, 2016, in the vicinity of Second Avenue and East 85th
CHRISTIAN JEWETT.
96. On or about March 22, 2016, in a telephone conversation, a co-conspirator told
defendant HERNANDEZ, I CAN BRING THE HALF RIGHT NOW
TOO, IF YOU WANT, and shortly thereafter, a co-conspirator arrived by
vehicle and entered and exited 138 Ludlow Street.
97. On or about March 24, 2016, in a telephone conversation, a co-conspirator
asked defendant HERNANDEZ, WHAT YOU NEED? to which
defendant HERNANDEZ replied, LIKE, TEN.
ordered 120 TO MY SPOT, defendant HERNANDEZ sold
cocaine to
99. On or about March 25, 2016, in the vicinity of Second Avenue and East 41st
HOLMES ordered TWO BETWEEN SECOND AND THIRD,
defendant HERNANDEZ sold cocaine to KYLE HOLMES.
100.
On or about March 26, 2016, in a telephone conversation, a co-
conspirator told defendant HERNANDEZ, I HAVE SOMEONE BY 2

AND 2ND, to which defendant HERNANDEZ replied, WHAT THEY
WANT? and asked for the address.
14
101.
conspirator told defendant HERNANDEZ, THAT SHIT WAS FUCKING

HALF BY POWER, HE SAID ITS WHACK THEN BASICALLY, to which
defendant HERNANDEZ responded, THATS THE WORK I GOT
TOO.
102.
conspirator told defendant HERNANDEZ, I HAVE SOMEONE OUT

DOOR ON 38TH AND 8, and defendant HERNANDEZ replied, OK.
103.
On or about March 27, 2016, in the vicinity of Second Avenue and East

CHRISTOPHER DODSON ordered 1.5 to DUANE READE because
he
only
had
100, defendant
HERNANDEZ
sold
cocaine
to
CHRISTOPHER DODSON.
104.
On or about March 30, 2016, in a series of telephone communications,
defendant HERNANDEZ agreed to sell more than one half of one ounce of
cocaine to a police officer known to the Grand Jury.
105.
On or about March 30, 2016, in the vicinity of 110 Ludlow Street,
defendant HERNANDEZ sold more than one half of one ounce of cocaine
to a police officer known to the Grand Jury.
106.
conspirator asked defendant HERNANDEZ YOU THINK YOU COULD

MAKE TEN GIRLS FOR ME AND GIVE IT TO ME? to which defendant
HERNANDEZ responded, LISTEN, UM, I TOOK TWENTY FROM
THERE, to which the co-conspirator asked, CAN YOU MAKE THE REST
AND GIVE IT TO ME THEN? and defendant HERNANDEZ reiterated,
I TOOK OUT TWENTY GRAMS.
107.
On or about March 31, 2016, in a telephone communication, a male
customer said, I NEED COKE PLEASE, after which defendant
15
HERNANDEZ agreed to sell the customer cocaine and said he would see the
customer soon.
108.
On or about March 31, 2016, in the vicinity of 132 West 3rd Street, after
a series of telephone communications during which ALEXANDER

MALLORY ordered 200 to MY PLACE and said to BUZZ 2,
defendant HERNANDEZ sold cocaine to ALEXANDER MALLORY.
109.
On or about March 31, 2016, in the vicinity of 412 West 25th Street, after
a series of telephone communications during which KATHERINE

WELNHOFER ordered 200, defendant HERNANDEZ sold cocaine to
KATHERINE WELNHOFER.
110.
On or about April 2, 2016, in the vicinity of 162 Orchard Street, after a

ordered cocaine, defendant HERNANDEZ sold cocaine to
.
111.
On or about April 4, 2016, in a telephone conversation, defendant
HERNANDEZ said to a co-conspirator, THIS NIGGA TEXT ME

TODAY IF WE COULD TAKE THE WHOLE THING, to which the coconspirator asked FOR THE THREE-FIVE OR THE NUMBER BETTER
THAN THAT? to which defendant HERNANDEZ replied that he DONT
WANT TO TAKE THAT RESPONSIBILITY AND THEN TAKE MAD
LONG TO DO IT MYSELF, to which the co-conspirator replied MY
COUSIN HAS SOMEBODY.
112.
On or about April 5, 2016, in the vicinity of 69 Central Avenue, Kings

ordered 200 while AT HOME, defendant HERNANDEZ
sold cocaine to
113.
On or about April 8, 2016, in a telephone conversation, a co-conspirator
told defendant HERNANDEZ, I HAVE SOMEONE ON 74TH, to which
16
defendant HERNANDEZ then called a female customer, confirmed her

location and that she needed ONE, and said he was on his way.
114.
On or about April 9, 2016, in a telephone conversation, a co-conspirator
asked defendant HERNANDEZ, HOW MUCH HE PAYING? to which

defendant HERNANDEZ replied IM SAYING FORTY-TWO, FORTYTHREE AROUND THERE, to which the co-conspirator responded, TEXT
HIM AND SHOW HIM WHAT YOU GOT AND THEN ILL JUST BRING
THE FIFTY.
115.
On or about April 11, 2016, in a telephone conversation, a co-
conspirator, asked defendant HERNANDEZ, YOU ALREADY GOT

THAT FROM P OR NO? to which defendant HERNANDEZ replied he
hadnt, and the co-conspirator said FUCK IT, IM ABOUT TO GET IT
FROM SOMEBODY ELSE.
116.
On or about April 13, 2016, in the vicinity of Bowery and East 4th Street,
after a series of telephone communications during which CHRISTIAN

CHRISTIAN JEWETT.
117.
On or about March 25, 2016, in the vicinity of Lexington Avenue and
East 100th Street, after a series of telephone communications during which

ordered
118.
120
TO
MY
SPOT,
defendant
On or about April 13, 2016, in the vicinity of Eighth Avenue and West
22nd Street, after a series of communications during which

ORDERED 200, defendant HERNANDEZ sold cocaine to
JAMES HULIHAN.
119.
On or about April 13, 2016, in a series of telephone communications,

the Grand Jury.
17
120.
On or about April 13, 2016, in the vicinity of 110 Ludlow Street,
defendant HERNANDEZ sold cocaine to a police officer known to the

Grand Jury.
121.
HERNANDEZ told a co-conspirator, CALL ME WHEN YOU AROUND

SO I CAN GIVE YOU SOME BREAD.
122.
On or about April 14, 2016, in the vicinity of Second Avenue and East

123.
conspirator asked defendant HERNANDEZ, YOU MAKE THOSE

UNITS OR NO? and told defendant HERNANDEZ to MAKE
STRAIGHT HUNDOS and defendant HERNANDEZ replied, I GOT
YOU.
124.
HERNANDEZ, told a co-conspirator, I DID A COUPLE HUNDRED

AND THE REST FIFTY, to which the co-conspirator responded I
THOUGHT IT WAS LIKE TEN GRAMS THERE? to which defendant
HERNANDEZ replied, CALL ME IF YOU GONNA COME PICK IT
UP.
125.
On or about April 16, 2016, in the vicinity of First Avenue and East 79th

ordered THREE TIMES, defendant HERNANDEZ
sold cocaine to
126.
HERNANDEZ told a co-conspirator ILL LET YOU KNOW WHATS

THERE ANYWAY, to which the co-conspirator responded PROBABLY
LIKE THREE GIRLS IN TOTAL.
18
127.
conspirator told defendant HERNANDEZ, I WAS GONNA BE DOWN

THERE WITH PRODUCT IN AN HOUR.
128.
On or about April 17, 2016, in the vicinity of Second Avenue and East

129.
HERNANDEZ told a co-conspirator IM GOING TO GIVE YOU

SEVEN. HES GOING TO GIVE YOU SEVEN-FIFTY. YOU GONNA
GET LIKE FIFTEEN HUNDRED and to JUST PICK IT UP.
130.
conspirator asked defendant HERNANDEZ, YOU GOT GIRLS OVER

THERE? to which defendant HERNANDEZ replied, NO, IM AT THE
AIRPORT.
131.
On or about April 17, 2016, in the vicinity of Lexington Avenue and
East 60th Street, after a series of telephone communications during which a coconspirator told
he had REALLY GOOD stuff,

agreed to buy 5/4 200 and was later told by the co-
conspirator to HOP IN THE FRONT of a white Mercedes, at which time

the co-conspirator sold cocaine to
132.
East 53rd Street, after a series of telephone communications during which

CHRISTOPHER DODSON ordered 4 FOR 240 and a co-conspirator told
CHRISTOPHER DODSON HES GONNA BE IN A WHITE
MERCEDES BETWEEN 53RD AND 54TH, A WHITE E-CLASS, HE HAS
LIKE GLASSES, at which time the co-conspirator sold cocaine to
CHRISTOPHER DODSON.
19
133.
On or about April 19, 2016, in the vicinity of Sixth Avenue and
Washington Place, after a series of telephone communications during which

ALEXANDER MALLORY ordered 60 FOR 1 to a CVS pharmacy, a coconspirator sold cocaine to ALEXANDER MALLORY.
134.
On or about April 20, 2016, in a series of telephone communications, a
customer ordered TWO HUNDRED WORTH to Worth Street and Wall

Street, to which a co-conspirator responded that he was Jays Cousin, that
Jay was in the Dominican Republic but he would SEND HIS GUY, and
thereafter called the customer and told the customer to HOP IN THE BLUE
CAR, ITS A BLUE HONDA.
135.
On or about April 20, 2016, in the vicinity of 162 Orchard Street, after
a series of telephone communications during which

ordered 100, a co-conspirator sold cocaine to
.
136.
East 53rd Street, a co-conspirator sold cocaine to CHRISTOPHER

DODSON.
137.
On or about April 21, 2016, in the vicinity of 43 West 13th Street, after a

ordered 200 and agreed to wait in the lobby of 43 West 13th Street, a coconspirator sold cocaine to
138.

Jury.
139.
On or about April 21, 2016, in the vicinity of 109 Essex Street, defendant
NUNEZ, sold cocaine to a police officer known to the Grand Jury.

140.
On or about April 22, 2016, in the vicinity of 637 East 6th Street, after a
series of telephone communications during which CHRISTIAN JEWETT
20
ordered 2 HUNDREDS to MY APT, a co-conspirator sold cocaine to

CHRISTIAN JEWETT.
141.
On or about April 23, 2016, a co-conspirator called another male and
asked the male to add minutes to the cell phone bill of 646-704-6955.
142.
On or about April 23, 2016, in the vicinity of 31-60 33rd Street, Queens
County, after a series of telephone communications during which KYLE

HOLMES ordered THREE to his apartment and a co-conspirator told
KYLE HOLMES IM IN THE WHITE MERCEDES, HOP UP FRONT,
a co-conspirator sold cocaine to KYLE HOLMES.
143.
On or about April 27, 2016, in the vicinity of 43 West 13th Street, after a

ordered 200 and agreed to wait in the lobby of 43 West 13th Street, a coconspirator sold cocaine to
144.
On or about April 27, 2016, in the vicinity of 315 West 55th Street, after
a series of telephone communications during which a co-conspirator told

he had only had ONE-HUNDRED PIECES,
agreed to buy TWO FOR $180 and was later told by the coconspirator to get into a blue Nissan, at which time the co-conspirator sold
cocaine to
145.
HERNANDEZ asked a co-conspirator, WHEN ARE YOU GOING TO

BRING ME THE PHONE?
146.
co-conspirator asked defendant HERNANDEZ, U GOT MONEY, SEEMS

LIKE MY WORK IS FREE AFTER A CERTAIN AMOUNT.
147.
On or about April 29, 2016, in the vicinity of Sixth Avenue and West
57th Street, after a series of telephone communications during which KYLE

HOLMES ordered TWO to THE RESTAURANT QUALITY
ITALIAN, defendant HERNANDEZ sold cocaine to KYLE HOLMES.
21
148.
On or about April 30, 2016, in the vicinity of 495 Broome Street, after a

ordered 200 and agreed to wait RIGHT INSIDE 495 Broome Street,
149.
On or about May 1, 2016, in the vicinity of Second Avenue and East
32nd Street, after a series of telephone communications during which defendant

HERNANDEZ agreed to GIVE [CHRISTOPHER DODSON] THREE
and allowed CHRISTOPHER DODSON TO PAY THE FOUR
HUNDRED ON FRIDAY, defendant HERNANDEZ sold cocaine to
CHRISTOPHER DODSON.
150.
On or about May 1, 2016, in a telephone conversation, a co-conspirator
asked defendant HERNANDEZ, WHAT HAPPENED? to which

defendant HERNANDEZ replied, I WAS SUPPOSED TO SEE LIKE
TWO PEOPLE AND THEY FLAKED ON ME. ILL CALL YOU AS
SOON AS I HAVE IT.
151.
asked defendant HERNANDEZ, YOU KNOW ANYONE THAT

WANTS WEIGHT RIGHT NOW? to which the co-conspirator said IM
GOING TO BRING FOUR BILLS THEN, but asked defendant
HERNANDEZ, BRING THAT MUCH OR JUST BRING LIKE TWO?
to which defendant HERNANDEZ replied, BRING IT THEN.
152.
told defendant HERNANDEZ, IM JUST GOING TO BRING THE

WHOLE THING OVER THERE, CAUSE TO OPEN IT AT MY CRIB IS
GOING TO BE JUST CRAZY.
153.
told defendant HERNANDEZ to OPEN THE DOOR, and the coconspirator then entered 138 Ludlow Street carrying a backpack, and exited 138
Ludlow Street without the backpack.
22
154.
On or about May 5, 2016, in the vicinity of Sixth Avenue and

ALEXANDER MALLORY ordered 100 to a CVS pharmacy, defendant
HERNANDEZ sold cocaine to ALEXANDER MALLORY.
155.
On or about May 5, 2016, in a series of telephone communications, a

the Grand Jury.
156.
On or about May 5, 2016, in the vicinity of 119 Ludlow Street, defendant

157.

ALEXANDER MALLORY ordered 100 to a CVS pharmacy, a coconspirator sold cocaine to ALEXANDER MALLORY.
158.
On or about May 6, 2016, in the vicinity of 77 Water Street, after a series
of telephone communications during which ROMAN YOFFE agreed to DO

4 /6 at THE OFFICE, defendant HERNANDEZ sold cocaine to
ROMAN YOFFE.
159.
On or about May 6, 2016, in the vicinity of 637 East 6th Street, after a
series of telephone communications during which CHRISTIAN JEWETT

ordered 4/5, defendant HERNANDEZ sold cocaine to CHRISTIAN
JEWETT.
160.
asked defendant HERNANDEZ, YOU GOT BREAD FOR ME? to which

defendant
HERNANDEZ
responded,
SHITS
DEAD
TODAY,
TOMORROW IS FRIDAY, to which the co-conspirator replied HOW

ABOUT THAT SHIT, YOU FOUND OUT IF ITS GOOD OR NOT? and
defendant HERNANDEZ stated, YEP, BUT HE SAID IT WAS
OFFICIAL.
23
161.
said to defendant HERNANDEZ, I GOT THESE TEN YAMS ON ME,

SHOULD I BRING IT UP OR NO? to which defendant HERNANDEZ
asked, YOU GOT WHAT? and the co-conspirator replied, TEN YAMS IN
THE STASH, and defendant HERNANDEZ told the co-conspirator,
NAH, LEAVE THAT SHIT THERE.
162.
On or about May 8, 2016, in a series of telephone conversations, a co-
conspirator asked defendant HERNANDEZ, WOULD YOU MIND IF

THIS WHITE KID COMES THROUGH TO GET TWENTY GIRLS? and
asked YOU MIND SEPARATING TENS AND FIVES FOR THIS GUY?
To which defendant HERNANDEZ replied, TEN AND FIVE, THATS
ALL HE WANTS IS FIFTEEN? and later stated THAT NIGGA GAVE
ME THREE-FIFTY.
163.
On or about May 8, 2016, in a series of telephone conversations, a
customer asked defendant HERNANDEZ, YOU GOT ANY ADERALL?

to which defendant HERNANDEZ replied, NO. I HAVE SOME GOOD
WHITE. TRY WHAT I HAVE AND IF YOU DONT LIKE IT, ILL GIVE
YOU YOUR MONEY BACK.
164.

ALEXANDER MALLORY ordered 100 to a CVS pharmacy, defendant
HERNANDEZ sold cocaine to ALEXANDER MALLORY.
165.
told defendant HERNANDEZ, YO KENNY, I NEED TWO RIGHT

NOW, PULLING UP THE FRONT, causing defendant HERNANDEZ to
admonish the co-conspirator, YOU CANT BE BRINGING NIGGAS TO
MY BUILDING, but later said ILL BUZZ YOU IN.
24
166.
series
On or about May 10, 2016, in the vicinity of 132 West 3rd Street, after a
of
telephone
communications
during
which
ALEXANDER
MALLORY ordered 200 AT MY PLACE, defendant HERNANDEZ sold

cocaine to ALEXANDER MALLORY.
167.

ALEXANDER MALLORY ordered 100 to CVS pharmacy, a coconspirator sold cocaine to ALEXANDER MALLORY.
168.
On or about May 11, 2016, in the vicinity of 157 Allen Street, after a

ordered 100 while AT WORK, defendant HERNANDEZ sold cocaine
to
169.
.
On or about May 11, 2016, in the vicinity of 43 West 13th Street, after a

ordered 200, defendant HERNANDEZ sold cocaine to
170.
On or about May 12, 2016, in telephone conversations, a co-conspirator
told defendant HERNANDEZ, I GOT SOME NIGGA THAT LOOKING

TO TAKE LIKE TEN, TWENTY, BUZZ ME UP, and I GOT GOOD
NEWS ACROSS THE BOARD. JUST NINE, TEN, CALL IF YOU COULD
DO FIVE AND FIVE, JUST MAKE IT REAL QUICK SO I CAN RUN
RIGHT OUT, to which defendant HERNANDEZ responded, ILL CALL
YOU WHEN IM THERE THEN, to which the co-conspirator then said,
NIGGA WANTS TWENTY, SO HAVE THAT READY FOR HIM
TOMORROW, and defendant HERNANDEZ replied, ALRIGHT.
171.
On or about May 12, 2016, in the vicinity of 412 West 25th Street, after
a series of telephone communications during which KATHERINE

WELNHOFER ordered 2 BAGS, defendant HERNANDEZ sold cocaine
to KATHERINE WELNHOFER.
25
172.
On or about May 13, 2016, in the vicinity of Essex Street and Delaney

ordered 150 to THAT CHINESE STORE and was told he
would receive A FREE ONE because defendant HERNANDEZ was late,
173.
On or about May 13, 2016, in a telephone conversation, defendant
HERNANDEZ told a co-conspirator, YOU NEED TO BE ON YOUR

SHIT, COME FAST, TODAY IS FRIDAY WHEN I START, WHEN I GO
OUTSIDE I LAST THREE, FOUR HOURS, THEN I COME BACK, GET
ANOTHER.
174.
told defendant HERNANDEZ, BOWERY BETWEEN STANTON AND

HOUSTON, 255, GR GALLERY, BRING TWO HUNDO. Then in a
separate telephone conversation, defendant HERNANDEZ confirmed the
sale with a male customer and told the customer, HEY, IM HERE, YOU IN
THE GALLERY?
175.
On or about May 14, in the vicinity of 43 West 13th Street, after a series
ordered
200 and agreed to wait in the lobby of 43 West 13th Street, a co-conspirator
sold cocaine to
176.
On or about May 16, 2016, in the vicinity of Second Avenue and East

CHRISTOPHER DODSON ordered MORE and asked, AM I GIVING
YOU THE MONEY I OWE YOU?, a co-conspirator sold cocaine to
CHRISTOPHER DODSON.
177.
HERNANDEZ asked a co-conspirator, THIS NIGGA PAY YOU?

CHRIS? to which the co-conspirator replied, YEAH.
26
178.
On or about May 16, 2016, in the vicinity of 156 Second Avenue, a co-
conspirator sold cocaine to CHRISTIAN JEWETT.

179.
On or about May 18, 2016, in a series of telephone communications, a

Jury.
180.
On or about May 18, 2016, in the vicinity of 112 Ludlow Street,
defendant NUNEZ sold cocaine to a police officer known to the Grand Jury.
181.
On or about May 18, 2016, in the vicinity of 77 Water Street, after a
series of telephone communications during which ROMAN YOFFE agreed

to purchase 250 FOR 300 inside a WHITE MERCEDES, defendant
NUNEZ sold more than 500 milligrams of cocaine by pure weight to
ROMAN YOFFE.
182.
On or about May 20, 2016, in the vicinity of Ludlow Street and Delaney

ordered 100 to the 99 CENT STORE and a co-conspirator told
that his BOY would be at the Duane Reade pharmacy, a
co-conspirator sold cocaine to
183.
On or about May 20, 2016, in the vicinity of 230 Gates Avenue, Kings

ordered THREE HUNDRED and met with a coconspirator driving a WHITE CAR, a co-conspirator sold cocaine to
.
184.
On or about May 22, 2016, in the vicinity of Broadway and West 49th
Street, after a series of telephone communications during which a cohe had only had ONE-HUNDRED
conspirator told
PIECES,
agreed to buy $300 for $250 and was later
told by the co-conspirator to HOP IN FRONT of a white Mercedes, at which

time the co-conspirator sold cocaine to
27
185.
series
On or about May 25, 2016, in the vicinity of 313 First Avenue, after a
of
telephone
communications
during
which
ordered 5 FOR 200, a co-conspirator sold cocaine to

.
186.
On or about May 29, 2016, in the vicinity of Stanton Street between
Chrystie Street and the Bowery, after a series of telephone communications

during which CHRISTOPHER DODSON ordered $240 and was directed
to take cocaine from inside a blue Nissan Maxima, defendant NUNEZ sold
CHRISTOPHER DODSON cocaine.
187.
On or about May 29, 2016, in the vicinity of Stanton Street between
Chrystie Street and the Bowery, after a series of telephone communications

during which defendant NUNEZ directed a male customer to a blue Nissan,
New York license plate HEF 3858, parked on Stanton Street, defendant
NUNEZ sold cocaine to another individual.
188.
HERNANDEZ told defendant NUNEZ, I JUST LANDED. Defendant

NUNEZ replied, YOU KNOW YOU GOT SAVED RIGHT NOW. WE
BOTH GOT SAVED, THAT NIGGA WAS WORKING WITH THEM
THE WHOLE TIME.
189.
On or about May 30, 2016, in telephone conversations, defendant
HERNANDEZ told defendant NUNEZ, THE PHONE NIGGA, YOU

IN THE CRIB? YOU WANT ME TO GET IT? TEXT ME THE
ADDRESS, IM IN A CAB RIGHT NOW. IM RIGHT HERE IN
QUEENS.
190.
On or about May 30, 2016, in a telephone call, defendant
HERNANDEZ called himself to test a new cellular telephone, a phone that

defendant HERNANDEZ transitioned to in order to take customer orders.
28
191.
On or about June 2, 2016, in a telephone conversation, a co-conspirator
asked defendant HERNANDEZ, YOU ON DECK AND SHIT? I NEED

TWENTY OF THEM, to which defendant HERNANDEZ replied,
COME TO MY BUILDING, 138 LUDLOW.
192.
On or about June 5, 2016, in a telephone conversation, defendant
HERNANDEZ told a co-conspirator, YO, MY BOY HIT ME UP. HE

SAID HE COULD ONLY BRING ME EIGHTY FOR TODAY, YOU
WANT IT? to which the co-conspirator replied, YEAH, I GUESS.
193.
On or about June 7, 2016, in a series of telephone communications, a
police officer know to the grand jury asked defendant HERNANDEZ, YOU
AROUND THIS WEEKEND? to which defendant HERNANDEZ
responded from a new telephone number, and said ITS JAY, THIS IS MY
NEW NUMBER, SAVE IT. WHAT YOU NEED? CALL ME AT THIS
NUMBER, I WONT HAVE THE OTHER NUMBER NO MORE.
29
SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses
the defendant KENNY HERNANDEZ of the crime of OPERATING AS A
MAJOR TRAFFICKER, in violation of Penal Law 220.77(1), committed as follows:
The defendant, in the County of New York and elsewhere, acted as director of
a controlled substance organization during the period from on or about June 1, 2015
to on or about May 31, 2016, during which period such controlled substance
organization sold a controlled substance, to wit, cocaine, and the proceeds collected
and due from such sales had a total aggregate value of seventy-five thousand dollars
and more.
THIRD COUNT:
the defendant KENNY HERNANDEZ of the crime of CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Penal Law 220.39(1), committed as follows:
The defendant, in the County of New York, on or about June 1, 2015,
knowingly and unlawfully sold to a police officer known to the Grand Jury, a narcotic
drug, to wit, cocaine.
30
FOURTH COUNT:
FIFTH COUNT:
31
SIXTH COUNT:
The defendant, in the County of New York, on or about July 1, 2015, knowingly
and unlawfully sold to a police officer known to the Grand Jury, a narcotic drug, to wit,
cocaine.
SEVENTH COUNT:
the defendants KENNY HERNANDEZ and FELIX NUNEZ of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Penal Law 220.39(1), committed as follows:
The defendants, in the County of New York, on or about July 22, 2015,
32
EIGHTH COUNT:
The defendant, in the County of New York, on or about September 2, 2016,
NINTH COUNT:
the defendant KENNY HERNANDEZ and OSCAR ALMONTE of the crime of
The defendants, in the County of New York, on or about October 6, 2016,
33
TENTH COUNT:
The defendants, in the County of New York, on or about October 13, 2015,
ELEVENTH COUNT:
The defendant, in the County of New York, on or about October 20, 2015,
34
TWELFTH COUNT:
The defendant, in the County of New York, on or about October 29, 2015,
THIRTEENTH COUNT:
The defendant, in the County of New York, on or about November 11, 2015,
35
FOURTEENTH COUNT:
The defendant, in the County of New York, on or about November 23, 2015,
FIFTEENTH COUNT:
CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of
The defendant, in the County of New York, on or about December 21, 2015,
knowingly and unlawfully sold to a police officer known to the Grand Jury one or more
preparations, compounds, mixtures and substances containing a narcotic drug and the
preparations, compounds, mixtures and substances were of an aggregate weight of onehalf ounce or more.
36
SIXTEENTH COUNT:
The defendants, in the County of New York, on or about January 4, 2016,
SEVENTEENTH COUNT:
The defendant, in the County of New York, on or about January 26, 2016,
knowingly and unlawfully sold to CHRISTOPHER DODSON, a narcotic drug, to
wit, cocaine.
37
EIGHTEENTH COUNT:
knowingly and unlawfully sold to
, a narcotic drug, to wit,
cocaine.
NINTEENTH COUNT:
knowingly and unlawfully sold to KYLE HOLMES, a narcotic drug, to wit, cocaine.
38
TWENTIETH COUNT:
cocaine.
TWENTY-FIRST COUNT:
wit, cocaine.
39
TWENTY-SECOND COUNT:
The defendant, in the County of New York, on or about February 2, 2016,
cocaine.
TWENTY-THIRD COUNT:
wit, cocaine.
40
TWENTY-FOURTH COUNT:
TWENTY-FIFTH COUNT:
, a narcotic drug, to wit, cocaine.
41
TWENTY-SIXTH COUNT:
knowingly and unlawfully sold to AUSTIN DODSON, a narcotic drug, to wit,
cocaine.
TWENTY-SEVENTH COUNT:
wit, cocaine.
42
TWENTY-EIGHTH COUNT:
TWENTY-NINTH COUNT:
cocaine.
43
THIRTIETH COUNT:
cocaine.
THIRTY-FIRST COUNT:
wit, cocaine.
44
THIRTY-SECOND COUNT:
The defendant, in the County of Kings, on or about February 14, 2016,
cocaine.
THIRTY-THIRD COUNT:
cocaine.
45
THIRTY-FOURTH COUNT:
cocaine.
THIRTY-FIFTH COUNT:
, a narcotic drug, to
wit, cocaine.
46
THIRTY-SIXTH COUNT:
knowingly and unlawfully sold to CHRISTIAN JEWETT, a narcotic drug, to wit,
cocaine.
THIRTY-SEVENTH COUNT:
wit, cocaine.
47
THIRTY-EIGHTH COUNT:
wit, cocaine.
THIRTY-NINTH COUNT:
48
FOURTIETH COUNT:
cocaine.
FORTY-FIRST COUNT:
cocaine.
49
FORTY-SECOND COUNT:
FORTY-THIRD COUNT:
knowingly and unlawfully sold to ROMAN YOFFE, a narcotic drug, to wit, cocaine.
50
FORTY-FOURTH COUNT:
wit, cocaine.
FORTY-FIFTH COUNT:
51
FORTY-SIXTH COUNT:
cocaine.
FORTY-SEVENTH COUNT:
The defendant, in the County of New York, on or about March 1, 2016,
52
FORTY-EIGHTH COUNT:
wit, cocaine.
FORTY-NINTH COUNT:
53
FIFTIETH COUNT:
FIFTY-FIRST COUNT:
54
FIFTH-SECOND COUNT:
FIFTY-THIRD COUNT:
wit, cocaine.
55
FIFTY-FOURTH COUNT:
FIFTY-FIFTH COUNT:
cocaine.
56
FIFTY-SIXTH COUNT:
cocaine.
FIFTY-SEVENTH COUNT:
The defendant, in New York County and elsewhere, on or about March 5, 2016,
cocaine.
57
FIFTY-EIGHTH COUNT:
cocaine.
FIFTY-NINTH COUNT:
cocaine.
58
SIXTIETH COUNT:
SIXTY-FIRST COUNT:
59
SIXTY-SECOND COUNT:
cocaine.
SIXTY-THIRD COUNT:
60
SIXTY-FOURTH COUNT:
SIXTY-FIFTH COUNT:
wit, cocaine.
61
SIXTY-SIXTH COUNT:
knowingly and unlawfully sold to AUSTIN DODSON, a narcotic drug, to wit,
cocaine.
SIXTY-SEVENTH COUNT:
cocaine.
62
SIXTY-EIGHTH COUNT:
cocaine.
SIXTY-NINTH COUNT:
63
SEVENTIETH COUNT:
SEVENTY-FIRST COUNT:
wit, cocaine.
64
SEVENTY-SECOND COUNT:
SEVENTY-THIRD COUNT:
knowingly and unlawfully sold to ALEXANDER MALLORY, a narcotic drug, to
wit, cocaine.
65
SEVENTY-FOURTH COUNT:
knowingly and unlawfully sold to KATHERINE WELNHOFER, a narcotic drug,
to wit, cocaine.
SEVENTY-FIFTH COUNT:
The defendant, in the County of New York, on or about April 2, 2016,
cocaine.
66
SEVENTY-SIXTH COUNT:
The defendant, in New York County and elsewhere, on or about April 5, 2016,
cocaine.
SEVENTY-SEVENTH COUNT:
67
SEVENTY-EIGHTH COUNT:
cocaine.
SEVENTY-NINTH COUNT:
68
EIGHTIETH COUNT:
cocaine.
EIGHTY-FIRST COUNT:
wit, cocaine.
69
EIGHTY-SECOND COUNT:
wit, cocaine.
EIGHTY-THIRD COUNT:
wit, cocaine.
70
EIGHTY-FOURTH COUNT:
EIGHTY-FIFTH COUNT:
wit, cocaine.
71
EIGHTY-SIXTH COUNT:
wit, cocaine.
EIGHTY-SEVENTH COUNT:
cocaine.
72
EIGHTY-EIGHTH COUNT:
The defendants, in the County of New York, on or about April 21, 2016,
EIGHTY-NINTH COUNT:
wit, cocaine.
73
NINTIETH COUNT:
cocaine.
NINETY-FIRST COUNT:
cocaine.
74
NINETY-SECOND COUNT:
The defendant, in New York County and elsewhere, on or about April 23, 2016,
NINETY-THIRD COUNT:
cocaine.
75
NINETY-FOURTH COUNT:
NINETY-FIFTH COUNT:
76
NINETY-SIXTH COUNT:
cocaine.
NINETY-SEVENTH COUNT:
The defendant, in the County of New York, on or about May 1, 2016, knowingly
and unlawfully sold to CHRISTOPHER DODSON, a narcotic drug, to wit, cocaine.
77
NINETY-EIGHTH COUNT:
and unlawfully sold to a police officer known to the Grand Jury, a narcotic drug, to wit,
cocaine.
NINETY-NINTH COUNT:
and unlawfully sold to ALEXANDER MALLORY, a narcotic drug, to wit, cocaine.
78
ONE HUNDREDTH COUNT:

ONE HUNDRED-FIRST COUNT:

and unlawfully sold to ROMAN YOFFE, a narcotic drug, to wit, cocaine.
79
ONE HUNDRED-SECOND COUNT:

and unlawfully sold to CHRISTIAN JEWETT, a narcotic drug, to wit, cocaine.
ONE HUNDRED-THIRD COUNT:

80
ONE HUNDRED-FOURTH COUNT:

The defendant, in the County of New York, on or about May 10, 2016,
wit, cocaine.
ONE HUNDRED-FIFTH COUNT:

wit, cocaine.
81
ONE HUNDRED-SIXTH COUNT:

cocaine.
ONE HUNDRED-SEVENTH COUNT:

cocaine.
82
ONE HUNDRED-EIGHTH COUNT:

knowingly and unlawfully sold to KATHERINE WELNHOFER, a narcotic drug,
to wit, cocaine.
ONE HUNDRED-NINTH COUNT:

83
ONE HUNDRED-TENTH COUNT:

cocaine.
ONE HUNDRED-ELEVENTH COUNT:

wit, cocaine.
84
ONE HUNDRED-TWELFTH COUNT:

cocaine.
ONE HUNDRED-THIRTEENTH COUNT:

The defendants, in the County of New York, on or about May 18, 2016,
85
ONE HUNDRED-FOURTEENTH COUNT:

The defendants, in the County of New York, on or about May 18, 2016,
ONE HUNDRED-FIFTEENTH COUNT:

86
ONE HUNDRED-SIXTEENTH COUNT:

The defendant, in the County of Kings, on or about May 20, 2016, knowingly
and unlawfully sold to
ONE HUNDRED-SEVENTEENTH COUNT:

87
ONE HUNDRED-EIGHTEENTH COUNT:

wit, cocaine.
ONE HUNDRED-NINTEENTH COUNT:

wit, cocaine.
CYRUS R. VANCE, JR.

District Attorney
88

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

THE GRAND JURY OF THE COUNTY OF NEW YORK, by this

24. On or about November 23, 2015, in a series of telephone communications, a

200 but agreed to DO 3 [TO] GET 4, defendant HERNANDEZ sold

HERNANDEZ sold cocaine to KYLE HOLMES.

[HERNANDEZ] JUST GOT, defendant HERNANDEZ sold cocaine to

HERNANDEZ sold cocaine to KYLE HOLMES.

defendant HERNANDEZ sold cocaine to

74. On March 4, 2016, in a series of telephone communications, defendant

200 but agreed to DO 3 [to] GET 4, defendant HERNANDEZ sold

81. On or about March 10, 2016, in a series of telephone communications,

I GOT IT LIKE YOU WANT IT

TODAY, defendant HERNANDEZ sold cocaine to

HERNANDEZ sold cocaine to AUSTIN DODSON.

88. On or about March 16, 2016, in a telephone conversation, a co-conspirator told

HERNANDEZ replied, I DONT CARE, TELL HIM TO SELL IT.

93. On or about March 19, 2016, in a telephone conversation, a co-conspirator,

94. On or about March 20, 2016, in a series of telephone conversations, a customer

On or about March 26, 2016, in a telephone conversation, a co-

conspirator told defendant HERNANDEZ, I HAVE SOMEONE BY 2

On or about March 26, 2016, in a telephone conversation, a co-

conspirator told defendant HERNANDEZ, THAT SHIT WAS FUCKING

On or about March 26, 2016, in a telephone conversation, a co-

conspirator told defendant HERNANDEZ, I HAVE SOMEONE OUT

32nd Street, after a series of telephone communications during which

On or about March 30, 2016, in a series of telephone communications,

On or about March 30, 2016, in the vicinity of 110 Ludlow Street,

On or about March 31, 2016, in a telephone conversation, a co-

conspirator asked defendant HERNANDEZ YOU THINK YOU COULD

On or about March 31, 2016, in a telephone communication, a male

customer said, I NEED COKE PLEASE, after which defendant

a series of telephone communications during which ALEXANDER

a series of telephone communications during which KATHERINE

On or about April 2, 2016, in the vicinity of 162 Orchard Street, after a

series of telephone communications during which

On or about April 4, 2016, in a telephone conversation, defendant

HERNANDEZ said to a co-conspirator, THIS NIGGA TEXT ME

On or about April 5, 2016, in the vicinity of 69 Central Avenue, Kings

County, after a series of telephone communications during which

On or about April 8, 2016, in a telephone conversation, a co-conspirator

told defendant HERNANDEZ, I HAVE SOMEONE ON 74TH, to which

defendant HERNANDEZ then called a female customer, confirmed her

On or about April 9, 2016, in a telephone conversation, a co-conspirator

asked defendant HERNANDEZ, HOW MUCH HE PAYING? to which

On or about April 11, 2016, in a telephone conversation, a co-

conspirator, asked defendant HERNANDEZ, YOU ALREADY GOT

after a series of telephone communications during which CHRISTIAN

On or about March 25, 2016, in the vicinity of Lexington Avenue and

East 100th Street, after a series of telephone communications during which

22nd Street, after a series of communications during which

On or about April 13, 2016, in a series of telephone communications,

defendant HERNANDEZ agreed to sell cocaine to a police officer known to

On or about April 13, 2016, in the vicinity of 110 Ludlow Street,

defendant HERNANDEZ sold cocaine to a police officer known to the

On or about April 13, 2016, in a telephone conversation, defendant

HERNANDEZ told a co-conspirator, CALL ME WHEN YOU AROUND

32nd Street, after a series of telephone communications during which

On or about April 14, 2016, in a telephone conversation, a co-

conspirator asked defendant HERNANDEZ, YOU MAKE THOSE

On or about April 15, 2016, in a telephone conversation, defendant

HERNANDEZ, told a co-conspirator, I DID A COUPLE HUNDRED

Street, after a series of telephone communications during which