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****DCJS FOR INDICTMENT******

INDICTMENT
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------
THE PEOPLE OF THE STATE OF NEW YORK :
AGAINST :
X. EDDIE MARTINS : INDICTMENT NO. 07467-2017
DEFENDANT : CIVIL RIGHTS BUREAU
X. RICHARD HALL :
DEFENDANT :
:
------------------------------------------------------------

PL 130.35(1) RAPE IN THE FIRST DEGREE


AFO: N SEX CRIME: Y
PL 130.25(3) RAPE IN THE THIRD DEGREE
AFO: N SEX CRIME: Y
PL 130.65(1) SEXUAL ABUSE IN THE FIRST DEGREE (5 COUNTS)
AFO: N SEX CRIME: Y
PL 130.20(1) SEXUAL MISCONDUCT
AFO: N SEX CRIME: Y
PL 130.20(2) SEXUAL MISCONDUCT (2 COUNTS)
AFO: N SEX CRIME: Y
PL 130.55 SEXUAL ABUSE IN THE THIRD DEGREE (5 COUNTS)
AFO: N SEX CRIME: Y
PL 130.50(1) CRIMINAL SEXUAL ACT IN THE FIRST DEGREE (2 COUNTS)
AFO: N SEX CRIME: Y
PL 130.40(3) CRIMINAL SEXUAL ACT IN THE THIRD DEGREE (2 COUNTS)
AFO: N SEX CRIME: Y
PL 130.52(1) FORCIBLE TOUCHING (2 COUNTS)
AFO: N SEX CRIME: Y
PL 135.20 KIDNAPPING IN THE SECOND DEGREE
AFO: N SEX CRIME: N
PL 135.05 UNLAWFUL IMPRISONMENT IN THE SECOND DEGREE
AFO: N SEX CRIME: N
PL 135.60(1) COERCION IN THE SECOND DEGREE (5 COUNTS)
AFO: N SEX CRIME: N
PL 135.60(4) COERCION IN THE SECOND DEGREE (5 COUNTS)
AFO: N SEX CRIME: N
PL 135.60(8) COERCION IN THE SECOND DEGREE (5 COUNTS)
AFO: N SEX CRIME: N
PL 135.65(1) COERCION IN THE FIRST DEGREE (5 COUNTS)
AFO: N SEX CRIME: N
PL 200.10 BRIBE RECEIVING IN THE THIRD DEGREE
AFO: N SEX CRIME: N
PL 195.00(1) OFFICIAL MISCONDUCT (6 COUNTS)
AFO: N SEX CRIME: N
KINGS COUNTY DISTRICT ATTORNEY
NOTICE OF FILED INDICTMENT

DATE: OCTOBER 26, 2017

DEFENDANT DOCKET NUMBER

EDDIE MARTINS
RICHARD HALL

INDICTMENT NUMBER: 07467-2017 DATE FILED:

NEXT DATE:

NEXT PART:

FRANK DEGAETANO
-------------------------------------------------
ASSISTANT DISTRICT ATTORNEY
INDICTMENT
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

------------------------------------------------------------
THE PEOPLE OF THE STATE OF NEW YORK :
: INDICTMENT NO. 07467-2017
AGAINST : CIVIL RIGHTS BUREAU
:
:
X. EDDIE MARTINS-VFO :
DEFENDANT :
X. RICHARD HALL-VFO :
DEFENDANT :
:
:

-----------------------------------------------------------

COUNTS
RAPE IN THE FIRST DEGREE
RAPE IN THE THIRD DEGREE
SEXUAL ABUSE IN THE FIRST DEGREE (5 COUNTS)
SEXUAL ABUSE IN THE THIRD DEGREE (5 COUNTS)
SEXUAL MISCONDUCT (3 COUNTS)
CRIMINAL SEXUAL ACT IN THE FIRST DEGREE (2 COUNTS)
CRIMINAL SEXUAL ACT IN THE THIRD DEGREE (2 COUNTS)
FORCIBLE TOUCHING (2 COUNTS)
KIDNAPPING IN THE SECOND DEGREE
UNLAWFUL IMPRISONMENT IN THE SECOND DEGREE
COERCION IN THE SECOND DEGREE (15 COUNTS)
COERCION IN THE FIRST DEGREE (5 COUNTS)
BRIBE RECEIVING IN THE THIRD DEGREE
OFFICIAL MISCONDUCT (6 COUNTS)

A TRUE BILL ERIC GONZALEZ


ACTING DISTRICT ATTORNEY
__________________________
FOREPERSON
FIRST COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF RAPE IN THE FIRST DEGREE [PL 130.35(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANT EDDIE MARTINS, ACTING IN CONCERT WITH THE DEFENDANT
RICHARD HALL, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND
STATE OF NEW YORK, ENGAGED IN SEXUAL INTERCOURSE WITH ANOTHER PERSON, NAMELY:
REDACTED, BY MEANS OF FORCIBLE COMPULSION.

SECOND COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF RAPE IN THE THIRD DEGREE [PL 130.25(3)] COMMITTED AS
FOLLOWS:
THE DEFENDANT EDDIE MARTINS, ACTING IN CONCERT WITH THE DEFENDANT
RICHARD HALL, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND
STATE OF NEW YORK, ENGAGED IN SEXUAL INTERCOURSE WITH ANOTHER PERSON, NAMELY:
REDACTED, WITHOUT SUCH PERSONS CONSENT WHERE SUCH LACK OF CONSENT IS BY
REASON OF SOME FACTOR OTHER THAN INCAPACITY TO CONSENT.

THIRD COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE FIRST DEGREE [PL 130.65(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE PENIS OF THE
DEFENDANT EDDIE MARTINS TO THE VAGINA OF REDACTED, BY MEANS OF FORCIBLE
COMPULSION.

FOURTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL MISCONDUCT [PL 130.20(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANT EDDIE MARTINS, ACTING IN CONCERT WITH THE DEFENDANT
RICHARD HALL, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND
STATE OF NEW YORK, ENGAGED IN SEXUAL INTERCOURSE WITH ANOTHER PERSON, NAMELY:
REDACTED, WITHOUT SUCH PERSONS CONSENT.

FIFTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE THIRD DEGREE [PL 130.55] COMMITTED
AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE PENIS OF THE
DEFENDANT EDDIE MARTINS TO THE VAGINA OF REDACTED, WITHOUT SUCH PERSONS
CONSENT.

SIXTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF CRIMINAL SEXUAL ACT IN THE FIRST DEGREE [PL 130.50(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, ENGAGED IN ORAL SEXUAL CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS
OF THE DEFENDANT EDDIE MARTINS AND THE MOUTH OF REDACTED, BY MEANS OF FORCIBLE
COMPULSION.
SEVENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF CRIMINAL SEXUAL ACT IN THE THIRD DEGREE [PL 130.40(3)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, ENGAGED IN ORAL SEXUAL CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS
OF THE DEFENDANT EDDIE MARTINS AND THE MOUTH OF REDACTED,WITHOUT SUCH
PERSONS CONSENT WHERE SUCH LACK OF CONSENT IS BY REASON OF SOME FACTOR OTHER
THAN INCAPACITY TO CONSENT.

EIGHTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE FIRST DEGREE [PL 130.65(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE PENIS
OF THE DEFENDANT EDDIE MARTINS TO THE MOUTH OF REDACTED, BY MEANS OF FORCIBLE
COMPULSION.

NINTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL MISCONDUCT [PL 130.20(2)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, ENGAGED IN ORAL SEXUAL CONDUCT WITH ANOTHER PERSON, NAMELY:
CONTACT BETWEEN THE PENIS OF THE DEFENDANT EDDIE MARTINS AND THE MOUTH OF
REDACTED, WITHOUT SUCH PERSONS CONSENT.

TENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE THIRD DEGREE [PL 130.55] COMMITTED
AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE PENIS
OF THE DEFENDANT EDDIE MARTINS TO THE MOUTH OF REDACTED, WITHOUT SUCH PERSONS
CONSENT.

ELEVENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE FIRST DEGREE [PL 130.65(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING
THE HAND OF THE DEFENDANT EDDIE MARTINS TO THE VAGINA, AND/OR BREAST, AND/OR
BUTTOCKS OF REDACTED, BY MEANS OF FORCIBLE COMPULSION.
TWELFTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF FORCIBLE TOUCHING [PL 130.52(1)] COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, INTENTIONALLY, AND FOR NO LEGITIMATE PURPOSE, FORCIBLY TOUCHED THE
SEXUAL OR OTHER INTIMATE PARTS OF ANOTHER PERSON, NAMELY: CONTACT BETWEEN THE
HAND OF THE DEFENDANT EDDIE MARTINS TO THE VAGINA, AND/OR BREAST, AND/OR
BUTTOCKS OF REDACTED, FOR THE PURPOSE OF DEGRADING OR ABUSING REDACTED, OR FOR
THE PURPOSE OF GRATIFYING THE ACTORS SEXUAL DESIRE.

THIRTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE THIRD DEGREE [PL 130.55] COMMITTED
AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE HAND
OF THE DEFENDANT EDDIE MARTINS TO THE VAGINA, AND/OR BREAST, AND/OR BUTTOCKS OF
REDACTED, WITHOUT SUCH PERSONS CONSENT.

FOURTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF CRIMINAL SEXUAL ACT IN THE FIRST DEGREE [PL 130.50(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, ENGAGED IN ORAL SEXUAL CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS
OF THE DEFENDANT RICHARD HALL AND THE MOUTH OF REDACTED, BY MEANS OF FORCIBLE
COMPULSION.

FIFTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF CRIMINAL SEXUAL ACT IN THE THIRD DEGREE [PL 130.40(3)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTIN AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, ENGAGED IN ORAL SEXUAL CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS
OF THE DEFENDANT RICHARD HALL AND THE MOUTH OF REDACTED, WITHOUT SUCH
PERSONS CONSENT WHERE SUCH LACK OF CONSENT IS BY REASON OF SOME FACTOR OTHER
THAN INCAPACITY TO CONSENT.

SIXTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE FIRST DEGREE [PL 130.65(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE PENIS
OF THE DEFENDANT RICHARD HALL TO THE MOUTH OF REDACTED, BY MEANS OF FORCIBLE
COMPULSION.
SEVENTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL MISCONDUCT [PL 130.20(2)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS EDDIE MARTIN AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, ENGAGED IN ORAL SEXUAL CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS
OF THE DEFENDANT RICHARD HALL AND THE MOUTH OF REDACTED, WITHOUT SUCH
PERSONS CONSENT.

EIGHTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE THIRD DEGREE [PL 130.55] COMMITTED
AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE PENIS
OF THE DEFENDANT RICHARD HALL TO THE MOUTH OF REDACTED, WITHOUT SUCH PERSONS
CONSENT.

NINETEENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE FIRST DEGREE [PL 130.65(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE HAND
OF THE DEFENDANT RICHARD HALL TO THE BREAST OF REDACTED, BY MEANS OF FORCIBLE
COMPULSION.

TWENTIETH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF FORCIBLE TOUCHING [PL 130.52(1)] COMMITTED AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, INTENTIONALLY, AND FOR NO LEGITIMATE PURPOSE, FORCIBLY TOUCHED THE
SEXUAL OR OTHER INTIMATE PARTS OF ANOTHER PERSON, NAMELY: CONTACT BETWEEN THE
HAND OF THE DEFENDANT RICHARD HALL AND THE BREAST OF REDACTED, FOR THE
PURPOSE OF DEGRADING OR ABUSING REDACTED, OR FOR THE PURPOSE OF
GRATIFYING THE ACTORS SEXUAL DESIRE.

TWENTY FIRST COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF SEXUAL ABUSE IN THE THIRD DEGREE [PL 130.55] COMMITTED
AS FOLLOWS:
THE DEFENDANTS EDDIE MARTINS AND RICHARD HALL, ACTING IN CONCERT WITH
EACH OTHER, ON OR ABOUT SEPTEMBER 15, 2017, IN THE COUNTY OF KINGS, CITY AND STATE
OF NEW YORK, SUBJECTED REDACTED TO SEXUAL CONTACT BY TOUCHING THE HAND OF THE
DEFENDANT RICHARD HALL TO THE BREAST OF REDACTED, WITHOUT SUCH
PERSONS CONSENT.
TWENTY SECOND COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF KIDNAPPING IN THE SECOND DEGREE [PL 135.20]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMEBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, ABDUCTED REDACTED.

TWENTY THIRD COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF UNLAWFUL IMPRISONMENT IN THE SECOND DEGREE
[PL 135.05] COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, RESTRAINED REDACTED.

TWENTY FOURTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: SEXUAL INTERCOURSE WITH THE DEFENDANT
EDDIE MARTINS, WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO
ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY
MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH,
THE DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE
PHYSICAL INJURY TO HER.

TWENTY FIFTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS OF THE
DEFENDANT EDDIE MARTINS AND THE MOUTH OF REDACTED, WHICH SHE HAD A
LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT
IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A
FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS
AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO HER.

TWENTY SIXTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS IDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE HAND OF THE
DEFENDANT EDDIE MARTINS AND THE VAGINA, AND/OR BREAST, AND/OR BUTTOCKS OF
REDACTED, WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN
FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF
INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH, THE
DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE
PHYSICAL INJURY TO HER.
TWENTY SEVENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS OF THE
DEFENDANT RICHARD HALL AND THE MOUTH OF REDACTED, WHICH SHE HAD A
LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT
IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A
FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS
AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO HER.

TWENTY EIGHTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(1)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE HAND OF THE
DEFENDANT RICHARD HALL AND THE BREAST OF REDACTED, WHICH SHE HAD A
LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT
IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A
FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS
AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO HER.

TWENTY NINTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(4)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: SEXUAL INTERCOURSE WITH THE DEFENDANT
EDDIE MARTINS, WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO
ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY
MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH,
THE DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD ACCUSE
REDACTED OF A CRIME OR CAUSE CRIMINAL CHARGES TO BE INSTITUTED AGAINST HER.

THIRTIETH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(4)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS OF EDDIE
MARTINS AND THE MOUTH OF REDACTED, WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM
ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL
RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS
NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD
HALL WOULD ACCUSE REDACTED OF A CRIME OR CAUSE CRIMINAL CHARGES TO BE
INSTITUTED AGAINST HER.
THIRTY FIRST COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(4)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE HAND OF THE
DEFENDANT EDDIE MARTINS AND THE VAGINA, AND/OR BREAST, AND/OR BUTTOCKS OF
REDACTED, WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN
FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF
INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH, THE
DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD ACCUSE
REDACTED OF A CRIME OR CAUSE CRIMINAL CHARGES TO BE INSTITUTED AGAINST HER.

THIRTY SECOND COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(4)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS OF THE
DEFENDANT RICHARD HALL AND THE MOUTH OF REDACTED, WHICH SHE HAD A LEGAL RIGHT
TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH
SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF
THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS AND/OR THE
DEFENDANT RICHARD HALL WOULD ACCUSE REDACTED OF A CRIME OR CAUSE CRIMINAL
CHARGES TO BE INSTITUTED AGAINST HER.

THIRTY THIRD COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(4)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE HAND OF THE
DEFENDANT RICHARD HALL AND THE BREAST OF REDACTED, WHICH SHE HAD A LEGAL RIGHT
TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH
SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF
THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS AND/OR THE
DEFENDANT RICHARD HALL WOULD ACCUSE REDACTED OF A CRIME OR CAUSE CRIMINAL
CHARGES TO BE INSTITUTED AGAINST HER.

THIRTY FOURTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(8)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: SEXUAL INTERCOURSE WITH THE DEFENDANT
EDDIE MARTINS, IN WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO
ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY
MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH,
THE DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD ABUSE HIS
POSITION AS A PUBLIC SERVANT BY PERFORMING SOME ACT WITHIN OR RELATED
TO HIS OFFICIAL DUTIES, OR BY FAILING OR REFUSING TO PERFORM AN OFFICIAL DUTY, IN
SUCH A MANNER AS TO AFFECT REDACTED ADVERSELY.
THIRTY FIFTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(8)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS OF THE
DEFENDANT EDDIE MARTINS AND THE MOUTH OF REDACTED, WHICH SHE HAD A LEGAL RIGHT
TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH
SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF
THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS AND/OR THE
DEFENDANT RICHARD HALL WOULD ABUSE HIS POSITION AS A PUBLIC SERVANT BY
PERFORMING SOME ACT WITHIN OR RELATED TO HIS OFFICIAL DUTIES, OR BY FAILING OR
REFUSING TO PERFORM AN OFFICIAL DUTY, IN SUCH A MANNER AS TO AFFECT REDACTED
ADVERSELY.

THIRTY SIXTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(8)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE HAND OF THE
DEFENDANT EDDIE MARTINS AND THE VAGINA, AND/OR BREAST, AND/OR BUTTOCKS OF
REDACTED, WHICH SHE HAD A LEGAL RIGHT TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN
FROM ENGAGING IN CONDUCT IN WHICH SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF
INSTILLING IN REDACTED A FEAR, THAT IF THE DEMAND WAS NOT COMPLIED WITH, THE
DEFENDANT EDDIE MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD ABUSE HIS
POSITION AS A PUBLIC SERVANT BY PERFORMING SOME ACT WITHIN OR RELATED TO HIS
OFFICIAL DUTIES, OR BY FAILING OR REFUSING TO PERFORM AN OFFICIAL DUTY, IN SUCH A
MANNER AS TO AFFECT REDACTED ADVERSELY.

THIRTY SEVENTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(8)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE PENIS OF THE
DEFENDANT RICHARD HALL AND THE MOUTH OF REDACTED, WHICH SHE HAD A LEGAL RIGHT
TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH
SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF
THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS AND/OR THE
DEFENDANT RICHARD HALL WOULD ABUSE HIS POSITION AS A PUBLIC SERVANT BY
PERFORMING SOME ACT WITHIN OR RELATED TO HIS OFFICIAL DUTIES, OR BY FAILING OR
REFUSING TO PERFORM AN OFFICIAL DUTY, IN SUCH A MANNER AS TO AFFECT REDACTED
ADVERSELY.
THIRTY EIGHTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE SECOND DEGREE [PL 135.60(8)]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMPELLED OR INDUCED
REDACTED TO ENGAGE IN CONDUCT, NAMELY: CONTACT BETWEEN THE HAND OF THE
DEFENDANT RICHARD HALL AND THE BREAST OF REDACTED, WHICH SHE HAD A LEGAL RIGHT
TO ABSTAIN FROM ENGAGING IN, OR TO ABSTAIN FROM ENGAGING IN CONDUCT IN WHICH
SHE HAD A LEGAL RIGHT TO ENGAGE, BY MEANS OF INSTILLING IN REDACTED A FEAR, THAT IF
THE DEMAND WAS NOT COMPLIED WITH, THE DEFENDANT EDDIE MARTINS AND/OR THE
DEFENDANT RICHARD HALL WOULD ABUSE HIS POSITION AS A PUBLIC SERVANT BY
PERFORMING SOME ACT WITHIN OR RELATED TO HIS OFFICIAL DUTIES, OR BY FAILING OR
REFUSING TO PERFORM AN OFFICIAL DUTY, IN SUCH A MANNER AS TO AFFECT REDACTED
ADVERSELY.

THIRTY NINTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE FIRST DEGREE [PL 135.65(1)] COMMITTED
AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMMITED THE CRIME OF
COERCION IN THE SECOND DEGREE AS CHARGED IN COUNT TWENTY-FOUR, AND THEY
COMMITTED SUCH CRIME BY INSTILLING IN REDACTED A FEAR THAT THE DEFENDANT EDDIE
MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO
HER.

FORTIETH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE FIRST DEGREE [PL 135.65(1)] COMMITTED
AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMMITED THE CRIME OF
COERCION IN THE SECOND DEGREE AS CHARGED IN COUNT TWENTY-FIVE AND THEY
COMMITTED SUCH CRIME BY INSTILLING IN REDACTED A FEAR THAT THE DEFENDANT EDDIE
MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO
HER.

FORTY FIRST COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE FIRST DEGREE [PL 135.65(1)] COMMITTED
AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMMITED THE CRIME OF
COERCION IN THE SECOND DEGREE AS CHARGED IN COUNT TWENTY-SIX AND THEY
COMMITTED SUCH CRIME BY INSTILLING IN REDACTED A FEAR THAT THE DEFENDANT EDDIE
MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO
HER.

FORTY SECOND COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE FIRST DEGREE [PL 135.65(1)] COMMITTED
AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMMITED THE CRIME OF
COERCION IN THE SECOND DEGREE AS CHARGED IN COUNT TWENTY-SEVEN AND THEY
COMMITTED SUCH CRIME BY INSTILLING IN REDACTED A FEAR THAT THE DEFENDANT EDDIE
MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO
HER.

FORTY THIRD COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF COERCION IN THE FIRST DEGREE [PL 135.65(1)] COMMITTED
AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, COMMITED THE CRIME OF
COERCION IN THE SECOND DEGREE AS CHARGED IN COUNT TWENTY-EIGHT, AND THEY
COMMITTED SUCH CRIME BY INSTILLING IN REDACTED A FEAR THAT THE DEFENDANT EDDIE
MARTINS AND/OR THE DEFENDANT RICHARD HALL WOULD CAUSE PHYSICAL INJURY TO
HER.

FORTY FOURTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF BRIBE RECEIVING IN THE THIRD DEGREE [PL 200.10]
COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, SOLICITED, ACCEPTED, OR AGREED
TO ACCEPT ANY BENEFIT FROM REDACTED UPON AN AGREEMENT OR UNDERSTANDING
THAT THE DEFENDANT RICHARD HALL AND/OR THE DEFENDANT EDDIE MARTINS VOTE,
OPINION,
JUDGEMENT, ACTION, DECISION OR EXERCISE OF DISCRETION, AS A PUBLIC SERVANT OR AS
PUBLIC SERVANTS WOULD THEREBY BE INFLUENCED.

FORTY FIFTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF OFFICIAL MISCONDUCT [PL 195.00(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, WITH INTENT TO OBTAIN A
BENEFIT OR DEPRIVE REDACTED OF A BENEFIT, COMMITTED AN ACT RELATED TO THEIR
OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF THEIR OFFICIAL FUNCTIONS,
NAMELY: THE DEFENDANT EDDIE MARTINS ENGAGED IN SEXUAL INTERCOURSE WITH ANNA
POLEVAYA WHILE SHE WAS DETAINED BY THE DEFENDANT EDDIE MARTINS AND THE
DEFENDANT RICHARD HALL, KNOWING THAT SUCH ACT WAS UNAUTHORIZED.

FORTY SIXTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF OFFICIAL MISCONDUCT [PL 195.00(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, WITH INTENT TO OBTAIN A
BENEFIT OR DEPRIVE REDACTED OF A BENEFIT, COMMITTED AN ACT RELATED TO THEIR
OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF THEIR OFFICIAL FUNCTIONS,
NAMELY: CONTACT BETWEEN THE PENIS OF THE DEFENDANT EDDIE MARTINS AND THE
MOUTH OF REDACTED WHILE SHE WAS DETAINED BY THE DEFENDANT EDDIE MARTINS AND
THE DEFENDANT RICHARD HALL, KNOWING THAT SUCH ACT WAS UNAUTHORIZED.
FORTY SEVENTH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF OFFICIAL MISCONDUCT [PL 195.00(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, WITH INTENT TO OBTAIN A
BENEFIT OR DEPRIVE REDACTED OF A BENEFIT, COMMITTED AN ACT RELATED TO THEIR
OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF THEIR OFFICIAL FUNCTIONS,
NAMELY: CONTACT BETWEEN THE PENIS OF THE DEFENDANT RICHARD HALL AND THE MOUTH
OF REDACTED WHILE SHE WAS DETAINED BY THE DEFENDANT EDDIE MARTINS AND THE
DEFENDANT RICHARD HALL, KNOWING THAT SUCH ACT WAS UNAUTHORIZED.

FORTY EIGHTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF OFFICIAL MISCONDUCT [PL 195.00(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, WITH INTENT TO OBTAIN A
BENEFIT OR DEPRIVE REDACTED OF A BENEFIT, COMMITTED AN ACT RELATED TO THEIR
OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF THEIR OFFICIAL FUNCTIONS,
NAMELY: THE DEFENDANT EDDIE MARTINS TOUCHED HIS HAND TO THE VAGINA, AND/OR
BREAST, AND/OR BUTTOCKS OF REDACTED WHILE SHE WAS DETAINED BY THE DEFENDANT
EDDIE MARTINS AND THE DEFENDANT RICHARD HALL, KNOWING THAT SUCH ACT WAS
UNAUTHORIZED.

FORTY NINTH COUNT


THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF OFFICIAL MISCONDUCT [PL 195.00(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, WITH INTENT TO OBTAIN A
BENEFIT OR DEPRIVE REDACTED OF A BENEFIT, COMMITTED AN ACT RELATED TO THEIR
OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF THEIR OFFICIAL FUNCTIONS,
NAMELY: THE DEFENDANT RICHARD HALL TOUCHED HIS HAND TO THE BREAST OF REDACTED
WHILE SHE WAS DETAINED BY THE DEFENDANT EDDIE MARTINS AND THE DEFENDANT
RICHARD HALL, KNOWING THAT SUCH ACT WAS UNAUTHORIZED.

FIFTIETH COUNT
THE GRAND JURY OF THE COUNTY OF KINGS BY THIS INDICTMENT, ACCUSES THE
DEFENDANTS OF THE CRIME OF OFFICIAL MISCONDUCT [PL 195.00(1)] COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER 15, 2017,
IN THE COUNTY OF KINGS, CITY AND STATE OF NEW YORK, WITH INTENT TO OBTAIN A
BENEFIT OR DEPRIVE REDACTED OF A BENEFIT, COMMITTED AN ACT RELATED TO THEIR
OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF THEIR OFFICIAL FUNCTIONS,
NAMELY: THE DEFENDANT EDDIE MARTINS AND THE DEFENDANT RICHARD HALL RETURNED AN
ALLEGED CONTROLLED SUBSTANCE TO REDACTED, KNOWING THAT SUCH ACT WAS
UNAUTHORIZED.

ERIC GONZALEZ
ACTING DISTRICT ATTORNEY

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