COUNTY COURT COUNTY OF ONONDAGA STATE OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK Plaintiff Indictment No. 2016-0272-1 vs. Index No. 16-0309 RYAN LAWRENCE Defendant THE GRAND JURY OF THE COUNTY OF ONONDAGA by this indictment accuses RYAN LAWRENCE of the crime of MURDER IN THE FIRST DEGREE in violation of Section 125.27 (L)(a}(vii) and (b) of the Penal Law of the State of New York committed as follows. The said RYAN LAWRENCE, being over the age of 18 years old, on or about the 20th day of February, 2016, committed kidnapping in the first degree, and in the course of and in furtherance of such crime, intentionally caused the death of 22 month-old Maddox Lawrence; to wit: After abducting Maddox Lawrence from Onondaga County, the defendant unlawfully brought her to a remote and secluded location in Cortland County and intentionally struck Maddox Lawrence in the head with a wooden baseball bat resulting in blunt ‘force trauma that caused her death, The defendant then placed her body and the baseball bat in a prepared fire it for hours. Afterwards, the defendant took Maddox Lawrence's charred remains consisting of her head, torso, and parts of her legs, placed them in a container, transported them back to Onondaga County, tied her remains to a cement block, and disposed of those remains in Onondaga Creek. SECOND COUNT AND THE AFORESAID GRAND JURY by this Indictment further accuses RYAN LAWRENCE of the crime of KIDNAPPING IN THE FIRST DEGREE in violation of Section 135.25 (3) of the Penal Law of the State of New York, committed as follows. The said RYAN LAWRENCE, on or about the 20th day of February, 2016, at the City of Syracuse, in this county, abducted Maddox Lawrence and Maddox Lawrence died during the abduction. THIRD COUNT AND THE AFORESAID GRAND JURY by this Indictment further accuses RYAN LAWRENCE of the crime of MURDER IN THE SECOND DEGREE in violation of Section 125.25 (1) of the Penal Law of the State of New York, committed as follows. The said RYAN LAWRENCE, on or about the 20" day of February, 2016, intentionally caused the death of Maddox Lawrence; to wit: The defendant caused the death of Maddox Lawrence by intentionally striking Maddox Lawrence in the head with a wooden baseball bat resulting in blunt force trauma that caused her death, FOURTH COUNT AND THE AFORESAID GRAND JURY by this Indictment further accuses RYAN LAWRENCE of the crime of TAMPERING WITH PHYSICAL EVIDENCE in violation of Section 215.40 (2) of the Penal Law of the State of New York, committed as follows:The said RYAN LAWRENCE, on or about the 20° day of February, 2016, believing that certain physical evidence was about to be produced or used in an official proceeding or a prospective official proceeding, and intending to prevent such production or use, altered or destroyed such evidence; to wit: After abducting Maddox Lawrence and causing her death, the defendant built a fire at a remote and secluded Cortland County location and intentionally placed the body of Maddox Lawrence and the wooden baseball bat used to cause her death in the prepared fire pit in an effort to prevent the production or use of Maddox Lawrence's body and the wooden baseball bat at an official proceeding. Defendant additionally disposed of Maddox's remains in Onondaga Creek