STATE OF NEW YORK

TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

Complaint # ________

The People of the State of New York

-againstKENNETH C. YOUNGREN
4 Spruce St Alfred, NY 14802

FELONY
COMPLAINT

DOB; 12/10/1985

KORDELL J. JACKSON
DOB: 12/30/1975
107 Grangerford Heights, West Henrietta, NY 14586
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.
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. Kotin