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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK -against JOSE LUPERON, ‘OMAR LUPERON, JUAN FLORES, TYREAK ANDERSON, EDDIE OCASIO, STEVE ROJAS, XAVIER VARGAS, ALFRED ARIAS, RAMON ALMONTE, JESSE COLLADO, FRANCISCO MEDINA, MIGUEL TEJADA, |ARISMENDY SANTANA, ROBINSON COLLADO, JULIO VELAZQUEZ, EDWARD ADAMES, ALAN BURGOS, MERLIN CHAMA, JESSIE CONTRERAS, BRIAN ESPINAL, MIGUEL GARCIA, CRISTIAN GUZMAN, JAHACIEL HERNANDEZ, CHRISTOPHER MORATO, ELIAS RIVA, RADHAMES ROJAS, EDWARD SANCHEZ, RAFAEL SOLANO, MATTHEW TINEO, MELVIN TINEO, WILLIAM VELEZ, ALEJANDRO BAUTISTA, Defendants. THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses defendant JOSE, LUPERON of the crime of OPERATING AS A MAJOR TRAFFICKER, in violation of Penal Law § 220.77(2), committed as follows: The defendant JOSE L ERON in the County of New York and elsewhere, during the period from on ot about June 30, 2016, to on ot about to on or about the date of this indictment, as a profiteer, knowingly and unlawfully sold, a narcotic drug, to wit, cocaine, and the proceeds collected and due from such sales had a total aggregate value of seventy-five thousand dollars or more. SECOND COUNT ‘AND THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, further accuses defendant OMAR LUPERON of the crime of OPERATING AS A MAJOR TRAFFICKER, in violation of Penal Law § 220.772), committed as follows: ‘The defendant OMAR LUPERON in the County of New York and elsewhere, dusing the period from on ot about June 30, 2016, to on or about to on or about the date of this indictment, as a profiteer, knowingly and unlawfully sold, a narcotic drug, to wit, cocaine, and the proceeds collected and due from such sales had a total aggregate value of seventy-five thousand dollars or mote. THIRD COUNT AND THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses defendants 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, duting the period from August 29, 2015, to on of about the date of this indictment, with intent that conduct constituting the crimes of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE and CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE be performed, said crimes each being a class “A” felony, agreed with each other and others to engage in and cause the performance of such conduct. THE CONSPIRACY During the period of this conspiracy, defendants were members and associates of a narcotics distribution organization, which was principally engaged in the sale of cocaine, in and around areas of the Inwood neighborhood of New York County, among other locations. Defendants and other members of the organization, in furtherance of the narcotics distribution business: (i) obtained and transported quantities of cocaine; (i) possessed, processed, packaged, and stored quantities of cocaine; (ji) communicated with each other and others for the purpose of engaging in cocaine sales; and (iv) distributed and sold quantities of cocaine. It was part of said conspiracy for defendants and others to conceal the existence and puspose of the conspiracy and the nature of defendants’ illegal activities. Defendants attempted to do this by performing their activities in a covert manner, Tt was part of said conspiracy for defendant JOSE LUPERON to serve as the director, supervisor, and “boss” of the organization, by: @) maintaining sources of supply of cocaine; (i) controlling and directing the distribution of cocaine by the organization; (ii) ensuring that the cocaine was processed and packaged; (iv) providing said packaged cocaine to the workers of the narcotics distribution organization; (v) monitoring the sales of the organization's cocaine to the customers of the narcotics distribution organization; and (vi) apportioning and collecting the proceeds from the sale of cocaine, It was part of said conspiracy for defendant OMAR LUPERON to serve as a supervisor of the organization, by: () maintaining sources of supply of cocaine; (i) controlling and directing the distribution of cocaine by the organization; (ji) ensuring that the cocaine was processed and packaged; (iv) providing said packaged cocaine to the workers of the narcotics distribution organization; (v) monitoring the sales of the onganization’s cocaine to the customers of the narcotics distribution organization; and (vi) apportioning and collecting the proceeds from the sale of cocaine. It was part of said conspiracy for defendant JUAN FLORES to serve as a supervisor of the organization, by: @ maintaining soutces of supply of cocaine; (i) controlling and directing the distribution of cocaine by the organization; (ii) ensuring that the cocaine was processed and packaged; (iv) providing said packaged cocaine to the workers of the narcotics distribution organization; (v) monitoring the sales of the organization's cocaine to the customers of the narcotics distribution organization; and (vi) apportioning and collecting the proceeds from the sale of cocaine. It was part of said conspiracy for defendants STEVE ROJAS and XAVIER VARGAS to operate the narcotics distribution osganization, by: ()) monitoring the sales of the organization's cocaine to the customers of the narcoties distribution organization; and (i) monitoring and directing the activities and positions of the lookouts and steerers Tt was part of conspitacy for defendant ALFRED ARIAS and others to: @ collect the proceeds of the cocaine sales to the organization’s customers, and (ji) transfer those proceeds to defendants JOSE LUPERON, OMAR LUPERON, and JUAN FLORES. It was part of said conspiracy for defendant JULIO VELAZQUEZ and others to deliver the organization’s narcotics from the packaging and storage location to the sales location. It was part of said conspiracy for defendants JESSE COLLADO, RAMON ALMONTE, TYREAK ANDERSON, EDDIE OCASIO, FRANCIS -5-

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