ASSISTANT DISTRICT ATTORNEY NANCY NAYSON OF THE KINGS COUNTY DISTRICT ATTORNEY'S OFFICE SAYS THAT ON OR ABOUT JANUARY 18, 1998 AT APPROXIMATELY 10:00 AM AT 1813 NEW YORK AVENUE, COUNTY OF KINGS, STATE OF NEW YORK,
THE DEFENDANT COMMITTED THE OFFENSES OF:
PL 110/130.35-1 ATTEMPTED RAPE IN THE FIRST DEGREE
PL 130.65-1 SEXUAL ABUSE IN THE FIRST DEGREE
IN THAT THE DEFENDANT DID: SUBJECT A PERSON TO SEXUAL CONTACT BY FORCIBLE COMPULSION AND ATTEMPT TO ENGAGE IN SEXUAL INTERCOURSE BY FORCIBLE COMPULSION.
THE SOURCE OF DEPONENT'S INFORMATION AND THE GROUNDS FOR DEPONENT'S BELIEF ARE AS FOLLOWS:
THE DEPONENT IS INFORMED BY PASSION JULINSEY THAT, AT THE ABOVE TIME AND PLACE, THE INFORMANT OBSERVED THE DEFENDANT SAY TO INFORMANT "I'VE HAD IT" AND JUMP ON INFORMANT AND PIN INFORMANT TO THE FLOOR AND HOLD INFORMANT'S HANDS OVER HER HEAD AND SAY "WE'RE GOING TO FUCK", AFTER WHICH DEFENDANT ATTEMPTED TO PULL INFORMANT'S PANTS OFF AND PRESS DEFENDANTS BODY AGAINST THE INFORMANT'S AND CONTINUED TO TELL INFORMANT THAT THEY WERE GOING TO FUCK.
FALSE STATEMENTS MADE IN THIS DOCUMENT ARE PUNISHABLE AS A CLASS A MISDEMEANOR PURSUANT TO SECTION 210.45 OF THE PENAL LAW.
/s/_______________________________
DATE: 2/19/98 NANCY NAYSON
98K014430
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