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LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT...

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~ SUPERIOR COURT OF NEW JERSEY ...,~ LAW DIVISION - CRIMINAL F ~~ ~' ~' 201 State Grand Jury N umber SGJ729-19-3 ~ ~~~~ ~'~~~ ~~L~r~g~~~~ Superior Court Docket Number 1 9- ~~- 0 ~ ~ ~{ 4- S S TATE OF NEVJ JERSEY ) v . ) INDICTMENT FABIAN FRATER ) MARSHEA ANTHONY ) CHARLES JACKSON ) BRYANT NEVERS ) SHADEIK STR.ATFORD ) N HAZIR BRIGGS -SMITH ) J AHVON PARKER ) MICHAEL LAWHORN ) KARON NEVERS ) KELLY CUNNINGHAM ) PETER BRUNO ) PHOUNG LE ) N ICHOLAS NAPALITANO ) ALFONSO PETRILLO ) J OAN DALTON ) RONALD JOHNSTONE ) TIMOTHY NESTOR ) 1
Transcript
Page 1: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

~ SUPERIOR COURT OF NEW JERSEY...,~LAW DIVISION - CRIMINAL

F~~ ~' ~' 201 State Grand JuryNumber SGJ729-19-3

~~~~~ ~'~~~ ~~L~r~g~~~~ Superior CourtDocket Number 1 9- ~~- 0 ~ ~ ~{ 4- S

STATE OF NEVJ JERSEY )

v . ) INDICTMENT

FABIAN FRATER )

MARSHEA ANTHONY )

CHARLES JACKSON )

BRYANT NEVERS )

SHADEIK STR.ATFORD )

NHAZIR BRIGGS-SMITH )

JAHVON PARKER )

MICHAEL LAWHORN )

KARON NEVERS )

KELLY CUNNINGHAM )

PETER BRUNO )

PHOUNG LE )

NICHOLAS NAPALITANO )

ALFONSO PETRILLO )

JOAN DALTON )

RONALD JOHNSTONE )

TIMOTHY NESTOR )

1

Page 2: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

CLAUDINE BURDZY )

PAUL ZUR.AWSKI )

The Grand Jurors of and for the State of New Jersey, upon their

oaths, present that:

(Racketeering - First Degree)

FABIAN FRATER

MARSHEA ANTHONY

CHARLES JACKSON

BRYANT NEVERS

SHADEIK STR.A'I'FORD

NHAZIR BRIGGS-SMITH

JAHVON PARKER

MICHAEL LAWHORN

~ ~~

KARON NEVERS

and other persons whose identities are known and unknown to the

Grand Jurors, who are named as a co-conspirators and members of

the enterprise, but not as defendants herein, at the times and

places herein specified, did commit the crime of Racketeering,

that is, the defendants and other persons employed by or

associated with an enterprise engaged in or the activities of

2

Page 3: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

which affected trade or commerce, purposely or knowingly did

conduct or participate directly or indirectly, or did conspire

in the conduct of the enterprise's affairs through a pattern of

racketeering activity, including the commission of a crime of

the first degree, in violation of N.J.S.A. 2C:41-2c and N.J.S.A.

2C:41-2d, all as hereinafter described.

THE RELEVANT TIMES AND PLACES

The predicate criminal activity occurred between on or about

July 1, 2018, and on or about January 22, 2019, at the City of

Paterson, in the County of Passaic, in the State of New Jersey,

and within the jurisdiction of this Court.

THE ENTERPRISE

FABIAN FRATER, MARSHEA ANTHONY, CHARLES JACKSON, BRYANT NEVERS,

~~,~7~ mr~~r~r TTTTT n-rr~ r~r~ -rrrf'~ C'~T/~TTV TTT~ZT(1TT DTDTIL~D 1VjTCU'TTi'T.~ritij.J~1n. ~ 1 iCl-~ 1 1~ V.CC.L ~ 1VriHL~ 1IC DiC1.lJ17~7 - iJi' 1 1 tl ~ vtzt V vtv rrii`t`ul~. ~ i• i 11r1LL

LAWHORN, KARON NEVERS and other persons whose identities are

known and unknown to the Grand Jurors, who are named as a co-

conspirators and members of the enterprise, but not as

defendants herein, did constitute an enterprise within the

meaning of N.J.S.A. 2C:41-lc, that is, a group of individuals

associated in fact, for the purposes set forth below.

THE PURPOSES OF THE ENTERPRISE

The purposes of the enterprise included collectively generating

income on behalf of and for the benefit of members of the

enterprise through the distribution of controlled dangerous

3

Page 4: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

substances in this State; using a defined structure with roles

for each enterprise member or associate; dividing proceeds from

enterprise members' and associates' criminal activities in

accordance with enterprise protocol; and concealing from law

enforcement authorities the existence of the enterprise, the

means and locations from which it conducted its affairs,

including, but not limited to, using a variety of locations,

residences or motor vehicles for storage or delivery of

controlled dangerous substances that members and associates of

the enterprise bought and sold, and to conceal the profits

derived from these activities.

THE PATTERN OF RACKETEERING ACTIVITY

The pattern of racketeering activity, as defined in N.J.S.A.

it ~ ~-. a ~ ~ 1 i- ~- ~ r r i ~ ~ r~ ~- rti n v~ -~ r ~~ ~ ~F- ~ ~ ri i-v1..:41-1u, ~.Ull~l~l-CU Vl Ql~ 1-00.~71. 1.`%VG 111 L.L~.LGlll..ti7 V~ ia.t,.r~.~~.~crlily

conduct by the enterprise during the relevant time, including

Possession with Intent to Distribute a Controlled Dangerous

Substance (N.J.S.A. 2C:35-5) , Distribution of a Controlled

Dangerous Substance (N.J.S.A. 35-5) , Distribution of a

Controlled Dangerous Substance within 1,000 feet of School

Property (N.J.S.A. 2C:35-7) , Distribution of a Controlled

Dangerous Substance within 500 feet of Public Property (N.J.S.A.

2C:35-7.1) , Aggravated Assault (N.J.S.A. 2C:12-1) , Attempted

Murder (N.J.S.A. 2C:11-3) , Possession of a Firearm for an

Unlawful Purpose (N.J.S.A. 2C:39-4) , and Financial Facilitation

Page 5: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

of Criminal Activity (N.J.S.A. 2C:21-25) , and Conspiracy to

commit these crimes, as described herein and in Counts Two,

Three, Five, Nine, Ten, Twelve, Thirteen, Fifteen, Eighteen,

Nineteen, Twenty-One, Twenty-Two, Twenty-Four, Twenty-Five,

Twenty-Seven, Twenty-Eight, Thirty, Thirty-One, Thirty-Three,

Thirty-Four, Thirty-Six, Thirty-Seven, Thirty-Nine, Forty,

Forty-Two, Forty-Three, Forty-Five, Forty-Seven, Forty-Eight,

Fifty, and Fifty-One of this Indictment.

FABIAN FRATER

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; Financial Facilitation of

Criminal Activity; and Aggravated Assault; which racketeering

COIICIUCL 1S Llle SUIJ~ ~C:t Vi CvLiil~~ iwi~, TWCll~l.y - ~C V G1I.~ iiiJci~~y -

Eight, Thirty, Thirty-One, Thirty-Three, Thirty-Four, Thirty-

Six, Thirty-Seven, Thirty-Nine, Forty, Forty-Two, and Forty-

Three of this Indictment.

MARSHEA ANTHONY

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; Financial Facilitation of

Criminal Activity; and Aggravated Assault; which racketeering

conduct is the subject of Counts Two, Thirty, Thirty-One,

Thirty-Three, Thirty-Four, Thirty-Nine, Forty, and Forty-Five of

Page 6: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

this Indictment.

CHARLES JACKSON

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; and Financial Facilitation of

Criminal Activity; which racketeering conduct is the subject of

Counts Two, Twenty-One, Twenty-Two, Forty-Seven, and Forty-Eight

of this Indictment.

BRYANT NEVERS

did Commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; and Financial Facilitation of

Criminal Activity; which racketeering conduct is the subject of

r~..,..~-.-, mom.,.. mL. ,,.+-t. Tl-. ri-~r~,(lr,c~ 'T1-~~ rf-tr_Throo T1-~i rf tr_ T~y ~~ rl_.V U111., .7 1 wU J 1111 ~ Y ~ 11111 V v Vlll. ~ l llyl l~ V 1111 ̀ . \r ~ i ii11 li V i V ~i ~i 1 1 1

Thirty-Nine, and Forty of this Indictment.

SHADEIK STR.ATFORD

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; Possession of a Firearm for an

Unlawful Purpose; and Attempted Murder; which racketeering

conduct is the subject of Counts Two, Three, and Five of this

Indictment.

C•~

Page 7: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

NHAZIR BRIGGS -SMITH

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; which racketeering conduct is

the subject of Counts Two, Nine, Ten, Twelve, Thirteen, and

Fifteen of this Indictment.

JAHVON PARKER

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; which racketeering conduct is

the subject of Counts Two, Eighteen, Nineteen, Twenty-Four, and

Twenty-Five of this Indictment.

MICHAEL LAWHORN

~ ,_. i., 7 r a- ..r ., ,~,-, ~ , /Y{- l-~~ : o r, rr ~ rr i r~ ~ i n ~ r rY ~ ri c r~ r i nU1~,1 (~U~~~~~~.L L. l,i1C 't a.t_;nc ~ccL iiiy l.Ulll-.L~lr 1. !✓Y ~.~~yuy 111y 111 Vl L.V11Vt./l1 iit~

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; which racketeering conduct is

the subject of Counts Two, Twenty-Four, and Twenty-Five of this

Indictment.

KARON NEVERS

did commit the racketeering conduct by engaging in or conspiring

to commit repeated acts of Conspiracy; Distribution of a

Controlled Dangerous Substance; which racketeering conduct is

the subject of Counts Two, Fifty, and Fifty-One of this

Indictment.

7

Page 8: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

All in violation of N.J.S.A. 2C:41-2c and N.J.S.A. 2C:41-

2d, and against the peace of this State, the government and

dignity of the same.

E

Page 9: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

(Conspiracy - Second Degree)

FABIAN FRATER

MARSHEA ANTHONY

CHARLES JACKSON

BRYANT NEVERS 4

SHADEIK STRATFORD

NHAZIR BRIGGS-SMITH

JAHVON PARKER

MICHAEL LAWHORN

KARON NEVERS

between on or about July 1, 2018 and on or about January 22,

2U1~, at the c:izy oz raLe~s~ii, iii ~ ie Cvu~~~y ~f rassaic,

elsewhere, and within the jurisdiction of this Court, with the

, purpose of promoting or facilitating the commission of the crime

of Distribution of a Controlled Dangerous Substance, did agree

that:

A. One or more of them knowingly would engage in conduct

which would constitute the aforesaid crimes, or

B. One or more of them knowingly would aid in the planning,

solicitation, or commission of said crimes, that is:

1. Knowingly or purposely distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

Page 10: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

of N.J.S.A. 2C:35 -5a(1) , and N.J.S.A. 2C:35 -5b(3) .

2 . Knowingly or purposely distribute a controlled

dangerous substance, that is, cocaine, contrary to the

provisions of N.J.S.A. 2C:35 -5a(1) , N.J.S.A. 2C:35 -5b(3) , and

N.J.S.A. 2C:35 -5c.

3 . Knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of School Property, which is

owned by or leased to the Paterson Board of Education and used

for school purposes, contrary to the provisions of N.J.S.A.

2C:35-7.

4 . Knowingly or purposely did distribute a controlled

dangerous substance, that is, cocaine, in violation of N.J.S.A.

2C: 35-5a, while within i, uuu feel o~ ~c:i~~~i rLUNEL i y, w ~~~;h is

owned by or leased to the Paterson Board of Education and used

for school purposes, contrary to the provisions of N.J.S.A.

2C:35-7.

5 . Knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 500 feet of Public Property, contrary to

the provisions of N.J.S.A. 2C:35-7.1a

10

Page 11: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

6. Knowingly or purposely did distribute a controlled

dangerous substance, that is, Ketamine, a Schedule III

controlled dangerous substance, in violation of N.J.S.A. 2C:35-

5a(1) and N.J.S.A. 2C:35 -5b(13) .

7 . Knowingly or purposely did distribute a controlled

dangerous substance, that is, Ketamine, a Schedule III

controlled dangerous substance, in violation of N.J.S.A. 2C:35-

5a, while within 1,000 feet of School Property, which is owned

by or leased to the Paterson Board of Education and used for

school purposes, contrary to the provisions of N.J.S.A. 2C:35-7.

All in violation of N.J.S.A. 2C:5-2, and against the peace

of this State, the government and dignity of the same.

11

Page 12: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THREE

( Attempted Murder - First Degree)

Shadeik Stratford

on or about October 27, 2018, at the City of Paterson, in the

County of Passaic, elsewhere and within the jurisdiction of this

Court, knowingly or purposely did attempt to inflict serious

bodily injury upon Victim #l, which would have resulted in the

said Victim #1's death, contrary to the provisions of N.J.S.A.

2C:11-3 and N.J.S.A. 2C:5-1, and against the peace of this

State, the government and dignity of the same.

12

Page 13: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FOUR

(Unlawful Possession of Weapon - Second Degree)

Shadeik Stratford

on or about October 27, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, did knowingly possess a certain weapon, that is, a

9mm Luger caliber Ruger semiautomatic pistol, bearing serial

number 30331691, contrary to the provisions of N.J.S.A. 2C:39-5,

and against the peace of this State, the government and dignity

of the same.

13

Page 14: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FIVE

(Possession of Weapon for an Unlawful Purpose - Second Degree)

Shadeik Stratford

on or about October 27, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, did knowingly possess a certain weapon, that is, a

9mm Luger caliber Ruger semiautomatic pistol, bearing serial

number 30331691, with purpose to use it unlawfully against the

person or property of another, contrary to the provisions of

N.J.S.A. 2C:39-4(a) , and against the peace of this State, the

government and dignity of the same.

Page 15: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

rnrn.Tm a -ry

(Unlawful Possession of Weapon - Second Degree)

Shadeik Stratford

And

Nhazir Briggs-Smith

on or about October 29, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, did knowingly possess a certain weapon, that is, a

9mm Luger caliber Ruger semiautomatic pistol, bearing serial

number 30331691, contrary to the provisions of N.J.S.A. 2C:39-5

and N.J.S.A. 2C:2-6, and against the peace of this State, the

government and dignity of the same.

15

Page 16: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT SEVEN

(Unlawful Possession of a Large Capacity Ammunition Magazine -Fourth Degree)

Shadeik Stratford

And

Nhazir Briggs-Smith

on or about October 29, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly did possess a large capacity ammunition

magazine, contrary to the provisions~of N.J.S.A. 2C:39-3j and

N.J.S.A. 2C:2-6, and against the peace of this State, the

government and dignity of the same.

16

Page 17: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT EIGHT

(Possession of a Controlled Dangerous Substance - Third Degree)

Nhazir Briggs-Smith

Claudine Burdzy

And

Paul Zurawski

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

17

Page 18: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT NINE

(Distribution of a Controlled Dangerous Substance - ThirdDegree)

Nhazir Briggs-Smith

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and against

the peace of this State, the government and dignity of the same.

Page 19: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

r~rrnTm TL~TT

(Distribution of a Controlled Dangerous Substance on or within1,000 feet of School Property - Third Degree)

Nhazir Briggs-Smith

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of Paterson Public School 25,

which is owned by or leased to the Paterson Board of Education

and used for school purposes, contrary to the provisions of

N.J.S.A. 2C:35-7, and against the peace of this State, the

government and dignity of the same.

Page 20: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT ELEVEN

(Possession of a Controlled Dangerous Substance - Thi.rd Degree)

Nhazir Briggs-Smith

Claudine Burdzy

And

Paul Zurawski

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, Ketamine, a Schedule III

controlled dangerous substance, contrary to the provisions of

N.J.S.A. 2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the

peace of this State, the government and dignity of the same.

2 0

Page 21: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWELVE

(Distribution of a Controlled Dangerous Substance - ThirdDegree )

Nhazir Briggs-Smith

on or about November 2, 2018, at the City o~f Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, Ketamine, a Schedule III

controlled dangerous substance, contrary to the provisions of

N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(13) , and against the

peace of this State, the government and dignity of the same.

21

Page 22: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTEEN

(Distribution of a Controlled Dangerous Substance on or within

1,000 feet of School Property - Third Degree)

Nhazir Briggs-Smith

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, Ketamine, a Schedule III

controlled dangerous substance, in violation of N.J.S.A. 2C:35 -

5a, while within 1,000 feet of Paterson Public School 25, which

is owned by or leased to the Paterson Board of Education and

used for school purposes, contrary to the provisions of N.J.S.A.

2C:35-7, and against the peace of this State, the government and

dignity of the same.

22

Page 23: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FOURTEEN

(Possession of a Controlled Dangerous Substance - Third Degree)

Nhazir Briggs-Smith

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) , and against the peace of this State, the

government and dignity of the same.

23

Page 24: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FIFTEEN

(Distribution of a Controlled Dangerous Substance - ThirdDegree )

Nhazir Briggs-Smith

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and against

the peace of this State, the government and dignity of the same.

24

Page 25: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT SIXTEEN

(Eluding - Second Degree)

Nhazir Briggs-Smith

on or about November 2, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, while operating a vehicle, did knowingly flee or

attempt to elude law enforcement officers after having received

a signal from such officers to bring his vehicle to a full stop,

and in so doing, created a risk of death or injury to law

enforcement officers and others, contrary to the provisions of

N.J.S.A. 2C:29-2b, and against the peace of this State, the

government and the dignity of the same.

2 5

Page 26: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT SEVENTEEN

(Possession of a Controlled Dangerous Substance - Third Degree)

Jahvon Parker

~.

Joan Dalton

on or about November 13, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, cocaine, a Schedule II controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

2 6

Page 27: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT EIGHTEEN

(Distribution of a Controlled Dangerous Substance - ThirdDegree)

Jahvon Parker

on or about November 13, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, cocaine, contrary to the

provisions of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and

against the peace of this State, the government and dignity of

the same.

27

Page 28: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT NINETEEN

(Distribution a Controlled Dangerous Substance on or within1,000 feet of School Property - Third Degree)

Jahvon Parker

on or about November 13, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, cocaine, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of Paterson Public School 26

and/or the Rosa L. Parks Arts High School, which are owned by or

leased to the Paterson Board of Education and used for school

purposes, contrary to the provisions of N.J.S.A. 2C:35-7, and

against the peace of this State, the government and dignity of

the same.

m

Page 29: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY

(Possession of a Controlled Dangerous Substance - Third Degree)

Charles Jackson

Ronald Johnstone

And

Timothy Nestor

on or about November 23, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

2 9

Page 30: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-ONE

(Distribution of a Controlled Dangerous Substance - ThirdDegree )

Charles Jackson

on or about November 23, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and against

the peace of this State, the government and dignity of the same.

3 0

Page 31: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-TWO

(Distribution of a Controlled Dangerous Substance on or within5 00 feet of Public Property - Second Degree)

Charles Jackson

on or about November 23, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 500 feet of Eastside Park, contrary to

the provisions of N.J.S.A. 2C:35 -7.1a, and against the peace of

this State, the government and dignity of the same.

31

Page 32: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-THREE

(Possession of a Controlled Dangerous Substance - Third Degree)

Jahvon Parker

Michael Lawhorn

And

Nicholas Napalitano

on or about November 26, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

3 2

Page 33: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-FOUR

(Distribution of a Controlled Dangerous Substance - ThirdDegree)

Jahvon Parker

And

Michael Lawhorn

on or about November 26, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35-5a(1) ,N.J.S.A. 2C:35 -5b(3) , and N.J.S.A. 2C:2-

6, and against the peace of this State, the government and

dignity of the same.

33

Page 34: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-FIVE

(Distribution of a Controlled Dangerous Substance on or within

1,000 feet of School Property - Third Degree)

Jahvon Parker

And

Michael Lawhorn

on or about November 26, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of Paterson School 21 and/or

the Rosa L. Parks Arts High School, which are owned by or leased

to the Paterson Board of Education and used for school purposes,

contrary to the provisions of N.J.S.A. 2C:35-7 and N.J.S.A.

2C:2-6, and against the peace of this State, the government and

dignity of the same.

34

Page 35: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-SIX

(Possession of a Controlled Dangerous Substance - Third Degree)

Fabian Frater

And

Alfonso Petrillo

on or about December 3, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

3 5

Page 36: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-SEVEN

(Distribution of a Controlled Dangerous Substance - ThirdDegree )

Fabian Frater

on or about December 3, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and against

the peace of this State, the government and dignity of the same.

3 6

Page 37: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-EIGHT

(Distribution of a Controlled Dangerous Substance on or within1,000 feet of School Property - Third Degree)

Fabian Frater

on or about December 3, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

20:35-5a, while within 1,000 feet of Paterson Public School 24,

which is owned by or leased to the Paterson Board of Education

and used for school purposes, contrary to the provisions of

N.J.S.A. 2C:35-7, and against the peace of this State, the

government and dignity of the same.

3 7

Page 38: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT TWENTY-NINE

(Possession of a Controlled Dangerous Substance - Third Degree)

Fabian Frater

Bryant Nevers

Marshea Anthony

And

Kelly Cunningham

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this state, the government and digni~y ~~ ~r~~ Sa.«i~ .

Page 39: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY

(Distribution of a Controlled Dangerous Substance - ThirdDegree)

Fabian Frater

Bryant Nevers

and

Marshea Anthony

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) , N.J.S.A. 2C:35-5b(3) , and N.J.S.A.

2C:2-6, and against the peace of this State, the government and

dignity of the same.

39

Page 40: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-ONE

(Distribution of a Controlled Dangerous Substance on or within1,000 feet of School Property - Third Degree)

Fabian Frater

Bryant Nevers

and

Marshea Anthony

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of Paterson Public School 26,

which is owned by or leased to the Paterson Board of Education

and used for school purposes, contrary to the provisions of

N.J.S.A. 2C:35-7 and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

4 0

Page 41: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-TWO

(Possession of a Controlled Dangerous Substance - Third Degree)

Fabian Frater

Bryant Nevers

Marshea Anthony

and

Kelly Cunningham

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, cocaine, a Schedule II controlled

dangerous substance, contrary to the provisions of N:J.S.A.

2C:35-10 (a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and. dignity o~ the same.

41

Page 42: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-THREE

(Distribution of a Controlled Dangerous Substance - ThirdDegree)

Fabian Frater

Bryant Nevers

and

Marshea Anthony

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, cocaine, contrary to the

provisions of N.J.S.A. 2C:35 -5a(1) , N.J.S.A. 2C:35 -5b(3) , and

N.J.S.A. 2C:2-6, and against the peace of this State, the

government and dignity of the same.

4 2

Page 43: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-FOUR

(Distribution of a Controlled Dangerous Substance on or within1,000 feet of School Property - Third Degree)

Fabian Frater

Bryant Nevers

and

Marshea Anthony

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, cocaine, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of Paterson Public School 26,

which is owned by or leased to the Paterson Board of Education

and used for school purposes, contrary to the provisions of

N.J.S.A. 2C:35-7 and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

43

Page 44: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-FIVE

(Possession of a Controlled Dangerous Substance - Third Degree)

Fabian Frater

And

Peter Bruno

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and dignity of the same.

4 4

Page 45: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-SIX

(Distribution of a Controlled Dangerous Substance - .ThirdDegree)

Fabian Frater

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and against

the peace of this State, the government and dignity of the same.

4 5

Page 46: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-SEVEN

(Distribution of a Controlled Dangerous Substance on or within

1,000 feet of School Property - Third Degree)

Fabian Frater

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of the Martin Luther King

Elementary School, which is owned by or leased to the Paterson

Board of Education and used for school purposes, contrary to the

provisions of N.J.S.A. 2C:35-7 and N.J.S.A. 2C:2-6, and against

the peace of this State, the government and dignity of the same.

4 6

Page 47: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-EIGHT

(Possession of a Controlled Dangerous Substance - Third Degree)

Fabian Frater

Bryant Nevers

Marshea Anthony

and

Phoung Le

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) and N.J.S.A. 2C:2-6, and against the peace of

this State, L'n.e government a~~a aiyrii~y ~f ~ri~ 5air~~ .

4 7

Page 48: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT THIRTY-NINE

(Distribution of a Controlled Dangerous Substance - ThirdDegree)

Fabian Frater

Bryant Nevers

and

Marshea Anthony

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) , N.J.S.A. 2C:35 -5b(3) , and N.J.S.A.

2C:2-6, and against the peace of this State, the government and

dignity of the same.

Page 49: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY

(Distribution a Controlled Dangerous Substance on or within1,000 feet of School Property - Third Degree)

Fabian Frater

Bryant Nevers

and

Marshea Anthony

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 1,000 feet of School 16, which is owned

by or leased to the Paterson Board of Education and used for

school purposes, contrary to the provisions of N.J.S.A. 2C:35-7

and N.J.S.A. 2C:2-6, and against the peace of this State, ~the

government and dignity of the same.

. •.

Page 50: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-ONE

(Eluding - Second Degree)

Fabian Frater

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, while operating a vehicle, did knowingly flee or

attempt to elude law enforcement officers after having received

a signal from such officers to bring his vehicle to a full stop,

and in so doing, created a risk of death or injury to law

enforcement officers and others, contrary to the provisions of

N.J.S.A. 2C:29-2b and N.J.S.A. 2C:2-6, and against the peace of

this State, the government and the dignity of the same.

5 0

Page 51: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-TWO

( Aggravated Assault on a Law Enforcement Officer - Third Degree)

Fabian Frater

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, purposely did attempt to cause bodily injury to

Victim #2, a law enforcement officer of the Paterson Police

Department, while the said Victim #2 was acting in the

performance of his duties while in uniform or exhibiting

evidence of his authority, contrary to the provisions of

N.J.S.A. 2C:12-lb(5) (a) and N.J.S.A. 2C:2-6, and against the

peace of this State, the government and the dignity of the same.

51

Page 52: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-THREE

(Money Laundering - Third Degree)

Fabian Frater

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly did transport or possess property known,

or which a reasonable person would believe to be derived from

criminal activity, that is, the said FABIAN FR.ATER did possess

approximately $2,754 in U.S. currency, known or which a

reasonable person would believe to be derived from criminal

activity, contrary to the provisions of N.J.S.A. 2C:21-25(a) ,

and against the peace of this State, the government and dignity

of the same.

52

Page 53: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-FOUR

(Resisting Arrest by Flight - Fourth Degree)

Marshea Anthony

And

Bryant Nevers

on or about December 4, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, purposely prevented or attempt to prevent a law

enforcement officer from effecting an arrest by flight, contrary

to the provisions of N.J.S.A. 2C:29-2(a) (2) , and against the

peace of this State, the government and the dignity of the same.

53

Page 54: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-FIVE

(Money Laundering - Third Degree)

Marshea Anthony

on or about December 6, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly did transport or possess property known,

or which a reasonable person would believe to be derived from

criminal activity, that is, the said MARSHEA ANTHONY did possess

approximately $1,535 in U.S. currency, known or which a

reasonable person would believe to be derived from criminal

activity, contrary to the provisions of N.J.S.A. 2C:21-25(a) ,

and against the peace of this State, the government and dignity

of the same.

54

Page 55: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-SIX

(Possession of a Controlled Dangerous Substance - Third Degree)

Charles Jackson

on or about December 8, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35-10 (a) (1) , and against the peace of this State, the

government -and dignity of the same.

5 5

Page 56: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-SEVEN

(Possession with Intent to Distribute a Controlled DangerousSubstance - Third Degree)

Charles Jackson

on or about December 8, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess with intent to

distribute a controlled dangerous substance, that is, heroin,

contrary to the provisions of N.J.S.A. 2C:35 -5a(1) and N.J.S.A.

2C:35 -5b(3) , and against the peace of this State, the government

and dignity of the same.

56

Page 57: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-EIGHT

(Money Laundering - Third Degree)

Charles Jackson

on or about December 8, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly did transport or possess property known,

or which a reasonable person would believe to be derived from

criminal activity, that is, the said CHARLES JACKSON did possess

approximately $3,282 in U.S. currency, known or which a

reasonable person would believe to be derived from criminal

activity, contrary to the provisions of N.J.S.A. 2C:21-25(a) ,

and against the peace of this State, the government and dignity

of the same.

57

Page 58: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FORTY-NINE

(Possession of a Controlled Dangerous Substance - Third Degree)

Karon Nevers

on or about January 22, 2019, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did possess a controlled

dangerous substance, that is, heroin, a Schedule I controlled

dangerous substance, contrary to the provisions of N.J.S.A.

2C:35 -10(a) (1) , and against the peace of this State, the

government and dignity of the same.

Page 59: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FIFTY

(Distribution of a Controlled Dangerous Substance - ThirdDegree )

Karon Nevers

on or about January 22, 2019, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, contrary to the provisions

of N.J.S.A. 2C:35 -5a(1) and N.J.S.A. 2C:35 -5b(3) , and against

the peace of this State, the government and dignity of the same.

5 9

Page 60: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FIFTY-ONE

(Distribution of a Controlled Dangerous Substance on or within5 00 feet of Public Property - Second Degree)

Karon Nevers

on or about January 22, 2019, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, knowingly or purposely did distribute a controlled

dangerous substance, that is, heroin, in violation of N.J.S.A.

2C:35 -5a, while within 500 feet of Triangle Park, contrary to

the provisions of N.J.S.A. 2C:35 -7.1a, and against the peace of

this State, the government and dignity of the same.

C~

Page 61: LAW DIVISION - CRIMINAL F~~ ~' ~' 201 State Grand Jury ...MARSHEA ANTHONY CHARLES JACKSON BRYANT NEVERS 4 SHADEIK STRATFORD NHAZIR BRIGGS-SMITH JAHVON PARKER MICHAEL LAWHORN KARON

COUNT FIFTY-TWO

(Possession of a Weapon by a Convicted Person - Second Degree)

Nhazir Briggs-Smith

on or about October 29, 2018, at the City of Paterson, in the

County of Passaic, elsewhere, and within the jurisdiction of

this Court, having been convicted of the crime of Possession

with Intent to Distribute and/or Distribution within 1,000 feet

of School Property on Passaic County Accusation 17-04-00398-A

did purchase, own, possess or control a firearm, that is, 9mm

Luger caliber Ruger semiautomatic pistol, bearing serial number

30331691, contrary to the provisions of N.J.S.A. 2C:39-7b, and

.against the peace of this State, the government and dignity of

the same.

A TRUE BILL:'

Director Division of Criminal Justice

Dated:

60


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