DISTRICT ATTORNEY'S OFFICE NEW YORK ... - Gudavadze

RUSSO, KHURANA, HAOUZI, AND THEIR ACCOMPLICES ENGAGED
IN CRIMINAL CONDUCT PROSCRIBED BY NEW YORK PENAL LAW
AJNA respectfully alleges that RUSSO, KHURANA, HAOUZI and their accomplices,
whose names are not presently known to AJNA, engaged in conduct violative of New York Penal
Law, including: § 120.14 - menacing in the second degree; § 120.15 - menacing in the third degree;
§ 120.20 - reckless endangerment in the second degree; § 135.05 - unlawful imprisonment in the
second degree; § 135.65 - coercion in the first degree; § 140.05 trespass; § 140.10 criminal trespass
in the third degree; § 140.17 - criminal trespass in the first degree; § 140.20 - burglary in the third
degree; § 140.25 - burglary in the second degree; § 140.35 - possession of burglar's tools; § 145.10 -
criminal mischief in the second degree; § 155.25 - petit larceny; § 155.30 - grand Larceny in the
fourth degree; § 155.35 - grand larceny in the third degree; § 155.40 Grand larceny in the second
degree; §156.10 Computer Trespass; § 156.05 Unauthorized use of a computer; § 156.30 Unlawful
duplication of computer related material in the first degree; § 160.05 Robbery in the third degree;
§ 160.10 Robbery in the second degree; § 160.15 Robbery in the first degree; § 165.40 Criminal
possession of stolen property in the fifth degree; § 165.45 Criminal possession of stolen property
in the fourth degree; § 165.50 - criminal possession of stolen property in the third degree; § 165.52 -
criminal possession of stolen property in the second degree; § 20.00 - criminal liability for conduct
of another; 190.26 - criminal impersonation in the first degree.
In addition RUSSO made false statements to police that he had an authority from the Court
to engage in the above described conduct.
CONCLUSION
Based upon the aforesaid, and the Referral Order AJNA respectfully requests that the
Manhattan District Attorney investigate this matter.
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Respectfully submitted,