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

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RUSSO, KHURANA, HAOUZI, AND THEIR ACCOMPLICES ENGAGED IN CRIMINAL CONDUCT PROSCRIBED BY <strong>NEW</strong> <strong>YORK</strong> 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. 4 Respectfully submitted,
STERNIK & ZELTSER by: Emanuel Zeltser Emanuel Zeltser, Esq. 119 West 72 nd Street New York, NY 10023 t/f 212-656-1810 email: lawmail@rambler.ru DATED: April 15, 2010 VERIFICATION by David Kay DAVID KAY, declares under the penalty of perjury: 5 DAVIDOFF MALITO & HUTCHER LLP by: ____________________ William P. Walzer, Esq 200 Garden City Plaza, Suite 315 Garden City, New York 11530 tel.516.248.6400 fax: 516 -248-6422 wpw@dmlegal.com 1. I am vice president of Little Rest Twelve, Inc., a New York corporation, which operates AJNA Bar. 2. I have read the Brief submitted to the Manhattan District Attorney pursuant to Referral Order of the Court. 3. I personally witnessed many of the events described in the Brief. 4. I certify that all factual assertions in the Brief are true and correct to the best of my knowledge and belief. April 12, 2010 New York, NY _______________________ David Kay
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DISTRICT ATTORNEY'S OFFICE NEW YORK ... - Gudavadze

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