SECOND COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of MURDER IN THE SECOND DEGREE AS A CRIME OF TERRORISM, in violation of Penal Law §§125.25(1) and 490.25, committed as follows:
The defendant, in the County of New York, on or about December 4, 2024, with intent to intimidate or coerce a civilian population, influence the policy of a unit of government by intimidation or coercion, and affect the conduct of a unit of government by murder, assassination or kidnapping, committed the specified offense of MURDER IN THE SECOND DEGREE, in that defendant, with intent to the death of another person, caused the death of Brian Thompson.
THIRD COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of MURDER IN THE SECOND DEGREE, in violation of Penal Law §125.25(1), committed as follows:
The defendant, in the County of New York, on or about December 4, 2024, with intent to cause the death of another person, caused the death of Brian Thompson.
FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE, in violation of Penal Law §265.03(1)(b), an armed felony, committed as follows:
The defendant, in the County of New York, on or about December 4, 2024, possessed a loaded firearm with intent to use the same unlawfully against another person.
