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ELEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE, in violation of Penal Law §170.25, committed as follows:
The defendant, in the County of New York, on or about November 24, 2024, knowing the instrument to be forged and with intent to defraud, deceive and injure another, uttered and possessed a forged instrument, the same being and purporting to be, and calculated to become and to represent if completed, a written instrument officially issued and created by a public office, public servant and governmental instrumentality, to wit, a New Jersey driver’s license.
ALVIN L. BRAGG, JR.
District Attorney
