Redacted Ross IND.11.17.23

STATE OF NEW YORK
COL]NTY COURT COLINTY OF SARATOGA
THE PEOPLE OF THE STATE OF NEW YORK
-against- AUGUST 2023 TERM

Indictment No. H-23 1 -2023V
CRAIGN. ROSS, JR.,
Defendant. :lr^i)--lol5t-LSloot
COUNT ONE
THE GRAND ruRY OF THE COLINTY OF SARATOGA, by this Indictment, accuse the
defendant, Craig N. Ross, Jr. of the crime of KIDNAPPING IN TIIE FIRST DEGREE, a "Class A-
I" Felony, in violation of Section 135.25(1) of the Penal Law of the State of New York, committed
as follows:
The defendant, in the Town of Milton, County of Saratogq State of New York, on or about
September 30, 2023 through October 2,2023, abducted another person and his intent was to compel
a third person to pay or deliver money or property as ransom, or to engage in other particular conduct,
or to refiain from engaging in particular conduct.
COLNTTWO
AND THE GRAND ruRY AFORESAID, by this Indictment, accuse the defendant, Craig
N. Ross, Jr., of the crime of PREDATORY SEXUAL ASSAULT AGAINST A CHILD, a "Class
A-ll" Felony, in violation of Section 130.96 of the Penai Law of the State of New York, committed
as follows:
The defendant, in the Town of Milton, County of Saratoga, State of New York, on or about
September 30, 2023 t}rough October 2,2023,being eighteen years old or more, committed the crime
of Rape in the First Degree as defined in Section 130.35(4) ofthe Penal Law ofthe State of New
York, and the victim was less than thirteen years old, to wit: the defendant engaged in sexual
intercourse with another person who was less than thirteen years old and the actor is eighteen years
old or more.
COLTN'I'THREE
A-II" Felony, in violation of Section 130.96 of the Penal Law of the State of New York, committed
as follows:
The defendant, in the Town of Milton, County of Saratoga, State ofNew York, on or about
September 30, 2023 tfuough October 2,2023,being eighteen years old or more, committed the crime
of Criminal Sexual Act in the First Degree, as defined in Section 130.50(4) of the Penal Law ofthe
State ofNew York, and the victim was less than thirteen years old, to wit: the defendant engaged in
oral sexual conduct with another person who was less than thirteen years old and the actor is eighteen
years old or more.
couNT Fot-rR
A-II" Felony, in violation of Section 130.96 of the Penal Law of the State of New York, committed
as follows:
September 30, 2023 through October 2,2023,being eighteen years old or more, committed the crime
of Rape in the First Degree as defined in Section 130.35(4) of the Penal Law of the State of New
York, and the victim was less than thirteen years old, to wit: the defendant engaged in sexual
intercourse with another person who was less than thirteen years old and the actor is eighteen years
old or more.
C I]NT FIVR
N. Ross, Jr., of the crime of PREDATORY SEXUAL ASSAULT AGAINST A CHILD, ,,Class
a
AJI" Felony, in violation of Section 130.96 of the Penal Law of the State of New york, committed
as follows:
The defendant, in the Town of Milton, County of Saratoga, State ofNew York, on or about
September 30, 2023 through October 2,2023,being eighteen years old or more, committed the crime
of Criminal Sexual Act in the First Degree, as defined in Section 130.50(4) of the Penal Law of the
State ofNew York, and the victim was less than thirteen years old, to wit: the defendant engaged in
oral sexual conduct with another person who was less than thirteen years old and the actor is eighteen
years old or more.
COI,NT SIX
AND THE GRAND JURY AFORESAID, by this Indictment, accuse the defendant, Craig
N. Ross, Jr., of the crime of SEXUAL ABUSE IN THE FIRST DEGREE, a "Class D" Violent
Felony, in violation of Section 130.65(3) ofthe Penal Law olthe State of New York, committed as
follows:
September 30,2023 through October 2,2023, subjected another person to sexual contact when the
other person was less than eleven years old.
COLTNT SEVEN
AND THE GRAND JURY AFORESAID, by this Indictment, accuse the defendant, Craig
N. Ross, Jr., of the crime of SEXUAL ABUSE IN THE FIRST DEGREE, a "Class D" Violent
Felony, in violation of Section 130.65(3) ofthe Penal Law ofthe State of New York, committed as
follows:
The defendant, in the Town of Milton, County of Saratog4 State of New York, on or about
September 30,2023 through October 2,2023, subjected another person to sexual contact when the
otler person was less than eleven years old.
COUNT EIGHT
AND TI{E GRAND ruRY AIORESAID, by this Indictrnen! accuse the defendant, Craig
N. Ross, Jr., of the crime of ASSAULT IN THE SECOND DEGREE, a "Class D" Violent Felony,
in violation of Section 120.05(6) of the Penal Law of the State of New York, committed as follows:
The defendant, in the Town of Milton, County of Saratog4 State of New York, on or about
September 30, 2023 through October 2,2023, in the course of and in frutherance ofthe commission
or attempted commission of a felony, or of immediate flight therefrom, caused physical injury to a
person other than one ofthe participants.
COT-}]{T NINE
AND TIIE, GRAND JURY AFORESAID, by this lndicfinent, accuse the defendant, Craig
N. Ross, Jr., of the crime of ENDANGERING TI{E WELFARE OF A CHILD, a "Class A"
Misdemeanor, in violation of Section 260.10(1) of the Penal Law of the State of New York,
committed as follows:
The defendant, in the Town of Moreau, County of Saratog4 State of New York, on or about
September 30,2023, knowingly acted in a manner likely to be injurious to the physical, mental, or
moral welfare of a child less than seventeen vears old-
Grand Jury F
KARENA. HE
District Attomev

Redacted Ross IND.11.17.23

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STATE OF NEW YORK

COL]NTY COURT COLINTY OF SARATOGA

THE PEOPLE OF THE STATE OF NEW YORK

-against- AUGUST 2023 TERM

or to refiain from engaging in particular conduct.

years old or more.

years old or more.

other person was less than eleven years old.

otler person was less than eleven years old.

or attempted commission of a felony, or of immediate flight therefrom, caused physical injury to a

person other than one ofthe participants.

moral welfare of a child less than seventeen vears old-

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