SUPREME COURT OF THE STATE OF NEW YORK

COUNT\ OF NEW YORK

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i

THE PEOPLE OF THE STATE OF NEW YORK

-aga inst-

CHRISTOPHER BROWN,
MATTHEW MAHRER,

Defendants.
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THE GRAND JURY OF THE COUNTY OF NEW YORK, by thi s indictment, accuses

the defendants, CHRISTOPHER BROWN and MATTHEW MAHRER, of the crime of

CONSPIRACY IN THE FOURTH DEGREE, in vio lation of Penal Law§ 105.10, committed

as follows:

The defendants, in the County of New York and elsewhere, from on or about November

12, 2022, to on or about November 18, 2022, with intent that conduct constituting the class C

felony of Crim inal Possess ion of a Weapon in the Second Degree be performed, agreed with one

and more persons to engage in and cause the performance of such conduct.

OVERT ACTS

In furtherance of said conspiracy, and to effect the objects thereof, during the period from

on or about November 12, 2022, to on or about November 18, 2022, the fo llowing overt acts,

among others, were committed:

1. On or about November 12, 2022, defendant CHRISTOPHER BROWN published a

post on Twitter stating, in sum and substance, "Big moves being made on Friday."

2. On or about November 16, 2022, defe ndant CHRISTOPHER BROWN publi shed a

post on Twitter statin g, in sum and substance, "Brutally murder people with hatchets

and whatnot. How it fee ls to KILL PEOPLE."

3. On or about November 17, 2022, defendant CHRJSTOPHER BROWN pub lished a

post on Twitter stating, in sum and substance, "Gonna ask a Priest if I should become

a husband or shoot up a synagogue and die."

4. On or about November 18, 2022, defendant CHRJSTOPHER BROWN published a

post on Twitter stating, in sum and substance, "This time I'm rea lly gonna do it."

5. On or about November 18, 2022, defendant CHRJSTOPHER BROWN traveled into

New York County.

6. On or about November 18, 2022, defendants CHRJSTOPHER BROWN and

MATTHEW MAHRER were present together at St. Patrick's Cathedral in New York

County.

7. On or about November 18, 2022, defendants CHRJSTOPHER BROWN and

MATTHEW MAHRER traveled together out of New York State.

8. On or about November 18, 2022, while defendants CHRISTOPHER BROWN and

MATTHEW MAHRER were together with another, defendant MATTHEW

MAHRER participated in a phone call in which it was mentioned, in sum and

substance, that defendant MATTHEW MAHRER was at that time traveling to

Pennsylvania to obtain a firearm.

9. On or about November 18, 2022, defendant CHRISTOPHER BROWN transferred

$650 to defendant MATTHEW MAHRER.

10. On or about November 18, 2022, while together, defendants CHRJSTOPHER

BROWN and MATTHEW MAHRER traveled back into New York County.

11. On or about November 18, 2022, defendants CHRISTOPHER BROWN and

MATTHEW MAHRER were present together outside of 100 West 94 th Street, in New

York County, and possessed a firearm.

 12. On or about November 18, 2022, defendants CHRISTOPHER BROWN and

MA ITHEW MAHRER were present together outside of 100 West 94 th Street, in New

York County, and possessed a large capacity ammunition feeding device

13. On or about November 18, 2022, defendants CHRISTOPHER BROWN and

MATTHEW MAHRER were present together at Penn Station, in New York County.

SECOND COUNT:

AND THE GRAND WRY AFORESAID, by this indictment, further accuses defendant

CHRISTOPHER BROWN of the crime of CRIMINAL POSSESSION OF A WEAPON IN

THE SECOND DEGREE AS A CRIME OF TERRORISM, in violation of Penal Law §§

265.03(1)(6) and 490.25 , committed as follows:

The defendant, in the County of New York and elsewhere, on or about November 18,

2022, with intent to intimidate and coerce a civilian population, influence the policy of a unit of

government by intimidation and coercion, and affect the conduct of a unit of government by

murder, assassination and kidnapping, committed the specified offense of CRIMINAL

POSS ESSION OF A WEAPON IN THE SECOND DEGREE, in that the defendant possessed a

loaded firearm , to wit, a pistol , with intent to use unlawfully against another.

THIRD COUNT:

AND THE GRAND WRY AFORESAID, by this indictment, further accuses defendant

CHRISTOPHER BROWN of the crime of CRIMINAL POSSESSION OF A WEAPON IN

THE SECOND DEGREE AS A CRIME OF TERRORISM, in violation of Penal Law §§

265.03(3) and 490.25 , committed as follows:

 The defendant, in the County of New York and e lsewhere, on or abo ut Nove mber 18,

2022, with intent to intimidate and coerce a civ ili an population, influence the policy of a unit of

government by intimidation and coercion, and affect the conduct of a unit of government by

murder, assassination and kidnapping, committed the specified offense of CRIMINAL

POSSESSION OF A WEAPON IN THE SECOND DEGREE, in that the defendant possessed a

loaded firearm , to wit, a pistol , said possession not being in defendant' s home or place of business.

FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendant

CHRJSTOPHER BROWN of the crime of MAKING A TERRORISTIC THREAT AS A

HATE CRIME, in vio lation of Penal Law§§ 490.20 and 485.0S(l)(b), committed as fo llows:

The defendant, in the County of New York and elsewhere, during the period from on or

about November 12, 2022 to on or about November I 8, 2022, w ith the intent to intimidate and

coerce a civilian population, influence the policy of a unit of government by intimidation and

coercion, and affect the conduct of a unit of government by murder, assassination and kidnapping,

threatened to commit a specified offense and caused a reasonable expectation of fear of the

imminent commission of such offense and committed the act or acts constituting the offense in

who le or in substantial part because of a belief or perception regarding the race, color, national

origin, ancestry, gender, gender identity or expression, religion, religious practice, age, disability

or sexual orientation of a person, regardless of whether the belief or perception was correct.

FJFTH COUNT:

AND THE GRAND JURY AFORESAID, by thi s indictment, further accuses defendant

CHRJSTOPHERBROWN of the crime of MAKING A TERRORISTIC THREAT, in vio lation

of Penal Law§ 490.20, committed as follows:

 The defendant, in the County of New York and elsewhere, during the period from on or

about November 12, 2022, to on or about November 18, 2022, with the intent to intimidate and

coerce a civilian population, influence the policy of a unit of government by intimidation and

coercion, and affect the conduct of a unit of government by murder, assassination and kidnapping,

threatened to commit a specified offense and caused a reasonable expectation of fear of the

imminent commission of such offense.

SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendant

CHRISTOPHER BROWN 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 November 18, 2022, possessed a

loaded firearm, to wit, a pistol , with intent to use the same unlawfully against another person.

SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendant

MATTHEW MAHRER of the crime of CRIMINAL POSSESSION OF A WEAPON IN THE

SECOND DEGREE, in violation of Penal Law§ 265.03(l)(b), an armed felony , committed as

follows:

The defendant, in the County of New York, on or about November 18, 2022, possessed a

loaded firearm , to wit, a pistol, with intent to use the same unlawfull y against another person.
EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendants

CHRJSTOPHER BROWN and MATTHE W MAHRER of the crime of CRIMINAL

POSSESSION OF A WEAPON IN THE SECOND DEGREE, in violation of Penal Law §

265.03(3), an armed felony, committed as follows:

The defendants, in the County of New York, on or about November 18, 2022, possessed

a loaded firearm , to wit, a pistol , said possession not being in either defendant's home or place of

business.

NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendants

CHRJSTOPHER BROWN and MATTHEW MAHRER of the crime of CRIMINAL

POSSESSION OF A WEAPON IN THE THIRD DEGREE, in violation of Penal Law §

265.02(8), committed as follows:

The defendants, in the County of New York, on or about November 18, 2022, possessed

a large capacity ammunition feeding device.

TENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendants

CHRJSTOPHER BROWN and MATTHEW MAHRER of the crime of CRIMINAL

POSSESSION OF A FIREARM, in vio lation of Penal Law § 265.01-b(l), committed as

follows:

The defendants, in the County of New York, on or about November 18, 2022, possessed

a firearm , to wit, a pi stol.

ELEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses defendant

CHRISTOPHER BROWN of the crime of CRIMINAL POSSESSION OF A WEAPON IN

THE FOURTH DEGREE, in violation of Penal Law§ 265.01(2) , committed as follows:

The defendant, in the County of New York, on or about November 18, 2022, possessed a

dangerous instrument, to wit, a knife, with intent to use the same unlawfully against another.

AL VIN L. BRAGG, JR.

District Attorney
GJ #2-35
Filed: CCI CR-030518-22NY,
CR-030516-22NY

No.

THE PEOPLE OF THE STATE OF NEW YORK

-against-

CHRISTOPHER BROWN,
MATTHEW MAHRER,

Defendants.

INDICTMENT

CONSPIRACY IN THE FOURTH DEGREE, P.L. § 105 .10- DEF. Brown, DEF. Mahrer
CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE AS A CRIME OF TERRORISM, P.L. §§ 265.03(l)(b),(3) 490.25 , 2 Cts- DEF. Brown
MAKING A TERRORISTIC THREAT AS A HATE CRIME, P .L. §§ 490.20 and 485.05(l)(b)-DEF. Brown
MAKING A TERRORISTIC THREAT, P.L. § 490 .20-DEF. C. Brown
CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE, P.L. § 265.03(l)(b), an armed felony-DEF. Brown
CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE, P.L. § 265 .03(l)(b), an armed felony-DEF. Mahrer
CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE, P.L . § 265.03(3), an armed felony - DEF. Brown, DEF. Mahrer
CRIMINAL POSSESSION OF A WEAPON IN THE THIRD DEGREE, P.L. § 265.02(8)- DEF. Brown, DEF. Mahrer
CRIMINAL POSSESSION OF A FIREARM, P.L. § 265.01-b(l)-DEF. Brown, DEF. Mahrer
CRIMINAL POSSESSION OF A WEAPON IN THE FOURTH DEGREE, P.L. § 265.0 1(2)- DEF. Brown

AL VIN L. BRAGG JR., District Attorney

A True Bill

Edward Burns
Rackets Bureau Foreman

ADJOURNED TO PART GWPI ON 12/7/2022