IN THE COURT OF PUBLIC OPINION
STATE OF NEW YORK — ALL SIXTY-TWO COUNTIES
SARITHA KOMATIREDDY AND THE EXASPERATED PEOPLE OF THE STATE OF NEW YORK,
Plaintiffs,
— against —
LETITIA A. JAMES, Attorney General of the State of New York, Defendant.
PUBLIC INDICTMENT
Index No. 2026-11-03
Returnable at the polls, Tuesday, November 3, 2026 Trial by jury demanded
PRELIMINARY STATEMENT
SARITHA KOMATIREDDY AND THE EXASPERATED PEOPLE OF THE STATE OF NEW YORK, by this Complaint, allege that the defendant, LETITIA A. JAMES, has been derelict in the office of Attorney General of the State of New York, in fifty-two counts, as follows.
The defendant has held the office of Attorney General since January 1, 2019. For the whole of that period she has been the chief law enforcement officer of the State of New York, the lawyer for its people, and the head of a Department of Law with a budget that has nearly doubled in her care. She has commanded the broadest civil fraud statute in the nation, a Medicaid Fraud Control Unit of more than 270 employees, the sole regulatory authority over every charity in the State, an Organized Crime
1Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Task Force, and the standing to speak for nineteen million people in any court in the land.
The People do not allege that the defendant has been idle. They allege that she has been busy with the wrong things. While the defendant built a national reputation, much of the work of the office went undone. New Yorkers froze on sidewalks. New Yorkers were shoved onto subway tracks by men every part of the system already knew. New Yorkers were burned alive in train cars. A homeless father was beaten to death by children on a Binghamton sidewalk. A family of five, three of them small children, died in a fire at an Endwell motel that was being used as a shelter. A Buffalo mother was shot in front of her three children by a man a court had released the day before. Nurses were beaten. A Jewish man was stabbed in the chest on his way out of synagogue. Inmates who said they were raped in state custody were fought in court over typos. Nursing home patients were neglected while more than 2,000 abuse referrals a year produced a handful of convictions. Food benefits were skimmed from the poorest families in the State. Homes were stolen with forged deeds while complaints to her office more than tripled. Opioid settlement money won in the name of the dead was spent on snowblowers and headsets. Shelter executives were paid seven figures from grants the defendant increased.
Each count below names what the defendant was empowered to do, what she did instead, and who paid for the difference. Each count then states, in a sentence or two, where the defendant failed, ties that failure to something she did, said, funded, or refused to do, and cites the record with a working link. Wherever the public record names those who paid, this Complaint names them too. They are not statistics. They were New Yorkers, and the office charged with protecting them was looking elsewhere.
This is a statewide Complaint. The failures alleged here did not stop at the City line. They reach Buffalo, Rochester, Syracuse, Binghamton, Albany, Niagara County, the North Country, the Hudson Valley and Long Island, and the record cited is drawn from the newspapers and stations of every one of those places.
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This Complaint charges no crime and seeks no money. It is returnable to the only tribunal with jurisdiction over the defendant’s performance: the voters of New York, on November 3, 2026.
JURISDICTION AND VENUE
1. Jurisdiction over the defendant’s performance in office rests with the voters of the State of New York. Venue is proper in each of the State’s sixty-two counties, because the failures alleged here reached every one of them.
2. The events alleged below took place in, among other places, Albany, Babylon, Binghamton, Buffalo, Central Islip, Cheektowaga, Endwell, Ithaca, Rochester, Syracuse, the five boroughs of New York City, and the counties of Albany, Broome, Cortland, Erie, Essex, Monroe, Niagara, Onondaga, Suffolk and Sullivan.
GENERAL ALLEGATIONS
At all times relevant to this Complaint:
3. The defendant, LETITIA A. JAMES, was the duly elected Attorney General of the State of New York, sworn on January 1, 2019, and re-elected in November 2022. Under Article V, Section 4 of the State Constitution and Article 5 of the Executive Law, she was the head of the Department of Law and the chief legal officer of the State. By her own official biography, she began her career as a public defender at the Legal Aid Society. That biography lists no service as a criminal prosecutor.
4. The office the defendant held is not a ceremonial one. It carries the power to investigate and prosecute Medicaid fraud and patient abuse statewide through the Medicaid Fraud Control Unit. It carries the power to investigate organized crime and narcotics trafficking through the Organized Crime Task Force. It carries exclusive supervisory authority over every charitable organization in the State through the Charities Bureau. It carries the Martin Act, the broadest securities fraud statute in the nation, and Executive Law Section 63(12), which lets the
3Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Attorney General sue anyone who engages in repeated fraud or illegality in the conduct of business. It carries the standing to seek referrals from the Governor to prosecute matters that district attorneys will not, and the standing to appear in any court on behalf of the People of New York.
5. The People of New York paid handsomely for that office. The Department of Law carried an All Funds appropriation of approximately $263.8 million when the defendant took office. The Fiscal Year 2026 Executive Budget recommended $487.8 million, an increase of roughly $224 million, or 85 percent, over her tenure. Setting aside one-time settlement pass-through funds, the operating budget grew by roughly half. Headcount grew from 1,839 full-time employees to more than 1,950.
6. Over the same period, according to the State’s own Division of Criminal Justice Services, reported Index crimes rose from a historic low of 337,131 in 2019, the year the defendant took office, to 423,486 in 2024, an increase of 26 percent. Felony assaults in New York City rose for six consecutive years to their highest level since 1997. The number of unsheltered New Yorkers in the City rose from 3,588 in Fiscal Year 2019 to 4,504 in Fiscal Year 2025, according to the State Comptroller, while City spending on the unsheltered more than tripled.
7. Every fact alleged in this Complaint is drawn from the public record: from news reporting, from court filings, from federal and state audits, from the State Comptroller, from the United States Department of Health and Human Services, from the defendant’s own press releases, and from the defendant’s own words on video. A linked record follows every count. The People have invented nothing. Where this Complaint says the People have found no evidence that the defendant acted, it means that a search of her press releases, her court filings, her public statements and the news record turned up none. If the evidence exists, the defendant is invited to produce it.
8. The defendant’s principal defense, offered repeatedly and in advance, is that the crimes and failures alleged here belong to someone else: to the Mayor, to district attorneys, to the Legislature, to Washington. The People reject that defense.
4Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
The defendant asked for the job of chief law enforcement officer of the State. She asked twice. The question in every count below is not whether she was the only official who could have acted. It is whether she, holding the most powerful law office in New York, acted at all.
9. The failures alleged below were not accidents, and they were not someone else’s. They trace to choices the defendant made. In January 2020 she opened an investigation of the New York City Police Department for enforcing the subway fare. In July 2020 her office issued a report recommending that armed police be removed from calls involving mental illness and homelessness, that minor offenses be decriminalized, that the final say over police discipline be taken from the Police Commissioner and given to the Civilian Complaint Review Board, and that a commission be empowered to hire and fire the Commissioner and approve the department’s budget. She used her sole discretion over grants to send $54 million to organizations working against the police. And when federal inspectors examined the collapse of her Medicaid Fraud Control Unit, they found the cause was “a deliberate leadership choice.” Each count identifies the choice.
The record: Attorney General’s official biography; Executive Law Section 63; FY2026 Executive Budget, Department of Law; Division of Criminal Justice Services crime statistics; State Comptroller, March 2026; Attorney General’s July 2020 policing report; Attorney General’s January 2020 fare-enforcement investigation; HHS Inspector General letter, June 30, 2026.
THE COUNTS, BY CATEGORY
Part One (Counts 1-11): The mentally ill and the homeless, left to the streets
Part Two (Counts 12-22): Repeat offenders, the subway, and the war on police
Part Three (Counts 23-24): Hate crimes and antisemitism Part Four (Counts 25-28): Sex crimes
Part Five (Part Six (Counts 41-45): Housing, schools, and the cost of living
Part Seven (Counts 46-55): The office turned inward
5Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNTS ARISING OUTSIDE THE FIVE BOROUGHS
Western New York (Buffalo, Erie and Niagara Counties): Counts 10, 14, 20, 22, 26, 36, 40 and 44
Rochester and the Finger Lakes: Counts 9, 10, 16, 20, 21, 22, 23 and 26
Central New York (Syracuse, Cortland): Counts 10, 36 and 46
Southern Tier (Binghamton, Endwell, Elmira, Ithaca): Counts 7, 8, 10, 22, 23 and 25
Capital Region and North Country (Albany, Schenectady, Essex County): Counts 1, 10, 16, 22, 23, 27 and 36
Hudson Valley and Catskills (Yonkers, Ossining, Sullivan County): Counts 15, 22, 32 and 36
Long Island (Nassau and Suffolk Counties): Counts 10, 15 and 37 Every county: Counts 29, 31, 35, 45 and 46
PART ONE — THE MENTALLY ILL AND THE HOMELESS, LEFT TO THE STREETS
COUNT ONE
Dereliction Resulting in the Deaths of the Winter of 2026
Saritha Komatireddy and the Exasperated People of the State of New York further allege that the defendant abandoned New York’s homeless and mentally ill, and the neighbors who live beside them, as follows:
10. On the evening of January 23, 2026, the temperature in New York City fell from 38 degrees to 14 in a single day. It stayed below freezing for more than eleven days. By the time the City Council held its oversight hearing on February 10, the City counted 25 deaths in the cold snap. Eighteen people had been found dead outdoors, fifteen of them from hypothermia, and seven more had died in their homes. Ten of the first sixteen people found outdoors had prior contact with the shelter system.
11. The names of the dead were not officially released. The press and their families supplied them. Nolberto Jimbo-Niola, 52, born in Ecuador, was found on the morning of Sunday, January 25, sitting on a park bench off 34th Avenue in
6Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
North Corona, Queens. In his pocket were hospital discharge papers dated that Friday. A Code Blue alert, under which homeless patients are not supposed to be discharged into lethal cold, was already in effect.
12. Michael Veronico, 44, had been homeless since 2008 and had cycled through the shelters of Hell’s Kitchen for years. He was found on a stairwell at Warren and Smith Streets in Brooklyn on the morning of January 24, weeks before his 45th birthday. His sister said drugs, not exposure, took him, and that only a sustained public effort could have changed his odds. He did not get one.
13. Frederick Jones, 67, a Midtown resident under a guardianship, was found about a mile from his building. A 60-year-old man, whose name has not been released, was found on the grounds of a Bronx hospital, two days after he was discharged from it. Doreen Ellis, 90, who had dementia, wandered from her Brooklyn apartment during the storm and was found in her nightgown in the snow. Kenneth Luna, 29, was found in St. Mary’s Park in Mott Haven. Philip Piuma, 47, an alarm dispatcher and a parishioner of All Saints Episcopal Church in Bayside, was found on a bench outside a supermarket in Flushing on January 27, where he had been seen sitting the night before.
14. The director of the Coalition for the Homeless, in the organization since 1988, said he could not recall so many people dying outdoors in so short a time. He said the reason people refuse shelter is that the shelters are places they have learned to fear.
15. The cold did not kill only in the five boroughs. On the morning of November 30, 2025, Dajohn Woodberry Jr., 21, who was homeless, was found dead of hypothermia outside the north parking garage at Albany International Airport. The overnight temperature was about 30 degrees. Advocates in Albany said there were 78 Code Blue spaces for everyone who needed one.
16. The defendant had eight winters in office before this one. Under the Mental Hygiene Law, New York has long held the authority to commit those who cannot care for themselves, an authority the Legislature broadened in 2025. The defendant’s
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Charities Bureau regulates every nonprofit that runs a shelter in this State. The defendant’s office had the standing, the budget, and the platform to demand why hospitals discharge patients into Code Blue, why shelters are places people would rather die than enter, and why the mentally ill are left on benches until they stop moving. The People have found no evidence that she ever used any of them for that purpose. In January 2026 the cold did the rest.
17. Another winter is weeks away. On September 22, 2026, police officers stopped being sent to 311 complaints about homeless encampments in New York City, and no response time was announced for the agency that replaced them. Those calls peak every fall. The State Comptroller reported that encampment calls to 311 rose 12 percent last year. The policy tracks the defendant’s own recommendation. Her July 2020 report said police had become “the de facto response” to homelessness and mental illness, that this “must change,” and that armed officers should be removed from those calls by 2023. One legal services organization that receives grants from her office praised her “call to remove the NYPD” from “any enforcement involving homeless New Yorkers.” The NYPD’s Homeless Outreach Unit was dissolved that year. Whatever replaced it has not kept people from dying on benches.
Where the defendant failed: The defendant told New York in 2020 to take the police out of homelessness and said professionals would replace them. The People have found no evidence that in eight winters she built a mechanism, brought a case, or made a demand to protect the homeless from the cold, that she sent the Charities Bureau to examine conditions inside a single shelter, or that she sought the commitment of one New Yorker too sick to come indoors.
The record: Gothamist, Jan. 28, 2026; Gothamist, Feb. 12, 2026; THE CITY, Feb. 10, 2026; News 12 Bronx, Feb. 10, 2026; State Comptroller report, March 2026; WNYT Albany (Woodberry); Daily Voice via AOL; WNYT on Albany Code Blue capacity; Attorney General’s July 2020 report; Grantee statement, July 8, 2020; BK Reader on the Feb. 10 hearing; NY1, Feb. 2, 2026.
8Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT TWO
Dereliction in the Death of Erin Piacenti
18. On the afternoon of Monday, August 31, 2026, in Times Square, a 49-year-old Queens woman whose mental-health encounters with the NYPD were on record from 2018 and 2019 took two knives from a shopping bag and stabbed two strangers about twenty seconds apart. Erin Piacenti, 32, a bank vice president from Chester, New Jersey, on her first day back at work from maternity leave, died at the hospital. She left a husband and a five-month-old daughter. A 68-year-old man who had just stepped off the subway with his wife was stabbed and survived. Officers shot and killed the attacker after a four-minute standoff in which a stun gun failed and she threatened to kill them.
19. The attacker was known to the system. That is the pattern in every count of this Part. Ms. Piacenti walked through the busiest intersection in the country and did not walk out.
20. The one investigation the People can find that the defendant’s office opened after Times Square is the one state law requires: into the officers who shot the attacker.
Where the defendant failed: In 2020 the defendant’s office recommended removing police from mental-health calls and replacing them with “dedicated professionals.” The People have found no evidence that in the six years since she has assigned a single lawyer or physician among her 1,950 employees to identify dangerously mentally ill New Yorkers and bring commitment proceedings before they kill.
The record: CBS New York, Sept. 1, 2026; Associated Press, Sept. 1, 2026; WHYY/6abc; Attorney General’s July 2020 report.
COUNT THREE
Dereliction in the Death of Ross Falzone
21. On the night of May 7, 2026, Ross Falzone, 76, a retired special-education teacher, was shoved down the stairs of the 18th Street station in Chelsea. He died at Bellevue Hospital before dawn on May 8. The man charged, Rhamell Burke, 32, had been arrested four times since February, for assaulting a Port
9Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Authority police officer and a stranger among other charges, and released each time. On the afternoon of May 7 police picked him up a fifth time and took him to a hospital for a psychiatric evaluation. He arrived at 3:39 p.m. and was let go in a little over an hour. About five hours later he killed a man. He was still wearing the hospital wristband.
Where the defendant failed: A man with four arrests in three months went from a psychiatric emergency room to a subway staircase in a single afternoon. The People have found no evidence that the defendant, whose office wrote the 2020 plan to take police out of mental-health response, ever asked how that happened, or offered a plan for the people that report left behind.
The record: ABC7, May 2026; CBS New York; Gothamist; Fox 5 New York; Bloomberg, May 18, 2026.
COUNT FOUR
Dereliction on the Platform: Joseph Lynskey, Emine Yilmaz Ozsoy, and Michelle Go
22. On December 31, 2024, Joseph Lynskey, head of music programming at a Manhattan content company, was shoved into the path of a 1 train at the 18th Street station by Kamel Hawkins, 23. He survived, barely.
23. On May 21, 2023, Emine Yilmaz Ozsoy, 35, had her head shoved into a moving train at the Lexington Avenue-63rd Street station by Kamal Semrade, a shelter resident. She was paralyzed. He was sentenced this year.
24. On January 15, 2022, Michelle Go, 40, was shoved in front of an R train at Times Square by Martial Simon, a homeless man with schizophrenia who was later found unfit for trial. Her death, three years into the defendant’s tenure, was the warning.
10Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Where the defendant failed: In July 2020 the defendant recommended that police stop being the response to mental illness and homelessness. Eighteen months later Michelle Go was killed by a homeless man with schizophrenia. The People have found no evidence that the defendant has since proposed anything to get the violently mentally ill off the platforms and into treatment.
The record: AP/NY1 (Lynskey); CBS New York (Ozsoy); ABC7 (Ozsoy); NBC New York (Go); CBS New York (Go, 2025).
COUNT FIVE
Dereliction in the Burning of Debrina Kawam, and the Burning That Followed
25. On December 22, 2024, Debrina Kawam, 57, was sleeping on an F train at the Coney Island-Stillwell Avenue station when Sebastian Zapeta-Calil, a resident of a Brooklyn men’s shelter, set her on fire. She burned to death in the car. She had been living in City shelters since at least September 2024 and before that in Toms River, New Jersey. It took nine days to identify her.
26. On December 1, 2025, less than a year later, a 56-year-old homeless man asleep on a 3 train at Penn Station was set on fire by Hiram Carrero, 18. His name has not been made public. Two New Yorkers were set on fire on the subway in twelve months. Both were homeless, and one was killed by a shelter resident.
Where the defendant failed: The defendant’s Charities Bureau regulates the nonprofits that run those shelters. The People have found no evidence that it opened an inquiry after either burning. Her grant program, meanwhile, has paid nearly $7 million to an organization that lobbied to bar police from homeless outreach altogether.
The record: CNN, Dec. 31, 2024; PBS NewsHour; NBC New York, Dec. 2025; Gothamist, Dec. 2025.
11Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT SIX
Dereliction in the Deaths of Angel Lata Landi, Chang Wang, and Wilma Augustin
27. On November 18, 2024, Ramon Rivera, 51, homeless and released from Rikers Island on October 17, walked across Manhattan and stabbed three strangers to death: Angel Lata Landi, 36, a construction worker; Chang Wang, 67, who was fishing on the East River; and Wilma Augustin, 36, who was sitting on a park bench. The Mayor called it a failure of the criminal justice and mental health systems. One month out of jail, three New Yorkers dead.
Where the defendant failed: The People have found no evidence that the defendant’s office ever asked how a man like Mr. Rivera is released, where he goes, or who watches him. It did have $6.5 million for one legal services organization whose decarceration project seeks “a collective future without jails.”
The record: Manhattan District Attorney, indictment; NBC New York; CNN, Nov. 24, 2024.
COUNT SEVEN
Dereliction in the Death of Peter Bennedum of Binghamton
28. Peter Bennedum grew up in Binghamton. He was 45, a father, homeless, and struggling with addiction. On the night of April 27, 2026, near Carroll and Henry Streets on the North Side, five boys aged 13 to 15 punched and kicked him and left him on the sidewalk. He lay there for about an hour and a half before police found him. He died on May 5 at Wilson Medical Center. All five boys are charged with murder. Binghamton police said the motive was a social media trend: record an attack on a homeless or drug-addicted person and post it.
29. A week later, in Times Square, Leonides Baez, 39, a father of two, was stabbed in the heart by a teenager who told police it was a trend called “mess with crackheads.”
30. A grown man should not have been living on a sidewalk in Binghamton. If he was sick, he should have been somewhere
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with a bed and a doctor. For years New York has left people in obvious collapse on its streets, and a generation of children has learned from it that some people do not count.
Where the defendant failed: The defendant has the standing and the settlement money to press for treatment beds in every region of the State. The People have found no evidence that she pressed for a single one in Broome County, and Peter Bennedum died on a sidewalk as a prop in a video.
The record: WBNG Binghamton, May 6, 2026; WSKG, May 7, 2026; Spectrum News; Pipe Dream, Binghamton University.
COUNT EIGHT
Dereliction in the Endwell Motel Fire: Michelle Woolfolk and the Molyneaux Family
31. At about 6 a.m. on Monday, June 22, 2026, fire swept the length of a motel on East Main Street in Endwell, Broome County. Six people died of smoke inhalation: Michelle Woolfolk, 58, on the first floor, and on the second a family of five, Josh Molyneaux, 29, Domonique Cruz-Champion, 27, and their children Ella, 3, Romyn, 2, and Zachariah, ten months. About 70 people were displaced. The motel was one of several used to house homeless families at public expense, with 56 placements there that morning. State Police charged a resident, Tyler Russell, 24, a parolee, with arson and six counts of manslaughter.
32. Some $9.4 million in public money was spent in Broome County in 2025 placing homeless families in hotels and motels. Weeks before the fire, a Spectrum News review found that the motel was one of three in the county where families were living next door to registered Level 2 and Level 3 sex offenders. A resident who had been there three weeks with her children said the place did not feel safe. A state legislator from the area said afterward that the problem is statewide.
13Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Where the defendant failed: Across upstate New York, homeless families are being housed in roadside motels for want of anything better. The People have found no evidence that the defendant has ever examined that system, in Broome County or anywhere else. Six people died in it.
The record: New York State Police, June 26, 2026; WBNG, June 25, 2026; Spectrum News, June 22, 2026; Spectrum News, June 25, 2026; States Newsroom, June 26, 2026; Spectrum News, July 8, 2026.
COUNT NINE
Dereliction Inside the Shelters: Nicholas Ahmad, Victoria Goode, Robbie Miller, and Michael Nairy
33. On Sunday, September 27, 2026, shortly before noon, Nicholas Ahmad, 33, was stabbed to death inside the Fort Washington Men’s Shelter on West 168th Street, a 200-bed facility for men with both mental illness and substance use disorders. Prosecutors say a fellow resident, Javed Tyghter, 29, announced in front of witnesses that he was going to kill Mr. Ahmad, went to his room, came back, and did it. The shelter is run under a City contract by one organization that works with the homeless.
34. It was not the first killing in a shelter run by that organization. On December 16, 2022, Victoria Goode, 27, was stabbed to death by her roommate on the sixth floor of the New Providence Women’s Shelter on East 45th Street, which it also runs. Residents said afterward that doors did not lock and that they slept with one eye open. In 2022 NBC News reported accounts from former residents and employees of abuse at a Bronx shelter for LGBTQ adults that the same organization ran. It holds a 40-year City contract, reported at $500 million, for the 200-bed women’s shelter it opened this year on West 59th Street, beside the Gertrude Ederle Playground. Neighbors asked for an investigation of that contract in 2023. The People have found no evidence that the Attorney General took it up.
35. On December 26, 2024, Robbie Miller, 35, a social worker employed by the nonprofit that ran a Brownsville homeless shelter, was stabbed to death at the entrance to that shelter.
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Police found him in the lobby. The people who care for the homeless are being killed in facilities the defendant’s office is charged with overseeing.
36. It happens upstate as well. On the night of August 7, 2022, at a homeless shelter on Ormond Street in Rochester, Michael Nairy, 68, was stabbed to death as he lay in his bed. A second resident, in his twenties, was stabbed and survived. Police called the attack unprovoked and charged a fellow resident, Nathaniel Jeanpierre III, 40, with murder.
37. The defendant has gone to federal court to keep shelter funding flowing to operators like these without conditions, and issued press releases about each win. In eight years she has investigated only two shelter operators, both over stolen money. Neither inquiry touched safety.
Where the defendant failed: Residents have been stabbed to death in their beds and hallways in shelters from Washington Heights to Rochester, and a shelter worker was killed at his post. The defendant has investigated only two shelter operators in eight years, and the People have found no evidence that she has ever examined the safety record of any shelter operator.
The record: New York Times via DNYUZ, Sept. 28, 2026; CBS New York, Dec. 2022; amNewYork, Dec. 2022; West Side Spirit; Shelter operator on its 40-year contract; Gothamist (Miller); Brooklyn Eagle (Miller); Democrat and Chronicle via Yahoo (Nairy).
COUNT TEN
Dereliction From Binghamton to Buffalo to Long Island: Kevin Ray, Laverne Singletary, Karen Wargo, and the Workers of the Buffalo Psychiatric Center
38. The disorder is not confined to the City. In Binghamton, on May 13, 2025, Kevin Ray, 57, was stabbed to death at a charity’s facility at 131 Washington Street by Michael Brutvan. The facility closed indefinitely.
39. In Rochester, in July 2025, Karen Wargo, 46, who was homeless, was found dead on a sidewalk. Police said video showed
15Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
her being assaulted and kicked by Tavontay Haygood-Session, 31, who had pleaded guilty in 2024 to trying to set fire to a house with children inside. On September 22, 2025, Laverne Singletary, 59, was killed with a screwdriver at a gas station on Portland Avenue by Antonio McKnight, who had a prior conviction for a 2019 stabbing at the Rochester transit center.
40. In Buffalo, on April 3, 2024, Calvin Haskins stabbed three employees of the Buffalo Psychiatric Center with a knife hidden in his sock. He had earlier been charged with stabbing a man 17 times at a downtown Metro Rail station. He was sentenced to 20 years in January 2026.
41. In Albany, on September 20, 2024, John Hughes, 44, who was homeless, pulled a nail-studded board from a dumpster at Grand Street and Madison Avenue and beat a stranger with it. He was sentenced to seven years.
42. In Syracuse, officials describe the block outside one homeless shelter on Dickerson Street as a place of nightly fights, open drug use, and stabbings. A fence was built to contain it. In March 2026 a 41-year-old man was stabbed multiple times there.
43. On Long Island, on February 18, 2025, a man was found murdered inside a waist-high tent in a wooded homeless encampment off Suffolk Avenue in Central Islip.
Where the defendant failed: The defendant keeps regional offices in Binghamton, Rochester, Buffalo, Syracuse, Utica, Poughkeepsie and on Long Island. The People have found no evidence that any of them has brought a commitment proceeding or opened an inquiry into a shelter. In every region the pattern is the same.
The record: WBNG (Ray); BinghamtonHomepage; WROC (Singletary); WHEC; Erie County District Attorney; WNYT (Albany); CNY Central (Syracuse); WROC via Yahoo (Wargo); CNY Central, March 2026; Spectrum News (Syracuse fence); News 12 Long Island, Feb. 2025; Attorney General’s regional offices.
16Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT ELEVEN
Dereliction in Tolerating Illegal Injection Sites
44. Since November 2021 two supervised injection sites have operated in East Harlem and Washington Heights. New Yorkers are handed clean needles and a quiet room in which to use fentanyl. In August 2023 the United States Attorney for the Southern District of New York said the sites were operating in violation of federal, state and local law and called that “unacceptable.” New York City recorded more than 3,000 overdose deaths in 2022, a record, with the sites open. Opioid settlement money has gone to syringe exchange programs. There are New Yorkers waiting weeks for a detox bed while public money subsidizes the alternative.
Where the defendant failed: A federal prosecutor said the sites violate New York law. The People have found no evidence that the State’s chief law enforcement officer has ever moved to close them.
The record: City & State, Aug. 2023; CBS New York, Aug. 2023.
PART TWO — REPEAT OFFENDERS, THE SUBWAY, AND THE WAR ON POLICE
COUNT TWELVE
Dereliction in the Death of Richard Williams
Saritha Komatireddy and the Exasperated People of the State of New York further allege that the defendant sided with repeat offenders over their victims and over the police, as follows:
45. On March 8, 2026, Richard Williams, 83, a United States Air Force veteran, was shoved onto the tracks at the Lexington Avenue-63rd Street station. Seconds earlier the same man had shoved Jhon Rodriguez, 30, onto the same tracks. Mr. Rodriguez, hurt himself, helped lift Mr. Williams off the rails before the next train came. Mr. Williams never regained consciousness and died of his injuries on March 17. The man charged, Bairon Posada-Hernandez, 34, had been deported four times, most recently in 2020, and had 15 prior arrests, according to the Department of Homeland Security. He was at
17Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
large in New York regardless. He was indicted for murder. Mr. Williams served his country and was killed waiting for a train in the city whose chief law enforcement officer had other priorities.
Where the defendant failed: The defendant has gone to court to ensure that violent criminals are released back into our communities. The People have found no evidence that she ever asked how a man deported four times and arrested fifteen came to be standing behind Mr. Williams on a Manhattan platform.
The record: PIX11, March 2026; NBC New York; Fox News.
COUNT THIRTEEN
Dereliction in the Attack on Amelia Lewis
46. On December 1, 2025, Amelia Lewis, 20, a New York University student, was attacked from behind on Broadway in Manhattan. The man arrested, James Rizzo, 45, had sixteen prior arrests, was a Level 2 sex offender, and had been released from state prison in September 2025, less than three months earlier. He was also charged with attacking Dianne Brazell, 68, a visitor from Houston, in Midtown on Thanksgiving.
Where the defendant failed: A parolee with sixteen arrests and a sex-offender designation was on the sidewalk within weeks of release. The People have found no evidence that the defendant’s office treated that as its problem. Her office has paid $6.5 million to one legal services organization that campaigned for the law that ended detention for technical parole violations.
The record: ABC7, Dec. 2025; CBS New York; Fox News.
COUNT FOURTEEN
Dereliction in the Death of Keaira Bennefield of Buffalo
47. On September 28, 2022, in Cheektowaga, Adam Bennefield, 45, beat his estranged wife, Keaira Bennefield, 30, a mother of three. She gave police a video of it and told them she believed he was capable of killing her. He had already
18Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
served 15 years in prison for kidnapping another woman at gunpoint. He was arraigned on October 4 on misdemeanor charges. The judge issued an order of protection and released him, saying the law did not permit bail on those charges whatever his record.
48. The next morning Ms. Bennefield put on a bulletproof vest to drive her children to school in Buffalo. At about 8:30 a.m., at Shawnee and Richlawn Avenues, Mr. Bennefield rammed her car with his truck and killed her with a shotgun. Her children, aged six months to nine years, were in the back seat. A jury later convicted him of murder.
Where the defendant failed: No judge in New York was allowed to weigh the danger Adam Bennefield posed to his wife. The defendant called for New York to “accelerate bail reform” in 2018 and said in 2021 that bail reform was not the problem. The People have found no evidence that she has ever asked the Legislature to let judges consider dangerousness. Keaira Bennefield wore a bulletproof vest because the law would not protect her.
The record: WKBW Buffalo, verdict; WGRZ Buffalo; Investigative Post, Nov. 3, 2022; Fox News.
COUNT FIFTEEN
Dereliction on Long Island: Malcolm Brown and Donna Conneely
49. On February 29, 2024, a girl walking to school in Babylon saw a severed arm in the leaves at Southards Pond Park. Over the next week police found the dismembered remains of Malcolm Brown, 53, and Donna Conneely, 59, both of Yonkers, in Babylon, West Babylon and Bethpage State Park. Four people were charged with cutting up and hiding the bodies. Meat cleavers and butcher knives were recovered. All four were released without bail. The Suffolk County District Attorney explained that under the 2019 law the charges were not bail-eligible and his prosecutors could not ask for bail. “In New York state,” he said, “we cannot argue dangerousness as a factor in our bail applications.”
19Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
50. One of the four was arrested again within days for shoplifting. Two were later indicted for the murders.
Where the defendant failed: Four people accused of dismembering two bodies walked out of a Suffolk County courtroom because the law the defendant asked New York to “accelerate” gave the judge no choice. The People have found no evidence that she said a word about the case or has ever asked that the law be changed.
The record: ABC7, April 29, 2024; Fox 5 New York; CBS New York; Long Island Press.
COUNT SIXTEEN
Dereliction Toward Chelsea Mora, Virginia Alvarez, and the Healthcare Workers of New York
51. On January 13, 2024, at Jacobi Medical Center in the Bronx, nurse Chelsea Mora was punched in the face by Edward Johnson, a repeat offender with a history of attacking medical staff, while she took his vital signs. She was left with a serious eye injury. He was granted supervised release two days later. On October 15, 2025, Virginia Alvarez, 46, a nurse’s aide at BronxCare, was beaten with fists and a metal pipe on her way to work, suffering fractures to her face and hands. The man arrested, Jeremiah White, 23, was charged with attacking a 15-year-old girl and a 54-year-old woman the same morning. A Manhattan hospital nurse attacked by a patient saw only misdemeanor charges filed, though New York law makes assault on a healthcare worker a felony.
52. The violence is statewide. In the Capital Region, St. Peter’s Health Partners reported that incidents of physical violence at its hospitals more than doubled between 2019 and 2025, an increase of 109 percent, according to Spectrum News. In April 2026, Rochester police said, a man at Rochester General Hospital became enraged with a nurse, pulled a loaded 9mm handgun, and threatened her before turning on the security officers who came to help.
53. State lawmakers report that roughly 70 percent of emergency room nurses in New York have been physically assaulted
20Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
at work, and that one incident in three results in injury. Workplace violence was a leading demand of the nurses who struck New York City hospitals in the winter of 2026.
Where the defendant failed: New York does not lack a statute. The People have found no evidence that the defendant has ever said the statute’s name out loud or stood beside the district attorneys who enforce it. The man who punched Chelsea Mora was back on the street in two days under release rules the defendant defends.
The record: ABC7, March 2024 (Mora); CBS New York, Oct. 2025 (Alvarez); News 12 Bronx, Dec. 2025.
COUNT SEVENTEEN
Dereliction in the Face of the Repeat-Offender Machine
54. According to New York Criminal Justice Agency data compiled by the campaign, in Manhattan alone, in the past year, 10,551 defendants were arrested and prosecuted for a new offense while on pretrial release; 1,753 of those were violent felonies. Re-arrests while awaiting disposition rose 76 percent, from 15,958 to 28,058. In early 2026 only 2,652 of roughly 44,091 arrestees were detained. Reported rape in Manhattan rose 26.7 percent and felony assault 14.5 percent between 2022 and 2025.
55. In January 2022 a written charging policy took effect in Manhattan under which certain misdemeanors would not be prosecuted, armed commercial robbery would be charged as petit larceny absent a “genuine risk of physical harm,” and incarceration would be a “last resort.” The results have been catalogued by the NYPD and the press: a man with 101 career arrests still free; a reputed gang member given a plea deal on multiple felonies, later arrested for mugging a 14-year-old at gunpoint; a robbery suspect freed without bail after charges were downgraded, later arrested for attempting to rape a 15-year-old; a man who raped a teenage relative given a plea deal, then charged with sexually attacking five more people within a month.
21Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Where the defendant failed: Executive Law Section 63(3) permits the Attorney General, on referral from the Governor, to prosecute what a district attorney will not. The People have found no evidence that the defendant ever sought such a referral or publicly objected to the policy. The perpetrators walked.
The record: New York Criminal Justice Agency data; CBS New York, Jan. 5, 2022; NYPD, Aug. 3, 2022; New York Post, Feb. 17, 2023; New York Post, June 16, 2022; New York Post, Sept. 22, 2022; Executive Law Section 63.
COUNT EIGHTEEN
Dereliction at the Turnstile: She Investigated the Police for Enforcing the Fare
56. On January 13, 2020, in her second year in office, the defendant announced an investigation of the New York City Police Department over its enforcement of the subway fare. She demanded the department’s arrest and summons data, its training materials and its agreements with the MTA, and warned that her office “will not hesitate to take legal action.” The message to every officer standing at a turnstile was plain.
57. By the MTA’s own counts, subway fare evasion has roughly tripled since 2019, and the Citizens Budget Commission has put the cost of fare and toll evasion at about $1 billion a year. By October 1, 2026, twenty people had been shoved onto New York City subway tracks since the start of the year. More than four million New Yorkers ride the subway every day and stand back from the platform edge when they do.
Where the defendant failed: One of the defendant’s first acts on subway safety was to investigate the police for enforcing the fare. Many of the people who rob, grope and shove riders never pay it. The People have found no evidence that she has called for enforcing the fare since or offered riders anything else.
The record: Attorney General press release, Jan. 13, 2020; NY1, Jan. 14, 2020; New York Daily News, June 1, 2026.
22Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT NINETEEN
Dereliction by Design: The Defendant’s Own Words and Her Own Report
58. The defendant’s inaction was not an oversight. It was consistent with what she said she believed. On January 1, 2018, in her inaugural address as Public Advocate, the defendant urged New York to “accelerate bail reform.” On June 9, 2020, at a Columbia University panel, she endorsed the “concept” of “defunding the police,” defined it as “reprioritizing the budget in NYPD” and “taking resources out” of the police, and said the nation must “reconsider the very fundamentals of how we as a society want to be policed.” According to research compiled for the People, she called that year for “redesigning” the role of police, and in 2008 defended an art exhibit that portrayed NYPD officers as trigger-happy racists.
59. She then put it in writing. On July 8, 2020, the defendant’s office issued a report on the NYPD that went well past its subject. It recommended that the role of police be “redesigned”; that armed officers be removed from calls involving mental illness, homelessness and school safety and replaced by 2023; that minor offenses be decriminalized “with the goal of reducing negative contact with the police”; that the Civilian Complaint Review Board be given “final disciplinary authority” over officers in place of the Police Commissioner; and that the department be put under a commission with the power to hire and fire the Commissioner and approve the NYPD’s budget. The report also endorsed removing police from traffic enforcement. The NYPD called it “political and not an investigative document.” Pieces of it have since become policy.
60. On June 24, 2021, asked directly whether bail reform was fueling shootings, the defendant answered: “No, I don’t believe that.” In a 2022 questionnaire she warned against “overreacting to spikes in crime” and said such spikes did not warrant changing the bail law. In September 2020 her office recommended that the NYPD get out of routine traffic enforcement and stop arresting motorists on low-level warrants at traffic stops.
23Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
61. New York remains the only state in the nation whose judges may not weigh a defendant’s dangerousness when setting bail.
Where the defendant failed: The defendant did not overlook the retreat from policing. She wrote the plan for it: fewer arrests, no police at homeless or mental-health calls, discipline taken from the Commissioner, the department’s budget in the hands of a commission. The People have found no evidence that the State’s chief law enforcement officer has ever asked the Legislature to let judges consider dangerousness. By her own account she does not think the law is broken.
The record: Columbia SIPA panel video, June 9, 2020; Public Advocate inaugural video, Jan. 1, 2018; New York Post, June 24, 2021; Jim Owles club questionnaire, 2022; New York Post, Sept. 25, 2020; Attorney General press release, July 8, 2020; Attorney General’s preliminary report on the NYPD; City & State, July 2020.
COUNT TWENTY
Dereliction by Subsidy: $54 Million to the Other Side
62. Between January 2019 and 2026, the defendant’s office disbursed roughly $226 million in grants. According to the State Comptroller’s public checkbook, more than $54 million of it, nearly one dollar in four, went to organizations working to restrain the police: $20.9 million to one legal services organization and its affiliates, which campaign to remove police from the City’s public schools; $8,238,213 to a Western New York legal organization that is suing the City of Buffalo over community policing; $8,192,613 to a Rochester-based legal organization that seeks to curtail police stops; $6,971,387 to a legal organization that seeks to bar police from engaging the homeless; $6,495,936 to a legal services organization whose decarceration project seeks “a collective future without jails”; and $3,350,116 to a sixth organization. The money came through the Homeowner Protection Program, a foreclosure-prevention fund over which the office holds “sole discretion.” Her predecessor paid the same groups a fraction of these sums.
24Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
63. In August 2020, while receiving the defendant’s grants, that sixth organization declared: “Defund the NYPD and redistribute the funds to services that actually benefit people.” It received payments from the defendant’s office before and after that statement. New Yorkers paid for it twice: once as taxpayers, and again as the victims named in the counts above.
Where the defendant failed: The defendant had sole discretion over these grants and sent nearly one dollar in four to organizations working against the police.
The record: State Comptroller, Open Book checkbook; New York Post, Aug. 9, 2026; Grantee statement, Aug. 23, 2020; Grantee decarceration project; Grantee statement, June 18, 2020; Grantee testimony, Dec. 2020; Grantee campaign on police stops; WKBW on the Buffalo lawsuit; Attorney General’s HOPP grant terms.
COUNT TWENTY-ONE
Dereliction Toward Officer Nicole Amatore
64. In December 2025, Rochester Police Officer Nicole Amatore ran toward gunfire and stopped a 38-year-old gunman who had already shot three of her fellow officers. All three survived. In September 2026 the State named her New York’s Police Officer of the Year. From that night to this day, some ten months, Officer Amatore has been under open investigation by the defendant’s office. State law requires the Attorney General to investigate every death at the hands of police. It does not require her to take ten months to tell the State’s Police Officer of the Year whether she is cleared.
Where the defendant failed: In 2020 the defendant demanded that police discipline be taken from police commanders and made independent and transparent. The People have found no evidence that her own investigations of officers carry any deadline, are independent, or are transparent. She has left the State’s Police Officer of the Year under a cloud for ten months.
The record: CNY Central, Sept. 2026; Officer.com; Executive Law Section 70-b.
25Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT TWENTY-TWO
Dereliction Toward the Corrections Officers of Upstate New York
65. The State’s prisons are upstate institutions: Collins in Erie County, Elmira in Chemung, Groveland in Livingston, and dozens more from the North Country to Sing Sing. Since the HALT Act took effect in 2022, the State’s own corrections data show assaults by inmates on staff rising sharply, by roughly 65 percent in 2024 over the same period of 2021. Officers were being ordered to work 24 hours straight.
66. On February 17, 2025, officers at Collins, Elmira and Groveland refused to report for duty, and the walkout spread to nearly every prison in the State. They asked for safer conditions. The defendant’s office filed a Taylor Law case against them. Within days a State Supreme Court justice signed the injunction her office sought, the State added the names of 300 officers and sergeants to its court papers, and State Police served orders on them at their homes.
Where the defendant failed: For three years the people who run New York’s prisons said they were being beaten on the job. The People have found no evidence that the defendant ever used her office to examine it. What the record does show is that she took the officers to court.
The record: The Post-Journal, Jamestown, Feb. 2025; CBS New York; Albany Law School Government Law Center; Spectrum News, Feb. 27, 2025.
PART THREE — HATE CRIMES AND ANTISEMITISM
COUNT TWENTY-THREE
Dereliction in the Face of a Wave of Antisemitic Violence
Saritha Komatireddy and the Exasperated People of the State of New York further allege that the defendant left Jewish New Yorkers without the protection of her office, as follows:
67. According to figures the campaign compiled from the State’s Division of Criminal Justice Services, New York recorded 505 hate crimes in 2020 and 989 in 2024. The Anti-Defamation
26Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
League’s annual audits counted 430 antisemitic incidents in New York in 2019 and 1,437 in 2024. Jewish New Yorkers are roughly one in ten City residents. Through the first seven months of 2026, by the NYPD’s count, they were the targets of 56.9 percent of confirmed hate crimes in the City.
68. The cases are not abstractions. On July 23, 2026, on the fast day of Tisha B’Av, a 50-year-old man wearing a kippah was stabbed in the chest with a screwdriver as he left the Jewish Center on West 86th Street. He has asked that his name not be published. The man charged, Raul Morales, 51, had stabbed a 57-year-old Asian man in the back four blocks away minutes earlier, and witnesses told police he shouted “Allahu akbar.” On August 14, 2026, Larry Montes, 46, of the Bronx, walked into Friday night services at Central Synagogue in Midtown shouting antisemitic slurs, struck a 63-year-old congregant, Michele Anenberg-Poma, in the face, and spat on and headbutted a 65-year-old security guard. The Manhattan District Attorney indicted him for hate crimes. The defendant’s response was a statement that she was relieved everyone was recovering. On January 28, 2026, a car was driven into Chabad-Lubavitch world headquarters at 770 Eastern Parkway in Crown Heights.
69. It is not only a City problem. On December 7, 2023, hours before the first night of Hanukkah, Mufid Fawaz Alkhader of Schenectady walked up to Temple Israel in Albany with a shotgun, fired twice into the air shouting “Free Palestine,” and tried to fire a third time before the gun jammed. Sixty-one children were in the preschool inside. One mother told the court her daughter’s teacher had prepared the children in her care to die. In October 2023 a Cornell University student from Pittsford, Patrick Dai, posted threats to shoot up the kosher dining hall in Ithaca, to “bomb jewish house,” and to stab and rape Jewish students. Cornell canceled classes. Both men were prosecuted by the United States Attorney. Mr. Alkhader received ten years and Mr. Dai 21 months. The People can find no civil action by the State’s Attorney General in either case.
70. The Attorney General’s own hate-crime authority is both criminal and civil. Executive Law 63(10) lets her take over any hate crimes prosecution that is not being effectively prosecuted by the district attorney, and her office has a Hate
27Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Crimes Unit to do it. She has not criminally prosecuted a hate crimes case even once, and has left the unit unstaffed. Civil Rights Law Section 79-n lets her sue anyone who attacks, threatens or intimidates a person because of religion. She knows how. In 2021 she sued a Schenectady man under that statute for choosing his victims by race. The People can identify no such action by the defendant over any attack described in this count. When antisemitic violence broke out at Columbia University in 2024, her public response was that her office was “monitoring the situation closely.”
Where the defendant failed: Reported hate crimes rose sharply on the defendant’s watch, and Jewish New Yorkers are the targets of most of them. She has criminal and civil authority over hate crimes and a unit to use it, and the People can find no case she brought over any attack described here, in the City, in Albany, or in Ithaca. She issued statements and monitored.
The record: Associated Press, July 24, 2026; Times of Israel, July 24, 2026; Jerusalem Post; Division of Criminal Justice Services statistics; U.S. Attorney, N.D.N.Y. (Temple Israel); Spectrum News, Aug. 12, 2025; U.S. Attorney, N.D.N.Y. (Cornell); Civil Rights Law Section 79-n; Attorney General press release, 2021 (Schenectady suit); Attorney General statement on Columbia, 2024; Associated Press, Aug. 15, 2026
(Central Synagogue); JTA, Aug. 2026; Combat Antisemitism Movement on NYPD data.
COUNT TWENTY-FOUR
Dereliction of the Tools Already in Her Hands
71. New York Civil Rights Law Section 79-m empowers the Attorney General to go to court against anyone who interferes with access to a place of religious worship. The defendant has used that statute to keep protesters away from other buildings. The People have found no evidence that she has ever used it for a synagogue. Title VI of the Civil Rights Act protects Jewish students from discrimination on campus. The defendant has brought civil rights actions on behalf of students of other backgrounds. The People have found no evidence that she has brought one for Jewish students.
28Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Where the defendant failed: The defendant needs no one’s permission to seek a buffer zone around a synagogue or to sue a school that lets Jewish students be threatened. The People have found no evidence that she has done either.
The record: Civil Rights Law Section 79-m.
PART FOUR — SEX CRIMES
COUNT TWENTY-FIVE
Dereliction in Leaving the Rape-Law Loophole Open for Eight Years
Saritha Komatireddy and the Exasperated People of the State of New York further allege that the defendant failed as follows:
73. On October 1, 2026, the Governor named the defendant special prosecutor in the case of a former Cornell University student, identified in court papers as Jane Doe, who alleges that seven men raped her at a fraternity house in Ithaca in October 2024. The Tompkins County district attorney had declined to prosecute. He said the woman told police she drank and took drugs willingly, and that under New York law her account did not describe a crime.
74. The law he was pointing to is Penal Law Section 130.00. It treats a person as too incapacitated to consent only if the alcohol or drugs were given to her without her consent. A bill to close that loophole was first introduced in 2019, the year the defendant took office. The Senate has passed it unanimously more than once. It has close to 100 Assembly cosponsors from both parties. The Assembly has never voted on it. The defendant endorsed the bill in a social media post in 2024. It died weeks later, again in 2025, and again this year.
Where the defendant failed: When a law keeps prosecutors from charging rape, it is the chief law enforcement officer’s job to get it changed. The defendant had eight legislative sessions and a Legislature led by her own party. Beyond one social media post, the People have found no evidence that she made the bill a priority.
29Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
The record: Gothamist, Oct. 1, 2026; City & State, Oct. 2, 2026; Newsweek, 2024; Penal Law Section 130.00.
COUNT TWENTY-SIX
Dereliction Toward Beverly Footman and Others Her Office Fights on Technicalities
75. The Adult Survivors Act gave victims of sexual assault one year to file civil suits that would otherwise have been too old to bring. Roughly 1,600 of those claims accuse state prison employees of abusing people in their custody. The defendant’s office defends the State against them. New York Focus reported that the office planned to ask judges to dismiss as many as 500 of the cases before any evidence was heard, on the ground that the claimants had not supplied exact dates and details. In the first test case a judge threw out a man’s lawsuit over typographical errors in his claim. His lawyers had asked to correct them. The defendant’s office objected.
76. The second test case belonged to Beverly Footman, who says three employees at Groveland Correctional Facility in Livingston County raped or molested her hundreds of times in 1990 and 1991. The defendant’s office asked a judge to dismiss her suit and submitted sworn statements that no one with the last name she gave for one of the men had ever worked at Groveland. Reporters found him in state payroll records. He had been head cook there for 25 years. The office withdrew its motion the same day. The man has denied her allegations. “They’ll always say you’re lying,” Ms. Footman told New York Focus.
Where the defendant failed: The State is entitled to a defense. It is not entitled to win a rape case on a typo. The defendant decides how her office litigates, and it told a judge that a prison cook did not exist when the payroll records were a public records request away.
The record: New York Focus, Feb. 20, 2026; New York Focus, Dec. 22, 2025.
30Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT TWENTY-SEVEN
Dereliction Toward Elizabeth Crothers
77. In 2001 Elizabeth Crothers, then 24 and chief of staff to an Assemblyman, reported that J. Michael Boxley, chief counsel to Assembly Speaker Sheldon Silver, had raped her. Mr. Silver announced an internal investigation and, at the same press conference, his full confidence in Mr. Boxley. The inquiry ended without a finding and Mr. Boxley kept his job. Two years later he was led out of the Capitol in handcuffs and charged with raping a second staffer, Rikki Shaw, who was 22. He pleaded guilty to sexual misconduct. Ms. Shaw’s lawsuit was later settled for $500,000, most of it public money. In 2015 the State paid another $545,000 to two aides sexually harassed by a member of the Assembly.
78. Ms. Crothers sued the State in 2023 under the Adult Survivors Act. The defendant’s office moved to have her case thrown out. A judge refused to dismiss her core claims. Her lawyer has said the office made “zero efforts to try to resolve the case.” Mr. Boxley invoked the Fifth Amendment more than 40 times at his deposition. According to the Times Union, the defendant’s office then listed him as one of its own defense witnesses. Trial was set for August 24, 2026.
Where the defendant failed: Nobody asks the defendant to answer for what Sheldon Silver’s Assembly did in 2001. She has to answer for what her office did in 2026. According to Ms. Crothers’s lawyer it made no effort to resolve her case, and according to the Times Union it listed the man she accused as its own witness.
The record: New York Post via AOL, April 7, 2026; Times Union, Aug. 2026; CBS New York, 2015.
COUNT TWENTY-EIGHT
Dereliction in Her Own House: Sofia Quintanar, a Chief of Staff, and $539,082.84 to Defend the Defendant
79. For about a decade the defendant had the same chief of staff. By the defendant’s own account she learned on October 2, 2022 that he had been accused of sexual misconduct. Her office
31Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
restricted his access and hired an outside law firm within the week. Voters were not told. The defendant was re-elected on November 8. The chief of staff resigned weeks later, and the matter became public only in December, through the press. One of the women, Sofia Quintanar, a former deputy press secretary in the office, has said he grabbed her and forcibly kissed her outside a Brooklyn fundraiser for the defendant on November 17, 2021. He has denied wrongdoing.
80. In 2021 the defendant’s office published a 165-page report finding that the then-Governor had sexually harassed 11 women, and she announced it at a televised news conference. In her chief of staff’s case the People have found no public release of the investigators’ findings and no statement of how many women came forward.
81. When Ms. Quintanar sued, the office retained an outside law firm. Taxpayers have paid that firm $539,082.84 of a contracted $575,000. A trial court dismissed the claims against the defendant and her office in 2025. On May 12, 2026, the Appellate Division revived Ms. Quintanar’s retaliation claims against the defendant’s campaign committee, and a separate claim against the office is proceeding in the Court of Claims. The public has absorbed the entire cost of defending the defendant’s handling of misconduct inside her own inner circle.
Where the defendant failed: When the man accused was a governor, the defendant held a press conference. When he was her own chief of staff and her name was on the ballot, she waited until the votes were counted, then sent the legal bill to the public.
The record: CBS New York, Dec. 7, 2022; Bloomberg Law, May 12, 2026; Quintanar v. Office of the Attorney General, 249 A.D.3d 488; Wigdor LLP on the Court of Claims ruling; State
Comptroller, Open Book contracts.
32Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
PART FIVE — FRAUD AND THE PUBLIC’S MONEY: THE WATCHDOG THAT DID NOT BARK
COUNT TWENTY-NINE
Dereliction of the Medicaid Fraud Control Unit: A “Deliberate Leadership Choice” and Federal Decertification
Saritha Komatireddy and the Exasperated People of the State of New York further allege that the defendant let the State’s fraud-fighting powers lapse while public money was stolen, wasted, and misspent, as follows:
82. The defendant’s Medicaid Fraud Control Unit receives roughly $60 million a year in federal funds, employs more than 270 people, and polices a $124 billion program covering nearly seven million New Yorkers. From 2023 through 2025 it reported 53 fraud convictions. The next-lowest unit of comparable size reported 129. In fiscal years 2023 and 2025 it secured eight to nine criminal indictments a year, while comparable states produced hundreds. Indiana’s unit, with 56 staff and a budget under $9 million, secured five times as many fraud indictments in fiscal 2025 and more civil recoveries.
83. The unit receives more than 2,000 referrals a year alleging abuse or neglect of Medicaid patients. Over the same three years it obtained four convictions for patient abuse or neglect. Federal inspectors found it had secured no more than five such convictions in any of the last six years. The residents of nursing homes in every county of the State, from Suffolk to Erie, were the victims of that arithmetic.
84. Measured against Medicaid spending during the defendant’s tenure, New York ranked 49th of 51 for investigations, 51st for indictments, and 51st for convictions. The unit returned $1.84 for every dollar spent in 2025, against a national average of $4.64. Its recoveries fell from $168 million in 2019 to $31 million in 2024.
85. On June 30, 2026, the United States Department of Health and Human Services denied recertification of the New York unit and suspended its federal funding effective July 1, 2026, finding it the “lowest performing” unit among its peers. The
33Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
defendant called the finding “outrageous” and said her office was “leading the nation.” The numbers say otherwise, and the numbers are hers.
86. The inspectors did not blame a shortage of money or staff. Their letter says the cause of the unit’s results “was a deliberate leadership choice to focus on civil fraud cases.” It calls that “leadership failure and poor decision making,” and it concludes that the unit “has sacrificed its ability to effectively fight criminal fraud.” The United States Attorney in Albany supplied the before and after. In 2016 through 2018, the three years before the defendant took office, the unit averaged more than 100 criminal indictments a year. From 2021 through 2025 it averaged nine. Medicaid fraud did not stop in 2019. The defendant’s office has defended the shift as intentional.
Where the defendant failed: Federal inspectors traced the collapse to a deliberate decision by the unit’s leadership to pursue civil cases in place of criminal ones. The defendant is that leadership. Criminal indictments fell from more than 100 a year before she took office to nine, and the unit lost its federal certification.
The record: HHS Inspector General letter, June 30, 2026; U.S. Attorney, N.D.N.Y., July 2, 2026; Empire Center, July 9, 2026; Jones Day analysis, July 2026.
COUNT THIRTY
Dereliction Toward the Crimes She Was Warned About in Writing
87. On Friday, August 28, 2026, Assistant Attorney General Daniel Wiesenfeld of the defendant’s Investor Protection Bureau sent an email to roughly 2,000 of his colleagues. He wrote that the office was spending “significant public taxpayer dollars to target convenient public enemies” while leaving unaddressed “rampant nonprofit homeless shelter fraud” and “crimes in and around synagogues.” He urged colleagues to find crimes first and defendants second, not the reverse.
88. The email was removed from the office’s servers. Mr. Wiesenfeld was placed on paid administrative leave. The defendant’s general counsel described the matter to staff as
34Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
“internal.” The crimes he named are the subjects of Parts Three and Five of this Complaint. The People have found no evidence that they have been addressed since.
Where the defendant failed: One of the defendant’s own prosecutors told her in writing where the fraud was. Her office removed the email and placed the prosecutor on leave.
The record: New York Post, Aug. 30, 2026; Washington Examiner, Sept. 2026.
COUNT THIRTY-ONE
Dereliction in the $11 Billion Home Care Program
89. New York’s Medicaid home care program lets hundreds of thousands of elderly and disabled New Yorkers, in every county, hire the aides who keep them out of nursing homes. In 2025 the administration of the entire $11 billion program was handed to a single company. Caregivers from Buffalo to Long Island went unpaid for weeks during the changeover. At least five lawsuits challenged the arrangement, two of them alleging the bidding was rigged. On June 16, 2026, the United States Department of Justice sued, alleging that state officials steered the contract and that the company misrepresented what it would deliver and overbilled.
90. Watchdog groups, legislators of both parties, reporters and health care associations had raised the alarm for years. The State Comptroller separately found billions of dollars in Medicaid home care billings that could not be verified.
Where the defendant failed: It took a federal lawsuit to bring the allegations into court. The defendant runs the one office in state government with a Medicaid Fraud Control Unit, the same unit her leadership steered away from criminal cases. The People have found no evidence that it ever examined the contract.
The record: New York Post, June 16, 2026.
35Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT THIRTY-TWO
Dereliction Toward the Shelter Operators Everyone Else Investigated
91. Since the defendant took office, watchdog after watchdog has found fraud in the nonprofit shelter business. Almost none of it was found by her. In 2019 the City’s Department of Investigation opened a probe of one shelter network that had taken more than $1 billion in City shelter contracts and paid $12 million in one year to a security firm founded by its own chief executive. In January 2020 federal prosecutors and City investigators raided a second provider, paid about $500 million by the City, over subcontractors that existed only as a vacant house and a post office box. In 2021 federal prosecutors charged Victor Rivera, chief executive of a Bronx shelter nonprofit, with taking bribes and kickbacks; ten women, among them a shelter resident named Erica Sklar, had told the New York Times he assaulted or harassed them. The same year the New York Post found that the chief executive of another provider was collecting more than $1 million a year through for-profit vendors he set up to bill his own nonprofit.
92. In October 2024 the Department of Investigation examined 51 City-funded shelter providers and reported nepotism, contracts let without bidding, and executive pay above $1 million. Its report pointed out that under Section 715 of the Not-for-Profit Corporation Law the Attorney General may “bring an action to enjoin, void or rescind” improper insider deals. The State Comptroller has audited provider after provider and found improper charges each time: $1.4 million at one provider; $2.4 million at a second, which also threw away an estimated 155,760 meals bought for the homeless; $1.3 million at a third, in Westchester County; $566,556 at a fourth; $4.5 million at a fifth. In April 2026 federal prosecutors arrested executives of a provider holding $185 million in no-bid shelter contracts, on kickback charges.
93. Against all of that, the defendant has investigated only two shelter nonprofits in eight years, and only one of those inquiries produced a conviction. In 2020 her office searched the home of the chief executive of one shelter nonprofit on suspicion of bribery, larceny and money laundering.
36Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
No charges followed. In 2021 her office obtained guilty pleas from Millennium Care and its director, Ethel Denise Perry, who had stolen more than $2 million meant for a Bronx shelter. Millennium was dissolved and its 100-room shelter handed to the shelter network the Department of Investigation had begun probing in 2019.
94. The defendant is not a stranger to these operators. The current chief executive of that shelter network, paid $836,684 in 2024, is a past donor to the defendant, who presented her with a “Power Women of the Bronx” award in 2022. The chief executive found billing his own nonprofit through for-profit vendors has given the defendant’s campaigns $4,000. A board member of one audited provider, which investigators found buying services from companies tied to its own board, has given $6,400, most of it in 2021.
Where the defendant failed: Federal prosecutors, City investigators and the State Comptroller all found the fraud. The one official with statutory power over every nonprofit in New York investigated only two shelter operators in eight years and convicted only one, and she took campaign money from people who run the system.
The record: NYC Department of Investigation report, Oct. 2024; CBS New York, Oct. 17, 2024; Wall Street Journal, July 21, 2019; New York Times, Jan. 29, 2020; New York Times, Feb. 7, 2021; New York Post, March 24, 2021; New York Post, Oct. 11, 2021; Comptroller audit (first provider); Comptroller audit (second provider); Comptroller audit (third provider); Comptroller audit (fourth provider); Comptroller audit (fifth provider); New York Post, April 5, 2026; City Limits, Oct. 18, 2021; Attorney General press release, Nov. 22, 2021; New York Times, Nov. 24, 2021; Crain’s New York Business, Sept. 18, 2024; World Liberty TV, Jan. 2022; State Board of Elections contribution records; Not-for-Profit Corporation Law Section 112; New York Post editorial, Sept. 7, 2025.
COUNT THIRTY-THREE
Dereliction in the Enrichment of Nonprofit Executives at Public Expense
95. According to the organizations’ tax filings and State payment records reviewed by the campaign, twenty-five executives 37Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
at three nonprofits funded through the defendant’s Homeowner Protection Program earned more than $350,000 each last year. All three organizations owe their grants to the defendant’s office. The first received $3.9 million; under the defendant its grants grew 419 percent. Its chief executive was paid $2.18 million. After the City’s Department of Investigation flagged that compensation, the defendant increased the organization’s grants, the chief executive’s pay more than doubled, and a state audit found $4.5 million in improper costs at the organization.
96. The second, a university, received a $1.2 million grant extension under the program less than two months after the defendant delivered its commencement address, despite never having received a prior payment under the program. Its chief executive was paid $1.36 million. The third received $1.7 million; its grants grew 203 percent.
Where the defendant failed: The defendant holds the authority, as regulator of every charity in New York, to challenge improper nonprofit compensation. The People have found no evidence that she used it against any of the three. Her office increased their grants.
The record: Comptroller audit, July 2025; CBS New York on the DOI report; State Comptroller, Open Book checkbook.
COUNT THIRTY-FOUR
Dereliction in the Face of $368 Million Spent and 916 More New Yorkers on the Street
97. According to the State Comptroller, New York City spending on services for the unsheltered rose from $102 million in Fiscal Year 2019 to nearly $368 million in Fiscal Year 2025, an increase of 262 percent. Over the same period the unsheltered population rose 26 percent, from 3,588 to 4,504. That is $81,705 per unsheltered person per year, more than the City’s median household income, spent so that more people would sleep outside. The Citizens Budget Commission placed total homeless-services spending near $3 billion a year as far back as 2018.
38Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Where the defendant failed: The nonprofits that receive that money answer to the defendant’s Charities Bureau. In eight years she has investigated only two of them, and the People have found no evidence that she has ever asked in public where the rest of the money went. The people it was meant to house are listed in Count One.
The record: State Comptroller, March 11, 2026; Comptroller report; Fox News, March 18, 2026.
COUNT THIRTY-FIVE
Dereliction in the Skimming of $51 Million From the Poorest New Yorkers
98. Since 2023, at least $51 million in food benefits has been stolen from New York SNAP recipients by criminals using card skimmers on magnetic-stripe EBT cards. Since the federal reimbursement program lapsed in December 2024, the families robbed have had no way to recover a dollar. California replaced its cards with chip-enabled cards in 2025 and cut theft by 83 percent. New York’s replacement cards are not expected to reach recipients until 2027.
Where the defendant failed: Skimming rings are organized crime. The defendant has an Organized Crime Task Force and a Bureau of Consumer Frauds and Protection. The People have found no evidence that she put either to work on the theft of groceries from the poor.
The record: New York Focus, Feb. 27, 2026; NYC Department of Investigation, Sept. 2025; City Limits.
COUNT THIRTY-SIX
Dereliction in the Stewardship of Opioid Settlement Money
99. The defendant campaigns on having secured more than $3 billion in opioid settlements for New York. The money was won in the name of the dead. How it has been spent is, in the words of an investigative report, “in many cases a mystery.” New York counties have received more than $330 million. One Catskills county spent more than $37,000 of it on Tasers. A Capital Region
39Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
county bought virtual reality headsets. A North Country county funded a community baby shower.
100. One Western New York city received nearly $6 million in settlement funds since 2023 and spent less than a third of it while more than 500 of its residents died of overdoses. What it did spend went in part to police and fire vehicles, lawnmowers for block clubs, snowblowers, speakers for a fireboat, and lights and sirens for a 2025 Ford Explorer. The State’s own Opioid Settlement Fund Advisory Board complained that the administering agency would not tell it how much money had reached providers.
Where the defendant failed: The People have found no evidence that the defendant has ever demanded an accounting of the opioid settlement funds. A treatment bed that does not exist because the money bought a snowblower is a death that could have been prevented.
The record: New York Focus, Jan. 5, 2026; Investigative Post, Feb. 17, 2026; KFF Health News, July 21, 2026.
COUNT THIRTY-SEVEN
Dereliction in the Purdue Pharma Case: Credit for a Deal Others Won
102. In 2021 the defendant signed on to a Purdue Pharma bankruptcy plan that would have given the company’s owners lifetime immunity from civil suits, though the owners themselves had never filed for bankruptcy. Eight other states and the District of Columbia refused, objected, and appealed. Their appeal forced the owners back to the table for billions more. In June 2024 the United States Supreme Court held, in Harrington v. Purdue Pharma, that the immunity the defendant had accepted was unlawful. The $7.4 billion settlement the defendant now takes a victory lap for exists because her position lost.
Where the defendant failed: In the most consequential opioid case in American history the defendant took the weaker deal. Other attorneys general did the fighting, and she claimed the credit.
40Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
The record: Harrington v. Purdue Pharma L.P., U.S. Supreme Court, June 27, 2024.
COUNT THIRTY-EIGHT
Dereliction Toward the Tenants of Public Housing
103. In March 2026 the City’s Department of Investigation found that more than 600 vacant public housing apartments in New York City were occupied by squatters between January 2022 and May 2025, while the number of empty units more than doubled, from roughly 2,800 to roughly 6,700, and 165,000 households sat on the waiting list. The same lock was used on every vacant unit in a development, and apartments listed as empty went uninspected. Trespassers used them to stash narcotics and run gang operations. Federal prosecutors charged a dozen people with running an open-air drug market out of empty apartments at the Johnson Houses. A man was found shot to death in a vacant unit at Castle Hill. In September 2026 tenants of one development were begging for help with a squatter who had taken over their hallway.
104. The warranty of habitability covers public housing tenants the same as anyone else. Housing authorities answer to the same building, fire, health and lead-paint laws as private owners.
Where the defendant failed: The defendant has used Executive Law Section 63(12) against private landlords for years. The People have found no evidence that she has ever used it on behalf of public housing tenants.
The record: New York Post, Sept. 5, 2026; Executive Law Section 63.
COUNT THIRTY NINE
Dereliction Toward the Families of Niagara County
105. A 2024 aerial environmental survey found radioactive contamination spread across parts of Niagara County. As many as 1,400 homes may be affected, the Buffalo News reported in August 2026. Families there do not know what the risk levels are or
41Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
what the State intends to do. The defendant’s office includes an Environmental Protection Bureau.
Where the defendant failed: The People have found no evidence that the defendant’s Environmental Protection Bureau has taken any action for the families of Niagara County. The State itself may be sued over the contamination, and she is the State’s lawyer.
The record: Buffalo News, Aug. 2026.
PART SIX — HOUSING, SCHOOLS, AND THE COST OF LIVING
COUNT FORTY
Dereliction in the Theft of New Yorkers’ Homes: Ray Cortez, Mohd Amin, and 517 Complaints
108. Deed theft is the theft of a house by forged or fraudulent paperwork. Its victims are mostly elderly, mostly immigrants and homeowners of color, and mostly in neighborhoods where a house bought for $20,000 is now worth millions. The defendant launched an initiative against it in 2020 and has called it a priority ever since.
109. By her own office’s count, deed theft complaints went from 149 in 2023 to 222 in 2024 to 517 in 2025. They more than tripled in two years. Records the office produced under the Freedom of Information Law show 15 complaints in 2019, her first year in office, and 106 in 2020. The office has not yet produced complete records for 2021 or 2022. On the figures it has produced, complaints have risen nearly 400 percent since she launched her initiative and more than 3,000 percent since she took office.
110. Enforcement has not kept pace. In 2022 the New York Times reported that the defendant’s office was prosecuting only three deed theft cases. Her deputies told lawmakers that year that the office was investigating “dozens” and did not have the capacity to take on many more. That is an office of more than 1,950 people. In 2023 the Legislature gave her the power to halt an eviction while a deed theft claim is investigated. As of
42Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
early 2026 her office said it had used that power only seven times.
111. Ray Cortez is a retired taxi driver who came to New York from Peru and bought a brownstone on St. Marks Place in Brooklyn in 1969 for about $20,000. In 2006, he says, a convicted felon he had met through his church tricked him into signing over the deed, with the help of a lawyer who was later disbarred, then borrowed nearly $700,000 against the house and disappeared. The house was foreclosed on and sold to a limited liability company. In January 2025, at the age of 90, Mr. Cortez was in housing court facing eviction from the home where he raised three children. His neighbors, his Assemblywoman and his Council member rallied to ask the defendant to investigate. His family told CBS News that after years of trying there had been no tangible results.
112. Mohd R. Amin, an immigrant from Bangladesh, bought a two-family house on Liberty Avenue in East New York in 2007. While he was back in Bangladesh, seriously ill and waiting years for a visa, a deed was filed with the City claiming he had sold the house for $1,000. It got his name wrong. A matching deed was filed on a second house he owned in Cypress Hills. Mr. Amin had to hire his own lawyers and sue.
113. In April 2026 a City Council member was arrested trying to stop the eviction of Carmella Charrington from her family’s Brooklyn home. The defendant’s office said it had reviewed the matter and that it was a property dispute, not deed theft. That same week the Mayor opened the City’s own Office of Deed Theft Prevention.
Where the defendant failed: The defendant made deed theft her signature housing issue in 2020. Complaints to her own office have nearly quintupled since, and more than tripled in the last two years alone. Against 517 complaints last year, the record shows only three prosecutions as of 2022 and only seven evictions paused as of this year. The City has now opened its own office to do the job.
The record: 6sqft, April 2026 (Attorney General’s complaint figures); NY1, April 24, 2026; City Limits, 2022 (three
43Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
prosecutions; capacity); Brick Underground, 2026 (seven interventions); Gothamist, June 27, 2022 (Cortez); Gothamist, Aug. 2024 (Cortez); ABC7, Jan. 15, 2025 (Cortez); CBS New York, Jan. 17, 2025 (Cortez); Commercial Observer, Aug. 2020 (Amin); Commercial Observer, May 2026; Attorney General press release, 2023. Also: Office of the Attorney General FOIL response on 2019-2021 complaint totals, on file with the campaign.
COUNT FORTY-ONE
Dereliction in the Award of the Land Trust Contract
114. According to tax filings and federal court records reviewed by the campaign, the defendant awarded the State’s Community Land Trust contract to a national housing nonprofit whose tax records reportedly showed most of its government-funded money remaining with the organization and not reaching anti-poverty groups. While under the State contract, the organization paid its executives nearly $8 million, with ten employees above $200,000 and a chief executive above $2 million, and faced allegations from the United States Department of Justice of Fair Housing Act accessibility violations dating to 2004.
Where the defendant failed: The People have found no evidence that the defendant, who regulates every charity in the State, examined the contractor before handing it the contract.
The record: State Comptroller, Open Book contracts. Also: Campaign research file, on file with the campaign.
COUNT FORTY-TWO
Dereliction Toward the Students Who Come to School to Learn
115. New York has spent more per public-school pupil than any state in America for nineteen consecutive years. On the 2024 National Assessment of Educational Progress, 26 percent of its eighth-graders were proficient in math and 31 percent in reading. On February 12, 2026, the defendant announced a settlement that places the discipline practices of the Buffalo Public Schools under an independent monitor and a “Discipline Ombudsperson” for four school years, with the aim of reducing suspensions. The president of the Buffalo Teachers Federation
44Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
answered that he hears from members almost daily about the violence they experience in their classrooms. One of the groups that cheered the settlement was a recipient of $8.2 million of the grants described in Count Twenty.
Where the defendant failed: The defendant put four years of state supervision behind the students who disrupt class. The People have found no evidence that she has offered anything to the students who come to learn or the teachers who are assaulted trying to teach them.
The record: Attorney General press release, Feb. 12, 2026; WKBW; Spectrum News, Feb. 12, 2026.
COUNT FORTY-THREE
Dereliction at the Kitchen Table: Higher Electric Bills, Costlier Homes
116. For more than two years the defendant’s office defended in federal court the All-Electric Buildings Act, which bans gas hookups in new buildings under seven stories and extends to nearly all new construction in 2029. On June 30, 2026, the Second Circuit upheld it. The State’s own grid operator has warned of reliability problems downstate within five years, and builders warn the mandate raises the cost of new housing at a time when New York has too little of it. The burden falls hardest on the families and small builders of upstate New York.
Where the defendant failed: The defendant put the full weight of her office behind a mandate that makes homes costlier to build and to heat, while so much of the work described in Parts One through Five went undone.
The record: Spectrum News, June 30, 2026.
45Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
PART SEVEN — THE OFFICE TURNED INWARD
COUNT FORTY-FOUR
Dereliction Measured in Dollars: A Budget That Nearly Doubled While Crime Rose 26 Percent
Saritha Komatireddy and the Exasperated People of the State of New York further allege that the defendant took more from them, returned less, and turned the office toward her own interests, as follows:
117. The Department of Law’s appropriation grew from approximately $263.8 million to a recommended $487.8 million during the defendant’s tenure. Reported Index crimes statewide rose 26 percent over the same years. The Medicaid Fraud Control Unit lost its federal certification. The unsheltered population of the City grew by a quarter. New Yorkers pay for the difference a second time, in what Ms. Komatireddy calls a crime tax: higher insurance premiums as car thefts climb, higher prices as stores lock up their shelves, and a billion dollars a year in lost fares. Syracuse families remain the likeliest in the State to be victims of property crime.
Where the defendant failed: The defendant took $224 million more a year from taxpayers. The People have found no bureau of her office whose output justifies it.
The record: FY2026 Executive Budget, Department of Law; Division of Criminal Justice Services statistics.
COUNT FORTY-FIVE
Dereliction by Outsourcing: $14.5 Million to Private Firms for Work the Office Exists to Do
118. According to State Comptroller contract records reviewed by the campaign, the defendant has billed New York taxpayers at least $14.5 million in outside counsel contracts for legal work her department, with nearly 700 lawyers, was created and funded to perform. State records show roughly 145 individual donors affiliated with those same outside firms contributed approximately $23,000 to the defendant’s political operations. Among the engagements, the office retained one
46Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
outside firm to contest federal subpoenas served on the office itself. Public contracts went out. Campaign contributions came in.
Where the defendant failed: The defendant commands one of the largest public law offices in the country and still sent $14.5 million of its work to private firms whose lawyers donate to her.
The record: State Comptroller, Open Book contracts; Gothamist on the outside-counsel retention; State Board of Elections contribution records.
COUNT FORTY-SIX
Dereliction in Hiring Harvey Weinstein’s Investigators: $4.4 Million to One Firm
119. According to the office’s own response to a Freedom of Information Law request, the defendant spent at least $5.4 million on outside experts, investigators and travel for a single civil case. One private investigations firm received $4.4 million of it. The office’s own headcount records show about 244 investigators on its payroll.
120. It is a firm Harvey Weinstein used against the women who accused him. As The New Yorker reported in 2017, when the model Ambra Battilana Gutierrez told police that Mr. Weinstein had groped her and then recorded him admitting it, her settlement required her to surrender her phone and other devices to the firm so the recording could be wiped. The firm also gathered photographs of the actress Rose McGowan, who has said Mr. Weinstein raped her, in which she appeared friendly with him.
Where the defendant failed: With some 244 investigators of her own, the defendant paid $4.4 million of public money to the firm Harvey Weinstein hired to discredit his accusers.
The record: Axios, Nov. 2017, summarizing The New Yorker; Firm’s corporate history. Also: Office of the Attorney General FOIL response G000545-061526 and headcount records, on file with the campaign.
47Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
COUNT FORTY-SEVEN
Dereliction in Accepting a $10 Million Appropriation for Her Own Legal Defense
121. The Fiscal Year 2026 State budget set aside $10 million for the private legal defense of state officials in federal matters. It named no one. It was widely reported to be for the defendant. It passed the Legislature on May 7 and 8, 2025, without a public hearing, and was signed on May 9, 2025. In August 2025 the State Comptroller separately approved up to $1 million in public funds for an outside law firm for the defendant.
122. New York’s Public Officers Law provides for the defense of officials in matters arising from their official duties. The matter for which this money was set aside arose from the defendant’s personal affairs, not the People’s business. Her spokesman has since said she would not draw on the fund. The People have found no evidence that she has asked that it be repealed or explained why taxpayers who cannot recover a stolen food benefit should stand behind her private lawyers.
Where the defendant failed: The State budget set aside $10 million of public money with the defendant’s personal legal troubles in mind. The People have found no evidence that she objected or asked that it be repealed.
The record: WSKG/New York Public News Network, Sept. 29, 2025; State Senate statement, May 8, 2025.
COUNT FORTY-EIGHT
Dereliction in Rewarding an Aide Fined for Misusing a City Car
123. According to Conflicts of Interest Board and campaign finance records reviewed by the campaign, an aide to the defendant used a taxpayer-funded City vehicle for the defendant’s 2018 campaign for Attorney General and was fined by the New York City Conflicts of Interest Board. Under oath she described herself as only a campaign “volunteer.” Campaign finance records show she was paid during the same period. She was then hired into the defendant’s office while, records
48Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
indicate, still receiving payments from the defendant’s former Public Advocate’s office.
Where the defendant failed: A sworn statement that the campaign’s review found contradicted by the defendant’s own campaign filings, in a proceeding about misusing public resources for the defendant’s benefit, was followed by a state job.
The record: NYC Conflicts of Interest Board enforcement orders; State Board of Elections records. Also: Campaign research file, on file with the campaign.
COUNT FORTY-NINE
Dereliction by Absence: Beverly Hills, San Francisco, New Orleans, San Juan, and Martha’s Vineyard
125. Campaign finance filings show the defendant’s campaign spent more than $13,500 at Puerto Rico hotels and restaurants between July and December 2023, and paid for lodging and a fundraiser on Martha’s Vineyard, in a year when she was not on the ballot. Since Ms. Komatireddy entered this race, the defendant’s filings show trips to Beverly Hills in December 2025 for an event with a partisan media personality, to San Francisco in February 2026 for a panel hosted by a partisan media company, and to New Orleans in April 2026 for her national party’s spring meeting.
Where the defendant failed: The events described in Parts One and Two happened in New York. The defendant was frequently somewhere else.
The record: Daily Caller, Feb. 29, 2024; State Board of Elections expenditure records.
COUNT FIFTY
Dereliction of Candor With the Public Record
126. The People have found no comprehensive report of the office’s housing work in eight years. Its largest housing program has had no performance report since 2015. A public records request for the office’s own real estate regulatory data has been delayed for months. A request for the office’s attorney
49Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
travel records since 2019 remains outstanding. The findings of the outside investigation into the defendant’s chief of staff have not been made public. The State’s Opioid Settlement Fund Advisory Board complained that it could not obtain basic data on where the money went.
Where the defendant failed: The defendant’s office exists in part to compel disclosure from others. On each matter listed here the People asked or looked, and found nothing.
The record: KFF Health News, July 21, 2026; CBS New York, Dec. 7, 2022.
COUNT FIFTY-ONE
Dereliction by Distraction: A National Platform Built on a Neglected Docket
127. Since 2025 the defendant has filed or joined dozens of lawsuits against the federal government. She has held press conferences and appeared on national television at a pace the People believe no predecessor approached. Over the same period her Medicaid unit produced nine indictments a year and her office investigated only two shelter operators. The People have found no case her Hate Crimes Unit brought over the attacks described in Part Three, and no answer from her office for the families named in Parts One and Two.
Where the defendant failed: The People do not begrudge the defendant her ambition. They begrudge paying for it.
The record: Attorney General press release archive.
COUNT FIFTY-TWO
Dereliction of Truth: A Pattern of Claims the Record Does Not Support
128. The defendant told the public her Medicaid fraud unit was “leading the nation”; federal inspectors ranked it last and traced the collapse to her own leadership’s deliberate choice. She told the public she delivered 453 affordable units; they were delivered under her predecessor. She told the public she won “$3 billion for New York”; the People have found no mention by her that private lawyers were allotted nearly $5 billion from
50Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
the same settlements or that counties spent the proceeds on Tasers and snowblowers. She takes credit for the Purdue settlement; the deal she signed was struck down. She told the public in June 2021 that bail reform was not fueling shootings; the Manhattan re-arrest figures in Count Seventeen are her answer.
Where the defendant failed: A chief law enforcement officer who cannot describe her own record accurately cannot be trusted to describe anyone else’s.
The record: HHS Inspector General, June 30, 2026; Harrington v. Purdue Pharma; New York Post, June 24, 2021.
DEMAND FOR RELIEF
WHEREFORE, Saritha Komatireddy and the Exasperated People of the State of New York demand judgment against the defendant on all fifty-five counts, and further demand:
1. That the defendant be removed from the office of Attorney General by the only lawful means available to the People, their votes, on Tuesday, November 3, 2026;
2. That the office be returned to a prosecutor who will use its powers for the purposes for which they were granted: to lock up repeat offenders, to bring dangerously mentally ill New Yorkers indoors and into treatment, and to root out the fraud that steals from the poor, the sick, and the taxpayer;
3. That an Office of Civil Commitment be opened inside the Department of Law on the first day of the next administration, staffed with law enforcement professionals and physicians;
4. That the State build residential treatment in every region, so that no county has to shelter a family in a roadside motel and no one is left to die on a sidewalk in Binghamton or outside an airport in Albany;
5. That the Charities Bureau audit and investigate every homeless shelter operator paid with public money for safety and effectiveness;
51Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
6. That the Medicaid Fraud Control Unit be rebuilt to match and exceed the standard of the smaller states that outperform it, and that every dollar of opioid settlement money be accounted for;
7. That deed theft complaints be investigated and prosecuted at the pace they arrive, so that Ray Cortez, Mohd Amin and every homeowner like them have the Attorney General on their side;
8. That the Hate Crimes Unit be put to work, and that the powers of Civil Rights Law Section 79-m be extended to the State’s synagogues;
9. That the rape-law loophole be closed;
10. That the names in this Complaint — Nolberto Jimbo-Niola, Michael Veronico, Frederick Jones, Doreen Ellis, Kenneth Luna, Philip Piuma, Dajohn Woodberry Jr., Erin Piacenti, Ross Falzone, Joseph Lynskey, Emine Yilmaz Ozsoy, Michelle Go, Debrina Kawam, Angel Lata Landi, Chang Wang, Wilma Augustin, Peter Bennedum, Leonides Baez, Michelle Woolfolk, Josh Molyneaux, Domonique Cruz-Champion and their children Ella, Romyn and Zachariah, Nicholas Ahmad, Victoria Goode, Robbie Miller, Michael Nairy, Kevin Ray, Laverne Singletary, Karen Wargo, Richard Williams, Jhon Rodriguez, Amelia Lewis, Dianne Brazell, Keaira Bennefield, Malcolm Brown, Donna Conneely, Chelsea Mora, and Virginia Alvarez — be remembered by whoever next holds the office, so that the list stops growing.
JURY DEMAND
Plaintiffs demand a trial by jury on every count. The jury is the electorate of the State of New York. It returns its verdict on Tuesday, November 3, 2026.
Dated: New York, New York, October 8, 2026
Respectfully submitted,
SARITHA KOMATIREDDY
52Counts 29-40): Fraud and the public’s money: the watchdog that did not bark
Candidate for Attorney General of the State of New York,
for herself and for the Exasperated People of the State of New York
Researcher Note: This is a working document that will be continuously updated throughout the campaign.
53Counts 29-40): Fraud and the public’s money: the watchdog that did not bark