STATE OF NEW YORK COUNTY COURT COUNTY OF MONROE, ‘THE PEOPLE OF THE STATE OF NEW YORK ERICA LYNN BELL AND MICHAEL P. STAGLES ‘THE GRAND JURY OF THE COUNTY OF MONROE, by this indictment, accuses the| defendant, ERICA LYNN BELL, of the crime of Murder in the Second Degree, in violation of] Section 125.25, Subdivision 4 of the Penal Law of the State of New York, committed as follows: ‘The defendant, ERICA LYNN BELL, on or about and between November 9, 2016 and| November 12, 2016, in the County of Monroe, State of New York, under circumstances evineing a depraved indifference to human life, and being eighteen years old or more, recklessly engaged in| conduct which created a grave risk of serious physical injury or death to Brook Stagles, a person less| than eleven years old and thereby caused her death. SECOND COUNT: AND THE GRAND JURY OF THE COUNTY OF MONROE, by this indictment, further] accuses the defendant, ERICA LYNN BELL, of the crime of Manslaughter in the First Degree, in} violation of Section 125.20, Subdivision 4 of the Penal Law of the State of New York, committed | as follows: ‘The defendant, ERICA LYNN BELL, on or about and between November 9, 2016 and| ‘November 12, 2016, in the County of Monroe, State of New York, being eighteen years old or moreand with the intent to cause physical injury to Brook Stagles, a person less than eleven years old recklessly engaged in conduct which created a grave risk of serious physical injury to Brook Stagles and thereby caused her death. THIRD COUNT: AND THE GRAND JURY OF THE COUNTY OF MONROE, by this indictment, further} accuses the defendant, MICHAEL P, STAGLES, of the crime of Criminally Negligent Homicide, in violation of Section 125.10 of the Penal Law of the State of New York, committed as follows: ‘The defendant, MICHAEL P. STAGLES, on or about and between November 9, 2016 and ‘November 13, 2016, in the County of Monroe, State of New York, with criminal negligence, caused] the death of Brook Stagles. SANDRA DOORLEY DISTRICT ATTORNEY OF MONROE COUNTY