People v. Brown

Judgment, Supreme Court, New York County (Michael R. Sonberg, J. at suppression hearing and self-representation col loquy; Bruce Allen, J. at plea and sentencing), rendered July 19, 2012, convicting defendant of eight counts of robbery in the first degree, and sentencing him, as a persistent violent felony offender, to concurrent terms of 20 years to life, unanimously affirmed.

When defendant indicated, during the allocution on one of the eight counts of first-degree robbery to which he pleaded guilty, that he “simulated” a firearm, he did not negate any element of the crime or cast any doubt…