Peoni (defendant) sold counterfeit dollar bills to Regno, who then sold the counterfeit bills to Dorsey. All three individuals knew that the money was counterfeit. Dorsey attempted to use the counterfeit money in Brooklyn and was arrested. Peoni was charged with and convicted of three counts of possession of counterfeit money. One of these counts stemmed from Peoni’s actual possession of the counterfeit bills, while the other two counts stemmed from accessory liability for Regno and Dorsey’s possession of the bills. Peoni was convicted on all three counts, and appealed his conviction based on the accessory liability for Dorsey’s possession of the bills.