UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
Grand Jury

N-15-3

r.{(_)
'>'l

UNITED STATES OF AMERICA

CRIMINAL NO. 3:16-'

v.

( sea s

VIOLATIONS:

MITCHELL ANDERSON and

JAMES C. DUCKETT, JR.

18 U.S.C. Section 1349 (Conspiracy to

Commit Mail and Wire Fraud)
18 U.S.C. Section 1341 (Mail Fraud)

18 U.S.C. Section 1343 (Wire Fraud)

18 U.S.C. Section 1957 (Illegal

Monetary Transactions)

INDICTMENT

GENERAL ALLEGATIONS

The Defendants and Relevant Entities

1.

Defendant MITCHELL ANDERSON (hereinafter, "ANDERSON") was

the President of Premier Sports Management Group LLC (hereinafter, "PSMG"), a

limited liability company based in Hartford, Connecticut. ANDERSON oversaw the

day-to-day operations of PSMG and was one of two signatories on its operating and
construction accounts at Santander Bank.

2.

Defendant JAMES C. DUCKETT, JR. (hereinafter, "DIJCKETT"), was

the Chief Executive Offrcer of Black Diamond Consulting Group (hereinafter "Black

Diamond.") DUCKETT held himself out as an investor and developer in sportsrelated projects.
Background

3.

On or about September 18, 2O\4, ANDERSON, on behalf of PSMG,

entered into a professional services contract with the City of Hartford, Connecticut

(hereinafter, "City of Hartford") for the re-development of the Dillon Stadium and
Colt Park venues located in the Coltsville section of the city. At that time, Dillon
Stadium was a multi-use facility primarily used by student and semi-professional
teams for football and soccer activities. Adjacent to Dillon Stadium was Colt Park,
an approximately 100-acre public facility with outdoor pools, playscapes, basketball
courts, baseball and softball fields, and open fields.

4.

Under the terms of the September L8, 2014 professional services

contract, PSMG agreed to serve as the project manager for the redevelopment of

Dillon Stadium and Colt Park in three parts. First, PSMG agreed to procure
professional soccer team franchise to be based

in Dillon Stadium. PSMG

agreed

that it would secure such a team within six months of the execution of the contract,
and the parties further agreed that PSMG's failure to do so would permit the City of

Hartford to reduce the scope of the project. Second, PSMG agreed to administer the
redevelopment of Dillon Stadium, which would include overseeing the development

plans for the demolition of the existing facility, the design of a new 9,000 seat

stadium, and the construction of the new stadium. Third, PSMG agreed to
separately oversee the design and construction of a new multi-purpose athletic field

at Colt Park, which would include an artificial turf field, bleacher seating for 3,000
people and facilities for bathrooms, locker rooms and concession stands.

5.

Under the terms of the September 18, 20L4 professional services

contract, PSMG agreed

to use only approved

sub-contractors

to perform its

obligations. The contract provided that the total budget for the redevelopment
project was $12,000,000, including up to $775,000 in management fees for PSMG,

which represented \Vo of the total project budget. The contract provided that the

City of Hartford's Development Services Department would manage the agreement

on behalf of the city.

6.

In or about February of 2015, ANDERSON was introduced

to

DUCKETT as a potential majority owner for the professional soccer team franchise
to be based in Dillon Stadium. In or about March of 2015, ANDERSON introduced
DUCKETT to offrcials from the City of Hartford as the potential majority owner for.
the soccer team, which was to be known as "Hartford City FC." At this meeting and

in subsequent communications with officials from the City of Hartford, DUCKETT

represented that he and his company, Black Diamond, had the financial means not

only to fund the soccer team franchise, but also to fund the construction of Dillon
Stadium without city resources. DUCKETT also represented that he was involved

in the construction of a domed stadium at a casino in Connecticut.

7.

In or about March of 2015, ANDERSON informed employees of PSMG

that PSMG and Black Diamond were merging. In an e-mail dated July 20,

2AL5,

ANDERSON stated to the head of the City of Hartford's Development Services

Department that PSMG and Black Diamond had "merged companies." DUCKETT
was copied on this e-mail.

8.

Consistent with the September 18,20L4 professional services contract,

PSMG retained sub-contractors

to perform the preliminary design and

environmental work for the site preparation of Dillon Stadium. Typically, these
sub-contractors would submit invoices for their work directly to PSMG. PSMG
would, in turn, prepare a single, PSMG invoice to the City of Hartford reflecting the
sum of the sub-contractors'individual invoices along with PSMGs

fee.

PSMG e-mailed

its

5Vo

management

invoices, together with the supporting sub-contractor

invoice(s), to the City of Hartford, Development Services Department for payment.

On occasion, ANDERSON and DUCKETT also hand-delivered these invoices to the

Development Services Department. After the PSMG invoice was processed by the

Development Services Department,

it

would be sent to the City of Hartford's

Finance Department, and then to the City of Hartford's Treasurer's Of,fice, which
would issue a check to PSMG. The City of Hartford would then mail the check via
United States Postal Service to PSMG at its offrce on Huyshope Avenue in Hartford.

On occasion, PSMG would request to have the check picked up in person. Once
paJrment from the City of Hartford was received, PSMG was responsible for paying

its sub-contractors.

9.
began

Beginning in or about February of 2015, ANDERSON and DUCKETT

scheme

to defraud the City of Hartford and PSMG's sub-contractors.

ANDERSON and DUCKETT did this by submitting PSMG invoices to the City of

Hartford for reimbursement of amounts that were due and owing to PSMG's subcontractors together with PSMG's

5Vo

rnanagement fee, which invoices were paid by

the city to PSMG. ANDERSON and DUCKETT, however, wrongfully kept a portion

of these monies instead of paying the full amounts due to the PSMG

sub-

contractors. ANDERSON and DUCKETT also used a portion of these funds for
expenses

not related to the Dillon Stadium/ Colt Park project, such as

cash

withdrawals, pa5rments for personal credit cards, and paSrments to vendors for
unrelated projects. As a result, PSMG's sub-contractors did not receive signifrcant
funds due and owing to them for their legitimate work.

10. In addition, ANDERSON and DUCKETT submitted artificiallyinflated PSMG invoices to the City of Hartford based upon invoices from Design

Firm #1, which ANDERSON and DUCKETT represented had done work on behalf
of the Dillon Stadium/ Colt Park project. In fact, Design Firm #1., a firm

specializing

in the design of stadium

DUCKETT and Black Diamond

in Florida

domes and coverings, had done work for

in an unrelated project, but had not yet been

retained to do work for the Dillon Stadium/ Colt Park project. The invoices given by
Design Firm #1 to PSMG were intended to demonstrate what the costs would be
PSMG entered into a contract

if

with Design Firm #1 for the Dillon Stadium/ Colt

Park project. ANDERSON and DUCKETT then kept the City of Hartford funds

received for the inflated invoices for themselves and directed those funds to other

expenses

not related to the Dillon Stadium/ Colt Park project, such as

cash

withdrawals, pa;rments for personal credit cards, and payments to vendors for
unrelated projects. As a result, the City of Hartford paid hundreds of thousands of
dollars for services that were not related to the Dillon Stadium/ Colt Park project.

11.

Moreover, in response to inquiries from the City of Hartford about the

status of securing a professional soccer team franchise for the Dillon Stadium
project, and in an effort to conceal their ongoing fraud, ANDERSON and DUCKETT
continued to make material misrepresentations about PSMG's performance under

the September 18, 2014 professional services contract, including representations

that PSMG and Black Diamond were in the process of securing a soccer franchise
from the North American Soccer League. In addition, in or about October of 2015,
DUCKETT presented officials from the City of Hartford with a false and fictitious

letter from "Invest Technical Services LLC," signed by Co-conspirator #1, whose
identity is known to the Grand Jury, that provided "Invest Technical Services LLC"
and Black Diamond had secured $440 million in funding for real estate development

projects

in the United States. Attached to that letter was a document falsely

purporting to be from an international bank confirming access to the $a+O million in

funds.

COUNT ONE
(Conspiracy to Commit Mail and Wire Fraud)

12.

Paragraphs 1-11 of this Indictment are realleged and incorporated as

though set forth fully herein.

6

The Conspiracy to Defraud

13.
unknown,

From in or about February 20\5 through October 2015, the exact dates

in the District of

Connecticut and elsewhere,

ANDERSON and DUCKETT (collectively,

"the

the Defendants

Defendants")

willfully and

knowingly did combine, conspire, confederate, and agree with each other, and with
others known and unknown to the Grand Jury, to commit mail and wire fraud as
described

in this Indictment, in violation of Title

18, United States Code, Sections

1341 and 1343.

Purpose of the Conspiracy

14.

The purpose of the conspiracy was for the Defendants, and others

known and unknown to the Grand Jury, to enrich themselves by defrauding the
City of Hartford and sub-contractors of PSMG, and to obtain money from the City of

Hartford and good and valuable services from the sub-contractors of PSMG by
means of materially false and fraudulent pretenses, representations, and promises.

Manner and Means

The manner and means by which the Defendants and their co-conspirators
sought to accomplish and did accomplish the objects and purposes of the conspiracy
included the following:

15. It was part of the scheme that the Defendants and their coconspirators submitted PSMG invoices to the City of Hartford, both by e-mail and in
person, representing that the invoices were for payments to be made to PSMG sub-

contractors, including Architecture Firm #1 and Environmental Firm #1, who had

-I

performed good and valuable services in connection with the Dillon Stadium/ Colt

Park project. After receiving pa5rment for these invoices from the City of Hartford,
which checks were sent by U.S. mail, the Defendants did not provide full payment

to the PSMG sub-contractors but instead deposited and moved the funds among
PSMG's various bank accounts. The Defendants and

their co-conspirators then

used the funds to benefit themselves, PSMG, Black Diamond and others, and to pay
expenses that were not related to the Dillon Stadiurn/ Colt Park project.

16. It was further part of the scheme that the Defendants and their coconspirators submitted PSMG invoices to the City of Hartford, both by e-mail and in
person, representing that the invoices were for payments to be made to PSMG sub-

contractors, including Design Firm #1, who had not performed the represented good

and valuable services in connection with the Dillon Stadium/ Colt Park project as
PSMG represented. After receiving payment for these invoices from the City of

Hartford, which checks were sent by U.S. mail, the Defendants used the funds to
benefit themselves, PSMG, Black Diamond and others, and to pay expenses that
were not related to the Dillon Stadium/ Colt Park project.

L7. It was further part of the scheme that the Defendants

and their co-

conspirators also made and caused to be made various false representations to the

City of Hartford, including that:

(a)

Invoices submitted by PSMG to the City of Hartford were for goods and

services actually rendered by approved sub-contractors for work done for the

Dillon Stadium/ Colt Park project; and

(b)

Payments received by PSMG foom the City of Hartford were used to

pay for goods and services provided by PSMG sub-contractors for work done
for the Dillon Stadium/ Colt Park project.

18. It was further part of the scheme that, in an effort to deceive PSMG
sub-contractors who inquired about the pa;rment of their invoices, the Defendants
and their co-conspirators would and did make false and misleading representations

by telephone and by e-mail-some of which traveled interstate-to the

contractors, including that the payments had to be held

in

"escrow" and

sub-

that the

payments had already been sent when in fact they had not.

19. It was further part of the scheme and in an effort to deceive the City of
Hartford into believing that PSMG was properly administrating its obligations
under the September 18, 20\4 professional services contract that the Defendants
and their co-conspirators would and did make false and misleading representations

by telephone and by e-mail, some of which traveled interstate, including that the
payments to PSMG sub-contractors had already been sent when in fact they had
not.

All in violation

of

Title 18, United States Code, Section 1349.

COUNTS TWO THROUGH FIVE
(Mail Fraud)

20.

Paragraphs 1-19 of this Indictment are realleged and incorporated as

though set forth fully herein.

21.

On or about the dates listed below, in the District of Connecticut and

elsewhere, for the purpose of executing and attempting to execute the above-

described scheme and artifice

to

defraud,

the Defendants identified below

knowingly caused to be delivered, and aided and abetted others to cause to be

delivered, through the United States mail, the foliowing checks, each constituting a
separate count of this Indictment:

Count

Date

Description of Mailing

Defendant(s)

Check #00600497 in the amount of

$32L,404.31 from the City of Hartford,
550 Main Street, to PSMG,I4O
Huyshope Avenue, Hartford, Connecticut
Check #00602464 in the amount of
$Sg,Sat.08 from the City of Hartford, 550
Main Street, to PSMG, 140 Huyshope
Avenue, Hartford, Connecticut
Check #00605196 in the amount of
$151,200.00 from the City of Hartford,
550 Main Street, to PSMG,140
Huvshope Avenue, Hartford, Connecticut
Check #0061123 in the amount of
$Zl7 J0A.00 from the City of Hartford,
550 Main Street, to PSMG,l40
Huyshope Avenue, Hartford. Connecticut

ANDERSON

(on or about)
2

3/9/2075

417120t5

5/t8120L5

8/24/2AL5

All in violation of Title

18, United States Code, Sections

ANDERSON

ANDERSON

ANDERSON

L34l and2.

COUNTS SIX THROUGH TEN

(Wire Fraud)

22.

Paragraphs 1-19 of this Indictment are realleged and incorporated as

though set forth fully herein.

23.

On or about the dates listed below, in the District of Connecticut and

elsewhere, for the purpose of executing the above-described scheme and artifice to

defraud, the Defendants identifred below knowingiy caused to be transmitted, and

aided and abetted others to cause to be transmitted, in interstate commerce by

10

means of wire communications certain signs, signals, and sounds, each constituting
a separate count of this Indictment, as follows:

Count

Date
(on or about)

Description of Interstate Wire

Defendant

2lLU20t5

E-mail from ANDERSON using e-mail

address manderson@psmg.email to an email address at the City of Hartford,
attaching PSMG Invoice #105 in the amount

ANDERSON

of $321,404.31
4

4/6/20t5

7116120t5

8/1812075

10

9/18/20t5

E-mail from ANDERSON using e-mail

address manderson@psmg.email to an email address at the City of Hartford,
attaching PSMG Invoice #105 in the amount
of $151.200.00
E-mail from Design Firm #1 to DUCKETT
at diamondgroup jdl@gmail.com and
ANDERSON at manderson@psmg.email,
attaching Design Firm #1 invoice number
2014-169-02 in the amount of $450,000 for
work proposed to be done on behalf of
PSMG, which invoice was falsely submitted
by PSMG on711612015 to the City of
Hartford as a paid invoice for services
actually rendered
E-mail from Design Firm #L to DUCKETT
at diamondgroup jdl@gmail.com and
ANDERSON at manderson@psmg.email,
attaching Design Firm #l- invoice number
2014-169-03 in the amount of $250,000 for
work proposed to be done on behalf of
PSMG, which invoice was falsely submitted
by PSMG on8118/2015 to the City of
Hartford as a paid invoice for serwices
actually rendered
E-mail from Design Firm #l to DUCKETT
at diamondgroupjdl@gmail.com, attaching
Design Finn #l- invoice number 2O14-t69-O4
in the amount of $300,000 for work proposed
to be done on behalf of PSMG, which invoice
was falsely submitted by PSMG to the City
of Hartford on9/18/15 as a paid invoice for
serwices actually rendered
11

ANDERSON

ANDERSON
DUCKETT

ANDERSON
DUCKETT

DUCKETT

All in violation of Title 18, United States Code, Sections 1343 and 2.
COUNTS ELEVEN THROUGH TWENTY-SX
(Illegal Monetary Transactions)

24.

Paragraphs l--23 of this Indictment are realleged and incorporated as

though set forth fully herein.

25.

On or about the dates set forth below, in the District of Connecticut

and elsewhere, the Defendants identified below did knowingly engage and attempt

to engage in the following monetary transactions by, through and to a financial

institution, affecting interstate and foreign commerce, in criminally derived

property of a value greater than $10,000, that is, the deposit, withdrawal, and

transfer of United States currency, such property having been derived from
specified unlawful activity, that is, mail fraud and wire fraud
18, United State Code, Sections l34L and 1343, as alleged

in violation of Title

in Counts Two through

Ten of this Indictment:

Count

Date

MonetarJr Transaction

Defendant(s)

Check # 1005 from PSMG construction

account (ending in 3713) at Santander
Bank in the amount of $200,000 to
Attorney D.F., an attorney working for

ANDERSON
DUCKETT

(on or about)
11

t2

3130/2015

4/6120L5

DUCKETT
Check #1035 from PSMG operating
account (ending in 3063) at Santander
Bank in the amount of $20,000 to an
individual with initials A.C. whose
identity is known to the Grand Jury

\2

ANDERSON

Count

Date
(on or about)

Monetary Transaction

Defendant(s)

13

5179/2A15

Wire from PSMG operating account

(3063) in the amount of $50,000 to a
purported investment company
associated with DUCKETT beginning

ANDERSON
DUCKETT

L4

512012015

15

815120L5

16

814120t5

17

815/20L5

18

81512015

19

811r/20t5

20

8lt3l20t5

27

8120/20t5

22

8/26/20L5

with initial "M"

Transfer from PSMG operating account
(3063) at Santander Bank in the
amount of $40,000 to Black Diamond
account (ending in 9025) at Santander
Bank
Check #1042 from PSMG construction
account (3713) in the amount of $16,770
to an entity controlled by ANDERSON
with the initials PS, LLC
Transfer from PSMG operating account
(3063) at Santander Bank in the
amount of $120,000 to Black Diamond
account (9025) at Santander Bank
Wire from Black Diamond account
(9025) at Santander Bank in the
amount of $40,000 to an individual with
initials D.E. whose identity is known to
the Grand Jury
Check #103 from Black Diamond
account (9025) in the amount of
$tZ,ZSZ.e4 to Capital One for an
account associated with DUCKETT
Wire from PSMG construction account
(3713) in the amount of $58,000 to an
entity with initials M.A.S.L. whose
identitv is known to the Grand Jury
Check #1153 from PSMG construction
account (3713) in the amount of $20,000
to "cash"
Check #1152 from PSMG construction
account (3713) in the amount of $50,000
to Desisn Firm #1
Transfer from PSMG operating account
(3063) at Santander Bank in the
amount of $15,000 to Black Diamond
account (9025) at Santander Bank
13

ANDERSON
DUCKETT

ANDERSON

ANDERSON
DUCKETT

DUCKETT

DUCKETT

ANDERSON

ANDERSON

ANDERSON
DUCKETT
ANDERSON
DUCKETT

Count

Date

Monetarlr Transaction

Defendant(s)

Transfer from PSMG operating account

(3063) at Santander Bank in the
amount of $105,000 to Black Diamond
account (9025) at Santander Bank
Check #686775 from Black Diamond
account (9025) at Santander Bank in
the amount of $25,000 to an entity with
initials K.R.L. whose identity is known
to the Grand Jurv
Check # 1005 from PSMG operating
account (3063) at Santander Bank in
the amount of $g0,gOO to an entity with
initials H.G.A. whose identity is known
to the Grand Jury
Wire from PSMG operating account
(3063) at Santander Bank in the
amount of $12,000 to an individual with
initials D.E. whose identity is known to
the Grand Jurv

ANDERSON
DUCKETT

(on or about)
23

9/2/2A$

24

9l2l2A$

25

t0/u20t5

26

L01512015

L4

DUCKETT

ANDERSON

ANDERSON

All in violation

of

Title

18, United States Code, Section 1957.

A TRUE BILL

P
FOREPERSON

UNITED STATES OF AMERICA

/,
UNITED STATES ATTORNEY

W'
ASSISTANT

STATES ATTORNEY

BITO
DOUGIAS P.
ASSISTANT UNITED STATES ATTORNEY

15