Li\IITED STATESDiSTRILTT

COLIRT
DISTRICTOF CONNECTICUT
GrandJurv H-15-1
UNIITEDSTATESOF ANIERICA

Llriminal No. 3:16CR

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18 Lf.S.C.Section371 ( Conspir acy)

l8 U.S.C.Section2314(Interstate
Transportation of Stolen Property)
18 U.S.C.Section2 (Aiding and Abetting)
18 U.S.C.Sectron981(aX1XC)(Forfeiture)
28 U.S.C.Section2a61@)(Forfeiture)

INDICTMENT
'Ihe (irand
Jur'1.'charges:

General Allegations
At all times relevant to this Indictment:
l.

Defendant Andrew SACCO ("SACCO") resided in Durham and New

Haven. C-'onnecticut. SACCO owned and onerated N{VP Auto Sales and Service,
LLC. locateciat 23 Bernhard Road, North Haven, Connecticut.

2.

Def'endantN'IatthewHAR\VOOD ("HARWOOD") resided rn Durham,

Connecticut. HAR\A'OOD owned and operateclDogfathel NIobile. LLC, a dog

gtoomingbusiness.
3.

2, J b

' i i R i Ti C O UIf ;
?:
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\IOLATIONS:

ANDREW SACCO
ANdNTATTHEWHAR\\TOOD

A "booster"is a person who steals goodsand merchandisefrom retail

stores. Generaliy, boosterswiil resell the stolen merchandiseto a "fence" at a

fraction of the retail vaiue. The fencewill then resell the stolen property at a profit

to a third party

COUNT ONE
(Conspiracv)
4.

The allegationsin paragraphs1 through 3 of this Indictment are re-

alleged and incorporar,ed b5,-reference as though tuily set forth in this count.

5.

Beginning in approximately January 2012 and continuing until at

least December L7, 20L4, the precise dates being trnknown to the Grand Jury, in the
District of Connecticut and elsewhere, defendants SACCO and HARWOOD did
unlawfuliy, knowLngiy, and intentionally.'combine,conspire, confederate, and agree
'uvitheach other and others. both known and unknown to the Grancl Jurl', to commit
arnoff'enseagainst the Llnrted States, that is, to transport, transmit, and transfer in
intet'state or forergn commer(:ean5,'stolen goods,wares, and merchandise having a
value of $5,000 or more, knowing the same hacl been stolen, converted. and taken b5,'
fraud, in violation of Title 18, United States Code, Section 2374.
Purpose of the Conspiracy
6.

The purpose of the conspiracy was for SACCO, HARWOOD, and their

co-conspiratorsto enrich themselves by obtainrng new, in-box property they knew to

be stolen and then selling and shipping the property to customers throughout the
United States and the worlcl, and to concealthe conspiracy from others.
Nlanner and N{eans of the Ccinspirac}t
The- manner

and means b;,' which

SACCO and HARWOOD

sought to

accomplish ancl did accompiish the objects of the conspiracy included, among others,

the foliowing;
7.

It wits part of the conspiracythat SACCO and HAR\ rOOD knowingly

pnrchasedand obtainedstolenproperty'and goodsfrom inclividualsthey referredto

as ''boostet's."The boosters,inciuding G.J., A.X4.,and C.C.,and others known and
unknown to the Grand Jury, wouid and did steal the propertl, und goodsfrom retail
stores,inclucling,but not limited to, Target, Staples,and Walmart. Many of the
boosterswere individualswho were addictedto narcoticsand who used the proceeds
from the salesof stolen property to purchaseillegal drugs.
8.

It was further part of the conspirac;'that SACCO and FLARWOOD

instructed and directed boosters on what products to steal. Such items included,
but were not limited to, personal care products, electronic goods,home improvement
products, pet products, and arts and crafts products.
9.

It rvas further part of the conspiracy that SACCO and HARWOOD

wor-rld and did rent cars for boosters fbr the purpose of giving them access to
transportation to steal goodsfor SACCO and HARWOOD to reseli.

10.

It was ftrrther part of the conspirac5,'

that boosters would and did

an'ange to deiiver the stolen merchandiseto SACCO,HARWOOD, and C.H., a coconspirator not charged herein, and to get paid for the merchandise.The delivery
locations included, but n<ltwere not limited to. SACCO'shouse at 42 Augur Lane.
Durham, Connecticut; HARW'OOD's house at

290 Tuttle Road, Durham.

Connectieut;and NI\IP Ar-rtoSaies and Service,LLC, at,23 Bernhard Road, North

Haven, Connecticut.

11.

It warsfurther part of the conspiracythat SACCO and HARWOOD

woulciand did look up the retail prices of particular products on their computers
anclmobilephonesto help determinehow much to pay boostersfoi'stolengoods.
L2.

It was further part of the conspiracythat SACCO, HARWOOD, and

C.H, wouid ancl did purchase the stolen products from boosters, often ftrr
approximatelv one-third of their retail value. SACCO, FI{RWOOD, and C'H' paid
boosters in cash for the stolen products. SACCO and HARWOOD also paid bt.rosters
with prescription painkillei's and illegal narcotics.
13.

It was further part of the conspiracy that SACCO and HARWOOD

woulcl anc'l did purchase from boosters stolen products to which seculitl' devices
were still alfixecL. SACCO nnd HARWOOD woulcl and did remove the securrty
devices from stolen products befoi'ereseliing the items.
14'

It was further part of the conspirac5' that SACCO and }L{RWOOD

would and dicl list and sell online, and caused to be listed and sold online, stolen
prociucts they obtained from boosters, including, but not timited to, on the Amazon
and eBay websites.
15.

It was further part of the conspirac5''that SACCO and HARWOOD

wotrld and clicl utiiize Amazcln and eBa5r accounts opened in the names of other
i n d r v i c l u a l s ,i n c l u d i n g D . A . , \ , L R . , G , R . , L . R . , a n d C . H . , w h o s e i d e n t i t i e s a r e k n o w n

fo the Grand Jur-v,to sell the stolengoods.

16.

It was fr-rrtherpart of the conspiracythat SACCO and HARWOOD

would ancl did store, process,and packagestolen goodsfor shipment at various

locations, including SACCO's house at 42 Augur Lane, Durham, Connecticut;

FIARWOOD's house at 290 Tuttie Road, Durham, Connecticut; a commerciai space
at 2 Broadway, North Haven, Connecticut; and M\,? Auto Sales and Service. LLC.
at 23 Bernhard Road, North Haven, Connecticut.
17.

It was further part of the conspiracy that FIARWOOD would and did

give M.R. and L.R., whose identities are known to the Grand Jury, stolen goodsand
directed them to sell the products online. A-fter the stolen goodswere shipped to the
purchasers, FIARWOOD obtained a portion of the sale proceeds.
18.

It was further part of the conspiracy that SACCO and I{ARWOOD

would and did ship and transport, or caused to be shipped and transported,
packages containing stolen goods from Connecticut across state lines to customers
outside of Connecticut. Such sales involved stolen soodswith a value in excessof
$5,000over the time period of the conspiracy.
19.

It was further part of the conspiracy that IIARWOOD and C.H. would

and did personaliy deliver stolen products from Connecticut to Fall River,
Massachusetts,to E.L., whose identity is known to the Grand Jury, who purchased
the goodsto resell.
20.

It was further part of the conspiracy that IIARWOOD would and did

pay for certain expenditures of SACCO's from the proceeds of the conspiracy,
including SACCO's mortgage for the residence at 42 Augur Lane, Durham,
Connecticut,and SACCO'scar loan.

Overt Acts

2\.

In furtherrrnce of the conspiracy and to effect the objects of the

conspiracv.SAC'ClO.
HARWOOD,and their co-conspirators,
known anclunknown to
the Grand Jury. committed and causedto be committed the following overt acts,
amongothei's,in the District of connecticutand elsewhere:
a.

on or about N{ay g, 2012, HARlvooD causedto be casheda $5,000

check, bearing check number #130, drawn on a Bank of America
accountending in 8118 that belongedto A.S., whoseidentity'is known
to the Grand Jurv:

b.

From approximatel;,'2013 through approximately 2074, SACCO and

HARWOOD uti.lizeda commercialspacelocated at 2 Broadway, North
Haven, Connecticut,to storeand packagestoienproductsfor shipment;
On or about July 26, 20L3. HARWOOD rented a car for A.M. at the
Enterpri.seRent-A-Carin Wallingford, Connecticut;

cl.

On or about July 3, 20L4,FLAR\VOODgave C.C. a handwritten list of

productswith the notation "all stuff Il3 if new items put on the siclewe
discuss";
On or about July 30. 20L4, SACCO removed a security device from
purpoltedly stolenproperty that he purchasedfor 9140 cash;and
On or about August 20, 20L4, HARWOOD paid $150 cash for
purportedi.v stolen items, including fol items with securitv clevices
affixed to them.

AII in violation of Title 18. United StatersCode, Section 371.

COUNTS TWO THROUGH FOUR

(InterstateTransportationof StolenProperty)
22.

The allegationsin paragraphs 1 through 4 and 6 through 21 of this

Indrctment are re-allegedand incor:poratedby referenceas though full-v set fbrth in

thesecounts.

On or about the dates set forth for each count below, the precise dates

23.

being unknown to the Grand Jury, in the District of Connecticut and elsewhere,
defendants SACCO and IIARWOOD did unlawfully transport, transmit, and
transfer in interstate and foreign commercestolen goods,wares, and merchandise,
that is, stolen goods SACCO and HARWOOD obtained from boosters and then
resold, shipped, and delivered from

Connecticut to customers outside of

Connecticut, of the value of $5,000 or more, knowing the same to have been stolen,
converted, and taken by fraud, the aggregatetransactions involving each account or
reseller below constituting a separatecount of this Indictment:
Count

Account/Reseller
Approximate
Dates
3l22lL2 to Lll28l"l,4 Account ending in24YB in the name
D.A./ShorelineProductson Amazon
Account registered to
ch*x*197?@gmail.com in the narne C.H'
on eBay

,]

Illl72 ta 1116112

4116/12toLl/25/13 E.L. in Fall River. Massachusetts

All in violation of Title 18, United States Code, Sections 2314 and2.
FORFEITURE ALLEGATION
(Interstate Transport of stoien Property and conspiracy)
24.

Upon conviction of one or more of the counts alleged in Counts One

through Four of this Indictment, defendants SACCO and IIARWOOD shall forfeit to
the United States of America, pursuant to Title 18, United States Code, Section
981(aX1XC)and Title 28, United States Code, Section 2461k), all right, title, and

interest in any and all propert5.',real or personal, which constitutes or is derived

frrm proceeds traceable to violations of Title 18, Llnited States Code, Sections 371
and 2314, rncluding but not limited to the followins:

I'inancial Accounts:
(a)

An interest up to the amonnt of $48,639.76 in an

American Funds N{utual Funds account endinq in 0554,
held in the name of X,IatthewHarwood.

(b)

An interest up to the amount of $2,939.64in an American

Funds Nluttral Funds accountending in 2369, held in the
name of [,Iatthew Harwood.

Real Propert]':
(c)

An interest in certain real property located at 290 Tuttle

R o a d .D u r h a m . C T 0 6 4 2 2 .

(d)

An interest in certain real property' loc:rted at 42 Augur

Lane. Durham. CT 06422.

2i"t.

If any of the above-describedforfeitable property, as a result of any act

or ornission of the defendants, cannot be located upon the exercise of due diligence,
has been transferred. soid to, or deposited with a third party. has been placed
beyond the jurisdiction of the court, has been substantially diminished in value, or
has been commingled with

rrthel property which cannot be divided without

clifficulty, it is the intent of the Uni"ted States, pursuant to Title 21, United States
Code, Serction 853(p), as incorporated b5' Title

28, United

States

Code,

Sectton 2461(c), to seek forfeiture of an-v*other property of said defendants up to the

value of the forf'eit,ableproperty described above.

Al1 rn accordancewith Title 18. United States Code, Section981( a ) ( 1)as

incorporateclby Title 28, Unrted States Code, Section246I(c), and Ruie 32.2(a),
FecleralRules of Llriminai Procedure.

A TRUE BILL

lsl

F9REIERSoN

UNITED STATES OF AMERICA

DEIRDREN,I.DATY
UNITED STATESATTORNEY

DAVID T. HU
ASSISTANT UNITED STATES ATTORI'IEY

JOHN T. PIERPONTJR
ASS{STANT UNITED STATES ATTORNIEY

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