UNITED
STATES
DISTRICT
COURT
DISTRICT
OF
CONNECTICUT
Grand
UNITED
STATES
OF
AMERICA
v.
MITCHELL
ANDERSON and
JAMES
C.
DUCKETT,
JR.
Jury
N-15-3 \
r.{
'>'l
(
sea
s
CRIMINAL
NO.
3:16-'
(_)
VIOLATIONS:
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
(IllegalMonetary
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
theday-to-day operations
of
PSMG
and
was
one
of
two
signatories
on
its
operating
and
construction
accounts
at
Santander Bank.
1
 
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
sports-
related
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
a
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
theredevelopment
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
2
 
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.
3
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