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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
GRAND JURY B-08-01
UNITED STATES OF AMERICA :
PETER C. BOTTI
18 U.S.C. § 371 [Conspiracy]
31 U.S.C. § 5324 [Structuring]
31 U.S.C. § 5317 [Criminal Forfeiture]
The Grand Jury charges:
(Conspiracy to Structure)
The Defendant and his Coconspirator
1. At all times relevant to this Indictment: (a ) PETER C. BOTTI (“BOTTI”), the
defendant herein, was a resident of Shelton, Connecticut; and (b) BOTTI’s coconspirator
(“conspirator”) was another resident of Shelton, Connecticut who shared office space with
Botti’s and the Conspirator’s Bank Accounts
2. At all times relevant to this Indictment, BOTTI maintained a checking account at
Naugatuck Valley Savings and Loan (“NVSL”) at 504 Bridgeport Avenue in Shelton,
Connecticut. On or about November 2, 2006, BOTTI opened another checking account at
Webster Bank (“Webster”) at 375 Bridgeport Avenue in Shelton, Connecticut.
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3. At all time relevant to this Indictment, the conspirator maintained a corporate checking
account at NVSL at 504 Bridgeport Avenue in Shelton, Connecticut and a personal bank account
at Sikorsky Federal Credit Union (“Sikorsky”) at 1000 Oronoque Lane, Stratford, Connecticut.
Conspirator’s family member maintained a Discover credit card account.
Regulations Concerning Cash Transactions
4. At all times relevant to this Indictment, Title 31, United States Code, Section 5313(a),
and the regulations promulgated by the Secretary of the Treasury, required domestic financial
institutions, such as NVSL, Webster, Sikorsky and Discover, to file a report of cash transactions
in excess of $10,000. These reports were known as Currency Transaction Reports (“CTRs”).
These reports were provided to the Internal Revenue Service of the United States and were
available to federal law enforcement authorities.
The Conspiracy to Structure Cash Transactions
5. From in or about June 2006 until in or about the date of this