UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
GRAND JURY N-06-05
UNITED STATES OF AMERICA :
18 U.S.C. § 371 [Conspiracy to Defraud]
18 U.S.C. § 666 [Bribery of a Public Official]
18 U.S.C. § 1341, 1346 [Mail Fraud]
18 U.S.C. § 371 [Conspiracy to Structure]
31 U.S.C. § 5324 [Structuring]
18 U.S.C. § 1001 [False Statements]
31 U.S.C. § 5317 [Criminal Forfeiture]
The Grand Jury charges:
(Conspiracy to Defraud the Citizens of Shelton, Connecticut)
The Defendant and his Coconspirator
1. At all times relevant to this Indictment, JAMES BOTTI (“BOTTI”), the defendant
herein, was a resident of Shelton, Connecticut. BOTTI owned and operated companies that
provided construction services, developed commercial sites, and leased buildings to third parties.
As a developer, BOTTI routinely sought approval from public commissions in Shelton.
2. At all times relevant to this Indictment, an elected public official known to the Grand
Jury (hereinafter identified as “Public Official # 1") was a resident of Shelton. Public Official #
1 was BOTTI’s co-conspirator but is not named as a defendant herein. Public Official # 1 owed
a duty of loyalty and honest services to the citizens of Shelton, Connecticut in the performance of
his public duties, free from deceit, favoritism, bias, conflict of interest and self-enrichment.
Public Official # 1 was an agent of a local government, the City of Shelton, authorized to act on
behalf of the government of Shelton.
3. At all times relevant to this Indictment, the City of Shelton received federal funds. For
each of the fiscal years ending June 30 from 2002 through 2007, Shelton received more than
$10,000 under a Federal program involving a grant, contract, subsidy, loan, guarantee, insurance
or other form of Federal assistance.
4. At all times relevant to this Indictment, the citizens of Shelton were entitled to receive
honest services from their elected and appointed officials, free from de