UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
FILED
JAN 23 P 01
GRAND JURY B-13-1
UNITED STATES OF AMERICA
US
CRIM. NO. 3:14CR esruo i1!W\lJT (i'
v.
ROBBIE ROSSI
The Grand Jury charges:
0: J4cr-oJ I
18 U.S.C. 1341 (Mail Fraud)
18 U.S.C. 2 (Aiding and Abetting)
INDICTMENT
COUNTS ONE AND TWO
Mail Fraud
18 U.S.C. 1341
1. Beginning on or about August 18, 2011 and continuing until on or about April 14,
2013, the exact dates being unknown to the Grand Jury, in the District of Connecticut and
elsewhere, the defendant, ROBBIE ROSSI, knowingly, willfully, and with the intent to defraud,
devised and intended to devise a scheme and artifice to defraud the Federal Emergency
Management Agency (FEMA), an agency of the United States of America, and to obtain money
and property from FEMA by means of materially false and fraudulent pretenses, representations,
and promises, in relation to and involving a benefit authorized, transported, transmitted,
transferred, disbursed, and paid in connection with a presidentially declared major disaster or
emergency (as those terms are defined in section 102 of the Robert T. Stafford Disaster Relief
and Emergency Assistance Act (42 U.S.C. 5122)), as set forth below.
Case 3:14-cr-00011-RNC Document 1 Filed 01/23/14 Page 1 of 4
Introduction: The Massachusetts Disaster Relief Declaration
2. On or about June 1,2011, severe weather, including a tornado outbreak, occurred in
central Massachusetts. After the storm, a Presidential Declaration of a major disaster was made
for certain areas of Massachusetts, including the cities of Springfield and West Springfield. This
Declaration authorized funds to be administered for citizens who had filed for federal disaster
assistance and met the criteria.
3. FEMA was assigned funding for this disaster under Massachusetts Severe Storms and
Tornadoes, Disaster Relief 1994 (FEMA-DR-1994) declared on or about June 15,2011. As a
result, FEMA supplied assistance to the affected residents of West Springfield and the
surrounding areas.
The Scheme and Artifice to Defraud
4. It was part of the scheme and artifice to defraud that on or about August 19,2011,
ROSSI applied for FEMA disaster assistance for damages he claimed he suffered as a result of
the June 1,2011 storm by completing a FEMA Application and a Declaration and Release Form.
5. It was further part of the scheme and artifice to defraud that ROSSI told FEMA
officials that at the time of June 1,2011 storm, ROSSI was renting a dwelling located at,71 New
Bridge Street, West Springfield, Massachusetts and that he could no longer reside in the dwelling
due to the damage inflicted by the tornado. On his application, ROSSI stated that the occupants
of the primary residence at 71 New Bridge Street were ROSSI and an individual named "Richard
Letguard," whom ROSSI identified as a "FriendlRelative."
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Case 3:14-cr-00011-RNC Document 1 Filed 01/23/14 Page 2 of 4
6. As ROSSI well and truly knew, he did not reside at 71 New Bridge Street during the
June 1,2011 storm. In fact, 71 New Bridge Street is not a valid or deliverable postal address in
West Springfield.
7. Although FEMA identified a damaged residence located at 75 New Bridge Street in
West Springfield, ROSSI never resided at that address, nor did any individual named Richard
Letguard. Neither the actual landlord nor the actual tenant of 75 New Bridge Street filed any
claim with FEMA arising from the June 1,2011 storm.
8. It was further part of the scheme and artifice to defraud that ROSSI provided FEMA
with false documentation of rental payments that he purported to have paid in the months
following the June 1,2011 storm in order to obtain rental assistance benefits from FEMA.
9. As a result of the materially false and fraudulent pretenses, representations, and
promises ROSSI made to FEMA, FEMA paid ROSSI over $12,000 in disaster relief benefits to
which ROSSI was not entitled.
The Execution of the Scheme And Artifice to Defraud
10. On or about the dates listed below, in the District of Connecticut and elsewhere,
having devised and intended to devise a scheme and artifice to defraud FEMA and to obtain
money and property from FEMA by means of materially false and fraudulent pretenses,
representations, and promises as set forth above, for the purpose of executing or attempting to
execute the scheme and artifice to defraud and deprive, ROSSI knowingly took and received
from an authorized depository for mail the following matters or things, and knowingly caused to
be delivered by mail at the place at which it was directed to be delivered by the person to whom
it was addressed, the following matters:
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Case 3:14-cr-00011-RNC Document 1 Filed 01/23/14 Page 3 of 4
Count Date (on or about) Description of matter or thing mailed
1 March 6, 2012
United States Treasury Check No. 4030007002605
in the amount of$1,398.00
2 March 6, 2012
United States Treasury Check No. 4030007002606
in the amount of $699.00
A TRUE BILL.
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All in violation of Title 18, United States Code, Sections 1341 and 2.
UNITED STATES OF AMERICA

Nt DALY L
UNITED STATES ATTORNEY
D ID 1. SHELDON
ASSISTANT UNITED STATES ATTORNEY
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