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UI-IITEDSTATS$DISTRICTCOTJRT

DISTRICTOF'CONNECTICUT
GrandJurv N-15-3

cRiMINALNcl'3:16cRIZS i.fl1PS

UNITED STATI,]SOF :\N{ERICA


v.

VIOI,ATIO]TIS:
18 U.S.C.Section371 (Conspirac))
18 U.S.C.Section2314(Interstate
Transport,of StolenProperty)
18 U.S.C.Section2 (Airlineand Abetting)
(Forfeiture)
18 U.S.C.Sectionf)81(aX1XC)
(Forfeiture)
28 U.S.C.Section2a61(c)

GOORGEJ. CONNBLL'T,JR.,
PA UL WILLI;\M NIUZ\-KA,
and WILffi$,X{JIBIDELL
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The Grand Jury charges:


General Allegations
At all times relcvant to this Inclict,mcnt:
1.

Defendant George J. CONNELLY, Jr, ("CONNELI,Y') resided in New

Haven, Connecticut. CONI.{ELLY owned and operated a businoss known as Acc


Amusements Ll,C ("Ace" or "Ace Amusements"), located at 42-44Ifimberly Avenue,
New Haven, Connecticur;.
2.

Defcndzrnt Paul \Yilliam

$lL.lZYK-,L("MUZYIL\")

resided in North

Haven, Connecticut. I\'IUZYILAworkcd Tvith CIONNELLY at :\cc Amusements.


3.

Defcnditnt lViiiiam

Connect:.cut.

RIJIDI,II,L ('REIDELL")

r<rsidcd in

Branford,

,1.

A "llooster'' i.s a person who steals goods and merchandise from retail

storcs. Generally, boostersseil the stolen merchandiseto a "fence" al a frilction of


the re tarl value.

rl{'tlro
Boost,ersare generally o1:ictitladclicts thilt use the J:roceerds

salc tg purchase iilegal drugs. Boosters c*n work either individuall-v or in groupri.
In{ividgals with the initials S.A. and D.P., who arc known to the Grnnd Jury and arc
not charged herein, were boosters.
5.

A "fence" isian organization or individual that receivesstolen goodsand

'Ihe fencegenerallyresellsthe stolen goodsand


mer.chandiscto resell it for profit.
merchandise to third parties.
CONNELLY and MUZII(A.

Ace Arnusementswas operated as a fcncc b1'

Individuals with initials L.W. and J.R.,rvhoare known

to the Grand Jury and are not chargedherein,are third partieswho purchasedstolen
gocldsfi'omAce Amusenrentsand, in turn, resoldthe goodsfor a profit.
6.

Ace Amusements was an entity registered with the State of Connocticut

in ol nround ,Iuiy 2007, but had been doing busine.ssas a secondhand dealer befrrre
that dal;e. It is liceni;ed bv the Citv of New Haven to conduct.husincss as u
secondhzrnddealer. Under Connecticut,law, a secondhand dealer is "primarill'
engageclin t,hc business of purchasing pcrsonal property of any t!'pe from a porsol]
who is not a wholesaler, for the purpose of reselling or cxchanging such property, ilncl
has physical possessionof such property," Conn. Gen. Stat. Section 21-3$a(3).
7.

As a licensed secondhand clealor, Ace Amusements wtrs subiect to

Conr,ect.icutstatutes t,hat require secr:ndhand dealers not to "takc, rccciv<:0r

purchase tangible personal propertl,' rvithout receiving pr:oofof thc identity of the
pcrson serllingthe property if such pcrson is not a wholesalcr. Such identification
shall inciude a photograph, an adelress,if available on ther identification, and an
identifuing number, including. bul not limited tcl, date r:l'birth."

Conn. Gen. Stat.

Section2l-47e(a).

Additionall.y,Connecticutlarv requires in part th;it "eachsecondhancl

ctealurshail maintain a record-keeping systern deemed trppropriate by the licensing


authority which shail be entered in English, at the time the secondhand dealer
purchases any article of personal property, a description of such article and the
name, the residence address, the proof of identity as requirecl by this section and a
general description of the person from lvhom, and Lhe clate anci hour when, such
property rvas purchased[.]" Conn. Gen. Stat. Section 21-47e(b). Connecticut law
also prohibits secondhanddealers from purchasing goodswith crish and flom cashing
any checks written

by' the secondhand dealership.

Clonn. Gen. Stat. Section

21-47e(e)(1)-(2).
9.

The New llavcn Policc Department ("NHPD") is responsible for the

monitoring, registration, and oversight of secondhanridealcrs within the city. The


police department has ,:ho$en an internet-baseci reconl-kccping s1'stem known as
LeaelsOnline to compiy with the state larvs governing sccondhand dealers. NHPI)
pelrsonnclmaintain contact with sccondhand dealers tr: ensure thart these regulations
are adhered to by the dealers.

cQgNr oNs.
(Ccnspiracy to Transport Stolen Property)
Thdsu$piri$y
10.

The allegations in paragraphs I through I of this Indictment. are

re-alleged and incorporated by reference as though sct out in full in this count.
11.

From approximately July 2007 through on or around January 25, 2016,

the precise dates being unknown to the Grancl Jury, in the District of Connecticut
and elsewhere, the defendants, CONNIILLY,

N'IIJZIXA, and REIDELL,

did

unlawfully, knowingly. ;and intentionally combino, conspire, confederate, and agroa


with ench other antl others both known and unknown to the Grand Jury, to cornmit
nn offcnse against the Linited States, that is, to transport, transmit, and transfer in
interstate or foreign corirmerceany stolen goods, wares, and merchandise having a
valne of $5,000 or more, knowing the same had been stolen, converted, and taken by
fraud, in violation of Title 18, United States Code, Section 2314.
Purpose of the Cr:nspir*rcy
12.

The purpose of the conspirac.v-was for CONNELLY,

il'IUZYM,

REIDOLL, an{i their co-conspiratorsto enric}r thernselvesby obtaining nelv, in-box


property they knew to be stolen and selling thcrn online to customers :rll oyer the
country ancl the world, and to conceal the conspiracy from others.
gf the Conspiracv
ltlanner arld lV.Ie.flns
The manner and means by which coNNaLLY,

MUZYI(A, and REIDELL

sor"rghtto accomplish a.nd did accomplish thc objects of the conspiracy inch.rclcci,

among others, thc follow'ing:


13.

It was pirrt of the conspiracythat CONNELLY orvned ancl-along with

l.lUZYlld-r:peraterl

Acr: ;\musements. CONNELLY and N{UZ}IL{ were responsihle

for the manngemttnt anciiovcrsight of Ace Amusements.


14.

It was furt"her a part of the conspiracy that Ace Amusements appeared

outwardly to bc a licen*ed secondhandstore but was, in truth and in fact, a front for a
fencing operation organized and run by CONNELLY and MUZYKA.
15.

It was further part of the conspiracy that CONNELLY and MIJZ\T(A

would ancl did obtain stolen property from boosters and then resold it, at, Ace
Amusemcnts, online, and to other resellers, inclucling REIDELI,, J.R. and L.W.
Purchases from Boosters
16.

It was further part of the conspiracy that CONNELLY and N,II-]ZYKA

knowingly pnrchasetl arrd obtained stolen property and goods from third parties,
such as S.A. and D.P., whom CONNELLY and MUZYI(A, referred to as Lrciosters.
CONNBLLY

also refcr:r"eclto boosters as junkies.

The boclsters had stolen or

shoplifted the new, in-box goodsfrom retail stores, :.ncludingbut not limited ro Home
Depot, Walmart, Target, anrl Lowe's.
17.

It wns ftrlthel part of the conspiracy that CONNALLY ancl IIUZYK{

woulcl and did direct. boosters, in sum and substAnce,to rcmove original stofe price
tatgs and security deviccs frorn stolen property that the boosters rvanted to sell to
COIINELLY anci S'{UZYIL\ ett Ace Amusements.

COI-INELLY and I\IUZYILA,also

removedoriginal storep.ricetags themselves,inciuding by peelingthe tags off and by


using a razar blade.
18.

It was furtlher part of the conspiracy that CONNELLY and MUZIT(A

would and did purchasethe stolenproductsfrom boostersat approximatelyone-third


of their retail value. (IONNELLY and MUZYKA paid cash for these products.
OccasionallyCONNELL,Ywould cause money to be advanced.to boosterswith the
anticipation that they would bring stolen products to repay such advances.
CONNELLY and MUZYKA tracked the amount of money CONNELLY advancedto
boosters.
19.

It was further part of the conspiracythat the types of stolen products

that CONNELLY and MUZYKA purchased from the boosters and then resold
included, but were not limited to, razors, power drills, tools, electric-toothbrush
heads, vacuum clean,ers, pet

products, and over-the-counter medication.

CONNELLY and MUZYKA purchasedstolen gift cardsto reseli as well.


Resal,eto Third Parties and Online
20.

It was further part of the conspirzrcythat, once purchasedfrom the

boosters,CONNELLY and MUZYKA would and did sell someof the stolenproducts
at Ace Amusements,ofte,nto repeat customers,including REIDELL, J.R., L.W., and
others. MUZYKA would and did set aside stolen goodsfor repeat purchasers,such
as REIDELL, at Ace Amusements. CONNELLY and MLIZYKA resoldthe products
to REIDELL and others ratapproximatelyhalf of their retail value.
6

2f .

It was furt,herpart of the conspiracythat REIDELL, J.R., L.\\'.. and

othcrs purchasedgoodsfrom Ace Anrusenrentsknowing at the time that the rtcrns


they' purchnsedwele stolen. RnlnAi,L referlecl to the boostersfrom whom
CONNEI,L,Y and MUZ,II(A bought stolen proclucts as junkies and shopliftcrs.
REIDELL would also rr:moveoriginal store labels from stolen productspurchasccl
from CONNELLY and I\{UZYKA at Ace Amusementsby using lighter fluid.
22.

It was further part of the conspiracythat trIUZYKA would and did rcscll

through the Internet some of the stolcn goodsCONNBLLY and iIIUZI-I(A obtainetl
from boosters. l\{Uzlli{

sold the stolen products on eBay and maintained the

proceedsof his online sa:Iesat an accountwith PayPal. I'IUZ\T{A's eBay u.qername}


was pck-sales. He resold the stolen goodsat approximatelyseventy-fivepercentof
their retail value.
23.

It was furthet part of the conspiracy that REIDELL, as well as other

repeat customers, inclucilingJ.R., L.W., and others known and unknown to the Grr,rnd
Jury, rcsold via the Internet the stolen products that they had purchased from
CONNELI,Y and I,IUZYK{.

REIDALL primarily sold the stolen products on eBnv

and rnnintnincd the trlroceedsof his online sales at accounts with


REIDELL's eBay userrlame is Rosemaryl060.

PayPnl,

Hc resoid the stolen goocls i:rt

approximately seventy-{ivc percent o{'thcir rctail value. The items that RLIIDELL
resokl onlineron eBay were purchased cxclusively at Ace Amusements.

24.

It was furt.her part of thc conspiracythat coNNELLy and MIJZyKA

sold stolcnproductst,oIIBIDBLL and othcrs knowingthat thcy rcsrildthe proclucts


oniine.
25.

It was further pilrf of the conspiracyt,hatthc protiuctssokl online by

I,ILIZYKA.,REIDELL, J.R., L.W., and others were shippedfi'om Connecticutacross


state lines to purchasersoutside of Connecticut*rnd the Unitecl Skitcs. Such sales
involved stolen goodsvrith vaiue in excessof ${i,000ovor the time period of the
conspiracy,both in total. as well es aggregatedfor cach of thc re -sellers--N{UZYI(A.,
REIDELL, and J.R.
Ace Amu,sementsas a Front
26.

It was furt.her a part of the conspirircy that Ace ;\musements held a

secondhandlicense tcl resell secondhandgoods to help mnintain an apperiranceof


legitimacy, when in truth and in fact, as alleged above, CO|;NBLLY and NIUZYKA,
purchascd zrnclresold stolen property at Ace Amusemcnts.

27,

It was further part r:f the conspiracythat Acc .,\musementswas a

cash-onlybusiness. Notwithstnnding Connecticutstate law goverrning


secondhand
dealcrs,COI{NELLY ancli\'IUZYK{ woukl and cliclpay boostersin cashfor thc stolen
property and sold the productsat Ace Amusements for ci.rshto dist{uiseand obsctrre
the sourcoand destinationof thc stolenproducts.
28.

It was further parrt of the conspiracy that L'ONNI|LLY and [,ILIZY]L\

took steps to conceal the conspiracy and defent the efficrlcy of the Now Haven Police
Dcprtrtment to regulate Ace Amusemonls as a sccondhanrlstor:c. N{orespccifically,

CONi{ELLY and M{"JZYIL{ woulcl and did rnake materrialiy firlsc entries into Leads
Online and also knowingly failed to make entrics into LeaclsOnlineras required by
law to concealthe true nature of Ace Amusemen"ts.
29.

It rvas further pnrt of the conspiracy that CONNELLY and MUZYILA,

hacl boosters endorse clhecks purportedly rnacle out frtxr r\ce Amuscments to the
boosters as supposedpayment for thc products the boosterssolclto Ace Arnusements
when, in truth and in fact, CONNBLi,Y and MUZYILA. paid br:osters in cash. The
checks signed by boosters were not cashed, deposited, clr othc.rrvisenegotiated, but
rather were held as false evidence that CONN$LLY

and MUZYKA

were in

compliance with state law.


30.

It was further a part of the conspiracy that CONNELJ,Y and MUZYI(A

maintained a display of goods filr sale at Ace Amusements to maintain an


appearance of legitimacy, when in truth and in fact the gooclswere stolen and served
to indicate to boosters thie t-v-pes
r:f gooclsCONINFjLLY and h,lUZYi({, wanted them to
steal to be resold at Ace Amusements.
31.

It was fr.rther zrpart of the urnspiracy that CONNBLLY and MUZYK{

stored stolen goodsintendecl ftlr resalerat 46 l{imbeirly Ave nue, Ncw FIaven, in a room
connected to Ace Amuse:mentsbut that was inaccessibleto the general puhiic.
Overt AgXs
32.

in furtherance of the conspimcy ancl t.ci effect the objcct.s of the

conspiracy, CONNBLLY, MUZYKA, nncl REIDHLL and thcir co-conspiratorsknown

and unknown to the Clrand Jury, committed and caused to be committed the
followingovert acts,amongothers,in the District of Connecticutand elsewhere:
Aduancesto Boosters
(a)

For a duraLionof time during the conspiracyunknorvn to the Grand

Jury, MUZYKA mainta:rneda record of monetary advancesthat CONNELLY had


given to various boostersto be paid back by the delivery of stolen property to Ace
Amusements;
SignedChechs
(b)

On June 22',,20L4,MUZYKA had D.P. sign an Ace Amusementscheck

for $140 purportedly made out to D.P. as payment for an Acer desktopcomputer,
when in fact D.P. had beenpaid in cash;
False Entries in Leads Online
(c)

MUZYI(A represented to Leads Online that D.P. sold to Ace

Amusements an Acer d,esktopcomputer for $140 on June 22, 20L4, and that Ace
Amusementspaid him by check,when in fact D.P. had beenpaid in cash;
,tr.R.Pu,rchases
from AceAmusements
(d)

On or about September25,2AL0, J.R. purchasedstolen productsfrom

Ace Amusementsfor $5,t)00;


MUZYKA Online Account
(e)

At all timesrrelevant to the Indictment, MUZYKA maintained an eBay

accountwith the usernamepck-sales,which he used to sell online stolen goodshe


10

purchascd irt.i\cc i\musemelrts;


M(IZYKA Banlz Transfer
(0

transferrcd S300 dollnrs fi'om }ris


On or aboul.June 27, 20L4, il,'IUZYI{-A.

PayPal account associat.edwith his eBay account to his personal Wehster Bank
account with account number ending in 9662.
REIDELL Online Account
(g)

At all timesrrelevant to the Indictment, REIDELL maintained an eBay

account with t,he username Rosemary1060, which he used to sell stoien goods he
purchased from r\ce Amugements oniine; and
CANI'{ELLY Purchase of Goods
(h)

On or aboul;June 29, 2015, an individual known to the Grand Jury sold

to CONNELLY productsi that had anti-theft stickers attached to them with n retail
value of $78f).32.

All in violationof litle 18,UnitedStatesCode.Section371.


THROUGH FOUR
llouNTS TWO_
(InterstateTransportof StolenPropert5')
33.

The allegations in paragraphs l through 9 and 11 through 3? of this

Indictment are re-allegeC and incorporated by reference as though set out in full in
fhese counts.

34.

In or aboutthe time periodAugust 1, 2011,throughJanuary 25. 2016,

in the District of Connecticutand elsewhere,defendantsCONNBLLY, lUtlZYKA,


and RIIIDELL dicl unla'vfully transport,tlansmit, and transfer in interstate ancl
11

foreign commerce,irnd aided and alretted each other and others to do the same, stolen
goods, wares, and merchandisel, that is, stolettr goods CONN0LI,Y and N{UZYKA
obtained from boosters that they resold an<l cnused to bc resold online by MLIZYI(A,
REIDELL,

and J.R. ,and shipped from

Connecticut to locations outside of

Connecticut, of the value of $5,000 or more, knowing tho same to have bccn stolen"
converted, and talken by fraud, the aggregale trilnsactions involving cach online
reseller constituting a separate count of this Indictment:

Count

Defendantg

OnlineReseller

CON'NELI,Y,MTiZ\-IIA,,REIDELL

REIDEI,L

CONNELLY. ]UUZYKA

MUZYIn\

CONNBLLY, MUZYIil

J.R.

All in violation of Title 18. tlnited States Code, Sections 2314 rind Z.

FORFEITURE ALLEGATION
(Interstate Transport of Stcilen Propcrty and Conspiracy)
35. Upon conviction of one or more of thc counts alleged in Counts One through
Four of this Indictment, defendant.q CONNELLY. h.'ILIZYKA,ancl REIDELL shall
forfeit to the United States of Amerrica, pursuilnt to Title ltl, tlnite<i Stnt.esCocle,
Section 981(aX1XC) and Title 2lJ,Llnited Statcs Coder.Section 2461(c),rill right, title,
and interest in any and all property, real or pcrsonal, which constittrtes or is derived
from proceedstraceablc to violations of Title 18, Llnitccl St:rtcs Cocle. Sections B?1
and 2314, including but :notlimitcd [o the fbllowing:

7?

F inancial f\ccounts:
(a)

An interest. up to the ilrnonnt of $10,684.$4in !'irst


Niap;ara Rank, Nerv Haven, Connecticut, account
numbcr cnciing tn P1;29,herldin the namc of Paul
N{uzvka.

(b)

r\n interest up to t,hc amount of $$,860.70in First


Niagara Bank, New Haven, Connecticut, acconnt
n u m b e r e n d i n g i n 0 2 3 1 , h e l d in the namc of Act:
Amusements. Ll,C.

(c)

An i,nterest up to the amount of $2,9?4.53in F'ilst


Niagarar Bank, New Haven, Connecticut, account
number cnding 2$40, held in thc nnme of George
CclnnellS.'.

Currencv:

(d)

Approximately $13,07f1.67 in [Jnited States


curfoncy, of which 92,ii49.00 wers seized from the
person of George Connelly. $6,0$)6.00was seized
from an r.rnlockedsafe, and $4,455.6? was seized
from various locations, all seired on or about
Januurry 2f>, 2016, from the husiness of Ace
Amuserncnts. LLC, locilted nt 42 l{imbcrlv Avenue.
New Haven, Conncct,icr.rt.

(e)

Approximntely' 91,727.00in l.lnitcd $tafcs currcncy


scizcd on or abr:ut Jarnuerry2i:, 201G.I'rom a 2014
Nissan Maximn with VIN numbcr cnding in ZgZ2
registcred to Paul Nltrzyka from the residencc ol'
Paul lVluzyka, located at 31 Fortunc Drive, North
Harven,C<;nnecticut.

(0

Appr'rximately 960,732.00 in
Llnitecl St:rtes
curt'enc),scized on or ilbout Januirry 20, 2016, from
the rcsidclnccof Pnul Nluzykn. Iocat,ec{
at Bl Frtrtune
Drive,,North l"{aven,Connecticut.

l3

Real Property:
(g)

An intererstup to the amount of $20(),000in cerrtain


real property locafed at 15ir Tr"rt,fleDrive. New
Hirven, CT 065I2- i:022.

36. If any of the abclve-dcscribedforfeitablc propcrty. ns n rcsult of any act or


omission nf the defendants, cannot be located upon the cxcrcisc of clue diligence. has
been transfert'ed, sold to, or clepositedwith a third pnrty, has bcernplaced beyrind the
jurisdiction of the court, has been substantially diminished in va]ue, or harsbeen
commingled with other property which cannot be divided without clifficulty, it is the
intent of the United Stafes, pursuant to Title 21, Linited States Code, Section flbg(p),
a-sincorporated by Title 28, United States Code, Section 2461(c),to seek fcrrfeitureof
any other propert-v of said clefendants up to the value of the forfeitable property
describedabove.

14

r\ll in accordnncewith Title 18, United States Codc, Scction981(aX1)as


incorporatedby Titlc i18,Linited States Code,Section2461(c).and Rulc 32.?(a),
FecleralRuiesof Criminal Proceclurc.
A TRUB BILL

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FOREPERSON
UNITED STATESOF IIMERIC..\
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UNITED STATES ATTICRITIEY

JOHl.-{,.ry:"
PIERPONT,J R.
AFSTSTANT
UNITODSTATESATTORNEY
{

DAVID T. HUAN
ASSISTANTUNITED S;TATESATTORNEY

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