Affidavit in Support of a Criminal Complaint, Michael Dimassa (Document 1-1, filed October 19, 2021)

Summary

Affidavit of FBI Special Agent Christopher Cieplik supporting a criminal complaint and arrest warrant for Michael Dimassa for a violation of Title 18, United States Code, Section 1343 (Wire Fraud). It states that Dimassa is listed in the City of West Haven Employee Directory as the Administrative Assistant to the City Council. It states that a May 5, 2021 payment voucher billed the City $85,595.00 for "COVID-19 Legal+ Lobbying+ Site work for COVID-19 Clinic" for Compass Investment Group, and that a check in that amount was deposited on May 7, 2021. It states that, according to the West Haven Corporation Counsel, the Health Director never engaged Compass Investment Group, and that from in or about February, 2021 through September, 2021, a total of $636,783.70 was paid to it by the City.

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Full text

        Case 3:21-mj-01036-RMS Document 1-1 Filed 10/19/21 Page 1 of 6




      STATE OF CONNECTICUT                                   ss: New Haven, Connecticut



     COUNTY OF NEW HAVEN                                        Date: October_, 2021



               AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

       I, Christopher Cieplik, having been duly sworn, depose and state the following:



1.              I am a Special Agent with the Federal Bureau oflnvestigation (FBI). I have been

employed by the FBI for over twenty-two years. Prior to becoming a Special Agent with the FBI,

I was a commissioned officer in the United States Coast Guard for approximately six years. I

graduated from the FBI Academy in Quantico, Virginia, and have attended numerous other law

enforcement training programs. Since June 2008, I have been assigned to the FBI N~w Haven

Field Office. My primary duties have been to identify, investigate and assist in the prosecution of

individuals who violate federal laws involving public corruption and financial fraud. I have

attended numerous specialized training courses and seminars, where I have received additional

training on how to investigate various types of criminal violations, including fraud, money

laundering, and public corruption. During my employment with FBI, I have initiated and/or

participated in numerous criminal investigations, initiated and/or participated in the arrest of

numerous defendants, initiated and/or participated in numerous search warrants, and initiated

and/or participated in the interview of numerous of witnesses, defendants, and subjects involved

in various criminal violations.

       2.       I submit this affidavit in support of an application for a criminal corrip-laint and

arrest warrant for MICHAEL DIMASSA for a violation of Title 18, United States Code, Section

1343 (Wire Fraud). Based upon the facts set forth below, there is probable cause to believe, and I
        Case 3:21-mj-01036-RMS Document 1-1 Filed 10/19/21 Page 2 of 6




do believe, that MICHAEL DIMASSA has violated the above-referenced criminal statute.

       3.      The information provided herein is based upon my own knowledge and

experience, as well as information provided to me by other law enforcement officers, including

members of the United States Department of Housing and Urban Development-Office oflnspector

General for Investigations.   Because this affidavit is submitted for the limited purpose of

establishing probable cause for the requested criminal complaint and arrest warrant, I have not

included each and every fact known to me concerning this investigation. Rather, I have set forth

herein only those facts that I believe are necessary to establish probable cause to support the

requested criminal complaint and arrest warrant.

                                              Background

       4.      MICHAEL DIMASSA is listed in the City of West Haven Employee Directory as

the Administrative Assistant to the City Council.     He is also currently a Connecticut State

Representative elected to represent West Haven and New Haven.

       5.      According to the City of West Haven, MICHAEL DIMAS SA has been employed

by the City of West Haven for approximately twelve years in various positions, including

legislative aide to the West Haven City Council, Council's Clerk, assistant to the Mayor and

administrative aide to the West Haven Registrar of Voters.

       6.      According to records at the State of Connecticut-Office of the Secretary of State,

the business COMPASS INVESTMENT GROUP, LLC was formed January 27, 2021. The

business has two principals, MICHAEL DIMASSA and Person 1. The listed business address

appears to be the home address of Person 1.

       7.      On February 5, 2021 a bank account for COMPASS INVESTMENT GROUP, LLC

was established at Webster Bank. The listed address appears to be the residence of Person 1. Both
        Case 3:21-mj-01036-RMS Document 1-1 Filed 10/19/21 Page 3 of 6




MICHAEL DIMASSA and Person 1 are listed as authorized signatories

       8.      A review of the bank account was conducted for the period of February 5, 2021

through April 30, 2021. This review revealed that from February 12, 2021 through April 30, 2021,

seven checks were made payable to COMPASS INVESTMENT GROUP, LLC from the City of

West Haven and were deposited to the business account. The checks ranged in value from

$11,847.50 to $87,650.0. These funds were then used for twenty-one cash withdrawals that were

conducted by MICHAEL DIMASSA, ranging from $8,000 to $10,000, for a total of $178,150.

Nine of the withdrawals were in the form of checks made out to himself and twelve were via

withdrawal slips.

                    Examples of Fraudulent Claims for Payment in May, 2021

       9.      On May 5, 2021, a City of West Haven Payment Voucher No. 602081 was

submitted for payment by the "COVID-19 Grant Department." Attached to this voucher was an

invoice listing alleged services provided to the West Haven Health Department. The voucher

described the services as "COVID-19 Legal+ Lobbying+ Site work for COVID-19 Clinic." The

invoice listed charges that included 305 hours of Consulting Service-Legislative Review Executive

Orders - COVID-19, 483 hours of Consulting Service-Support Staff Services, 305 hours of

Monitors/Security Site (April 2021-May 2021), and 102 hours of Consulting Service Lobbying

Service-COVID-19 Federal. The amount billed to the City of West Haven was $85,595.00

       10.     On May 6, 2021, Check Number xxxxx9061 was issued by the City of West Haven

Accounts Payable bank account in the amount of$85,595.00. The check was issued to COMPASS

INVESTMENT GROUP LLC. On May 7, 2021, the check was deposited into the Webster Bank

account of Compass Investment Group. Such deposit caused the transmission of an interstate wire.

       11.     On May 7, 2021, a cash withdrawal of $8,200 was taken from the account by
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MICHAEL DIMASSA. On the following dates, subsequent cash withdrawals were made by

MICHAEL DIMASSA:

May 10 - $8,500                    May 11 - $9,125

May 13 - $9,250                    May 17 - $9,100

May 18 - $9,350

       12.    On May 7, 2021 Mohegan Sun Patron Gaming records reflect MICHAEL

DIMAS SA executed a cash "Buy-In" of chips for $9,800. On the following dates subsequent cash

buy-ins were executed by MICHAEL DIMASSA:

May 10 - $5,700                    May 12 - $5,000

May 13 - $3,000                    May 15 - $5,000

May 17 - $4,600


       13.    On May 19, 2021 West Haven Payment Voucher No. 602082 was submitted for

payment by the "COVID-19 Grant Department." Attached to this voucher was an invoice listing

alleged services provided to the West Haven Health Department. The voucher described the

services as "COVID-19 Legal + Site work". The invoice listed items which included 150 hours

of Consulting Service-Legislative Review Opening Guidelines, 100 hours of Consulting Service-

Support Staff Services, 242 hours of Consulting Service Lobbying Service-COVID-19 Federal,

and Economic Consulting-Economic Site Plan Assessment/Review. The amount billed to the City

of West Haven was $84,650.00

       14.    On May 20, 2021 Check Number xxxxx9461 was issued by the City of West Haven

Accounts Payable bank account in the amount of $84,650.00. The check was issued to COMPASS

INVESTMENT GROUP LLC.
        Case 3:21-mj-01036-RMS Document 1-1 Filed 10/19/21 Page 5 of 6




       15.     On May 21, 2021 , the check was deposited into Compass' s Webster Bank account.

Such deposit caused the transmission of an interstate wire.

       16.     On May 21, 2021, $9,200 was withdrawn from the account by MICHAEL

DIMASSA.      On the following dates subsequent cash withdrawals were made by MICHAEL

DIMASSA:

       May 24 - $9,000                       May 24 - $9,000

       June 1 - $9,800                       June 1 - $9,800

       June 7 - $9,800

       17.     On May 21, 2021 Mohegan Sun Patron Gaming records reflect MICHAEL

DIMASSA executed a cash buy-in of $4,000. On the following dates, subsequent cash buy ins

were executed by MICHAEL DIMASSA:

May 23 - $6,200

May 28 - $4,000

May 29 - $10,400

                   Compass Investment Group Never Provided Any Services
                       to the West Haven Public Health Department

       18.     The invoices requesting payment to Compass Investment Group refer to services

provided to "City of West Haven, Health Department." According to the West Haven Corporation

Counsel, the West Haven Health Director never used, selected, approved, or otherwise engaged

Compass Investment Group for any work or services concerning the West Haven Public Health

Department.

       19.     From in or about February, 2021 through September, 2021, a total of $636,783.70

was paid to the Compass Investment Group by the City of West Haven.
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                                                       Conclusion

       20.      For the reasons set forth herein, I submit that there is probable cause to believe, and

I do believe, that MICHAEL DIMAS SA committed a violation of Title 18, United States Code,

Sections 1343 (Wire Fraud).           I respectfully request the issuance of the requested criminal

complaint and arrest warrant.

      · 21.     I also request that this affidavit, the requested criminal complaint and the requested

warranted be placed under seal by the Court until the time of the initial appearance because the

defendant has not yet been arrested.



                                                           Respectfully submitted,




                                                         19th
       Subscribed and sworn to before me this _ _ day of October, 2021

         Sarah A. L.       Digitally signed by Sarah A. L.
                           Merriam, U.S.D.J.
         Merriam, U.S.D.J. Date: 2021.10.19 15:02:26 -04'00'
       THE HON. SARAH A. L. MERRIAM
       UNITED STATES DISTRICT JUDGE


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