IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

UNITED STATES OF AMERICA

v.

ANDREY SHUKLIN, et al.,

Defendants.

:

:

:

:

:

:

:

:

Case No. 18-CR-109

Judge Timothy S. Black

JOINT STATUS REPORT

The Government submitsthis joint status report to the Court relating to the above-captioned 

case and states as follows:

On July 25, 2018, a federal grand jury returned a one-count Indictment against twelve 

defendants, charging the defendants with participating in a multiyear RICO Conspiracy in 

violation of 18 U.S.C. § 1962(d) relating to the transportation of household goods. (Doc. 3 

(Indictment).) To date, eight of the twelve defendants have been arrested and appeared in this 

District. The government considers the four defendants who have not yet been apprehended as 

fugitives. 

Shortly after the first defendant appeared in this District, the government began providing 

discovery. Discovery in this matter is voluminous—it includes, among other things, over 80 

forensically imaged computers, multiple email accounts, bank records, and corporate and customer 

files and documents, including evidence seized during post-Indictment search warrants of multiple 

warehouses located all over the country where customer goods were being stored.

1

 As a result, 

the government has been providing discovery on a rolling basis. 

 1 With cooperation and assistance from defendants, in the months following the Indictment, agents 

facilitated the recovery of household goods to approximately 200 customers from warehouses and 

storage units throughout the country. 

Case: 1:18-cr-00109-TSB Doc #: 98 Filed: 04/09/19 Page: 1 of 3 PAGEID #: 571
The parties have been working collaboratively to resolve any discovery issues. On March 

28, 2019, the government and available defense counsel participated in a conference call to discuss 

the status of discovery and to devise a strategy for producing and reproducing certain discovery in 

a way that is both cost-effective for defendants and allows counsel to access and review all 

materials in the most efficient manner. The government will continue to work with defense 

counsel to address any discovery concerns that may arise.

The government has provided this status report to all current counsel for defendants of 

record who have appeared to date, and they concur with its content. 

The parties respectfully request a conference to discuss scheduling at the Court’s 

convenience.

Respectfully submitted,

BENJAMIN C. GLASSMAN

United States Attorney

/s/ Matthew C. Singer

MATTHEW C. SINGER (IL 6297632)

MEGAN GAFFNEY (NY 4849220)

Assistant United States Attorneys

221 E. Fourth Street, Suite 400

Cincinnati, Ohio 45202

Matthew.singer@usdoj.gov

Megan.gaffney@usdoj.gov

(513)684-3711

Case: 1:18-cr-00109-TSB Doc #: 98 Filed: 04/09/19 Page: 2 of 3 PAGEID #: 571
CERTIFICATE OF SERVICE

I hereby certify that the foregoing was filed with the Court’s CM/ECF System this 9th day 

of April 2019, which provides electronic notice to all parties.

/s/Matthew C. Singer

MATTHEW C. SINGER (IL 6297632)

Assistant United States Attorney

Case: 1:18-cr-00109-TSB Doc #: 98 Filed: 04/09/19 Page: 3 of 3 PAGEID #: 571