A Federal RICO Complaint Against a Moving Broker: Fabricated Reviews, a Multi-State Corporate Network, and a No-Show Scheme That Settled

On August 29, 2022, Elliot Chanen and Sara Khodadost filed a civil complaint in the United States District Court for the Southern District of Florida (Case No. 0:22-cv-61610-RS). The 28-page complaint raised eight counts, including two federal RICO claims under 18 U.S.C. 1962(c) and 1962(d), a Lanham Act false advertising claim under 15 U.S.C. 1125, Florida common law fraud, intentional infliction of emotional distress, civil conspiracy, unjust enrichment, and a Florida Deceptive and Unfair Trade Practices Act (FDUTPA) claim.

The complaint described the defendants' operation as 'a national criminal enterprise designed to steal and extort money from people when they are most vulnerable.' The case settled. The settlement terms are not public.

The complaint named eight defendants and ten unnamed co-conspirators:

1. Moving Storage and Logistics Services Inc, d/b/a Value Added Moving ('VAM'). Florida corporation, 4005 North Federal Highway, Suite 207, Fort Lauderdale, FL 33308. DOT 3488475, MC 1147286, EIN 85-3038663. Phone numbers: (201) 704-7332, (888) 325-5081, (561) 486-7380. Registered to do business in Florida since August 28, 2020. Registered agent: Daniel Beirne, CPA, listed at 6023 Town Colony Drive, Apt. 223, Boca Raton, FL 33433. The complaint notes this address is the home address of defendant Victor Stanziale, not the agent's business address.

2. Value Added Solutions, d/b/a Value Added Movers ('VAS'). Minnesota corporation, 10596 97th Place North, Maple Grove, MN 55369. Same DOT number as VAM (3488475). Also associated with 950 3rd St, St Paul Park, MN 55071. Registered to do business in Minnesota since March 14, 2022.

3. All Seasons Moving South LLC, d/b/a All Season Movers. New Jersey corporation, 12 Breiderhoft Rd, Kearny, NJ 07032. DOT 125550. Associated with Atlas Van Lines. Registered in New Jersey on August 19, 2020, nine days before VAM registered in Florida. Phone numbers: (201) 997-8034, (201) 991-6075, (201) 747-4177, (973) 666-9600.

4. Victor Stanziale Jr. President of VAM. Approximately 33 years old at the time of filing. Address: 6023 Town Colony Dr #223, Boca Raton, FL 33433. The complaint identifies him as 'the person primarily responsible for the VAS's policies, practices, and procedures.'

5. Jacob Jeremy Sachs. President of VAS. Approximately 46 years old at the time of filing. Address: 8487 78th Street Court South, Cottage Grove, MN 55016.

6. Matthew Jason Preston Jr. Sales representative for VAM. Phone: (320) 297-4974 (Minnesota number). Also potentially used (954) 512-3506 and (612) 388-6438. Lived in Mankato, Minnesota or Pembroke Pines, Florida.

7. Donald LNU (last name unknown). Phone: (320) 297-4998. Lived in or near Fort Lauderdale, Florida.

8. Michael LNU, aka Michael M. Phone: (218) 203-5727. Resided in Fort Lauderdale, Florida or the St. Paul, Minnesota area. Identified himself as a VAM 'Customer Service Representative' who made $12 per hour.

The complaint documented three related entities operating across Florida, Minnesota, and New Jersey under the Value Added brand:

VAM (Florida) operated the website valueaddedmoving.com, listing the Fort Lauderdale address and the 888-325-5081 phone number.

VAS (Minnesota) operated valueaddedmovers.com, listing the Minnesota address and the same 888-325-5081 number.

A third website, valueaddednetworks.com, listed the Fort Lauderdale address and a Los Angeles, California phone number (213-567-4704).

Both VAM and VAS shared the same DOT number (3488475). All Seasons Moving South, the New Jersey entity that was dispatched as the carrier, registered nine days before VAM. The complaint alleges the three entities, along with their officers, constituted a racketeering enterprise under RICO.

The complaint identified specific false statements on the defendants' websites. The following claims were alleged to be false:

'35 years of serving' (VAM was registered in 2020). '62,360 boxes moved.' '3,560 happy customers.' 'Value Added Moving is one of the nation's largest moving brokers licensed by the U.S. Department of Transportation.' '[H]undreds of motor carriers and thousands of trucks currently participate in the Value-Added Moving Network affiliate program.' 'Value Added Moving promises you a team of dedicated professionals ready to assist you every stop of the way.' '[E]very step of the way you have a personal advocate, taking care of all your needs.' 'Typically we reply back in 20 minutes.' 'We will not share your information with any third parties.'

The complaint also identified eight named testimonials on the website as false: Marci Morelo (Miami, FL), Marci Moreno (Miami, FL), Susan Whiting (Charlotte, NC), Lidia Donahue (Charlotte, NC), Brenton Pace (Greensboro, NC), Neil Elbaum, Ilene Bailey, Jack Burrows, and Alexander Sanson.

On June 15, 2022, plaintiff Chanen spoke with sales representative Matthew Jason Preston Jr. about a move from Chicago, Illinois to Ann Arbor, Michigan. Preston demanded a $1,000 deposit 'to reserve the August 17 pick-up date' and required a backup date. Chanen e-signed the contract and authorized ACH payment of $1,000 on June 17, 2022.

On August 11, six days before the scheduled move, an individual using phone number (218) 203-5727 texted Chanen identifying himself as 'Michael from the Quality Assurance Department @ Value Added Moving' and asked Chanen to call to 'go over the final details of your scheduled pick-up.'

On August 12, Chanen called both Michael and Preston. Neither answered or returned calls.

On August 16, the day before the scheduled move, Chanen called VAM's toll-free number and spoke with defendant Donald, who said: 'if you don't receive a call by the end of the day today, they will be coming on Thursday, not Wednesday; and, if you don't hear anything by close of business on Thursday, call me back at this number.' This was the first time Chanen was told the movers would not honor the scheduled date.

At 6:55 p.m. that evening, a person named Alex called from a New Jersey area code and said he was 'a truck driver for All Seasons Moving' with a three-person crew, and that they would arrive Wednesday between 11 a.m. and 1 p.m.

Two hours later, at approximately 9 p.m., an individual named Will called and said: 'Hey, is this Elliot? So sorry, but we actually are not going to be able to show up tomorrow at all.' When Chanen protested that Alex had just confirmed, Will replied: 'Who's Alex?' Will then claimed the crew needed a '24-hour rest' due to 'trucking regulations' and would arrive Thursday.

On Thursday morning, no one arrived. Chanen called Alex, who texted that his team would not arrive until 6-8 p.m. At 10:33 a.m., Chanen reached Donald at VAM, who said the matter was 'out of Value-Added's hands' and that Chanen 'had to talk to the people at the Movers.' Donald concluded: 'Sorry they are being difficult, but there is not much I can do at this time.'

Will called at 11:25 a.m. saying the crew would arrive by 3 p.m. Neither Alex nor his crew ever showed up. Chanen made calls at 3:21, 3:23, 4:13, 7:22, 7:23, 7:23, 7:24, and 7:37 p.m. No one answered.

At 7:46 p.m., someone named Diego answered Will's phone and said: 'Oh, no one told you, you got rescheduled to Friday or Saturday.' When Chanen said his scheduled date was Wednesday August 17, Diego replied: 'Oh, I'll call you right back' and hung up. That was the last time Chanen heard from anyone at All Seasons.

Chanen and Khodadost rented a U-Haul and moved themselves.

On August 19, Chanen emailed VAM canceling the contract and demanding his $1,000 back. At 8:53 a.m., defendant Donald called and lied that the movers were 'still on their way.' Chanen repeatedly said the contract was cancelled. Donald responded that for a refund, Chanen would have to speak with 'Value Added's legal department.'

Beginning at 9:29 a.m., defendant Michael began power-calling Chanen from a blocked telephone number: 9:29, 9:33, 9:34, 9:38, 9:42, 9:42, 9:42 a.m. Three calls went through. Michael stated that VAM did not have a legal department and that the cancellation had to be in writing. When told the cancellation was already in writing, Michael emailed: 'the cancellation is outside of the company policy.'

At 10:00 a.m., Michael sent a screenshot of a navigation map and insisted the moving crew 'was only 80 miles away.' The map, filed as an exhibit in the complaint, shows the route indicator reading '88 mi' to the next turn, but the destination was 382 miles away with an estimated travel time of 5 hours and 43 minutes.

The $1,000 was never refunded.

The complaint alleged two RICO counts:

Count VII (18 U.S.C. 1962(c)): The defendants conducted and participated in a Racketeering Enterprise comprised of Stanziale, Sachs, Preston, and the LNU individuals, along with VAM, VAS, All Seasons, and other unknown companies. The enterprise 'did not go by a specific name, but it nevertheless acted as a continuing and cohesive unit.' Its primary objective was 'to steal funds belonging to individuals who were moving their entire households from one State to another.' The enterprise conducted its affairs through a pattern of wire fraud violations (18 U.S.C. 1343) and state extortion (18 U.S.C. 1961(1)). At least two predicate acts occurred within ten years of each other. The pattern amounted to 'continuing criminal activity' spanning more than two years.

Count VIII (18 U.S.C. 1962(d)): The defendants conspired to conduct and participate in the racketeering enterprise. The conspiracy existed 'since at least August 17, 2020, if not before.'

The complaint noted that 'Chanen and Khodadost are the only Plaintiffs in this particular lawsuit, at this time, they are by no means the Racketeering Enterprise's only victims. To the contrary, the Racketeering Enterprise has targeted and defrauded numerous victims.' The plaintiffs indicated their intent to pursue class action allegations under FRCP 23 pending further discovery.

The complaint reproduced a clause from VAM's contract:

'CUSTOMER HEREBY KNOWINGLY, VOLUNTARILY AND INTENTIONALLY WAIVES THE RIGHT TO A TRIAL BY JURY IN RESPECT OF ANY LITIGATION BASED HEREON, OR ARISING OUT OF, UNDER OR IN CONNECTION WITH THE GOODS AND SERVICES OBTAINED HEREUNDER, THE MOVE, OR ANY COURSE OF CONDUCT, COURSE OF DEALING, STATEMENTS (VERBAL OR WRITTEN) OR ACTIONS OF VALUE-ADDED MOVING OR THE MOVER. CUSTOMER ACKNOWLEDGES THAT THIS WAIVER CONSTITUTES A MATERIAL INDUCEMENT TO VALUE ADDED MOVING TO ENTER INTO THIS AGREEMENT.'

The plaintiff argued this clause was 'wholly unenforceable under public policy when, among other things, it appears in the fine print of an adhesion contract.'

The complaint sought:

1. Compensatory damages in an amount to be determined at trial. 2. Treble damages (triple the compensatory damages). 3. Punitive damages. 4. An order under 28 U.S.C. 1964(a) dissolving or reorganizing the defendants' enterprise. 5. An order directing defendants to divest themselves of any interest in the enterprise. 6. An order prohibiting each defendant from engaging in the same type of endeavor. 7. An order imposing reasonable restrictions on each defendant's future activities. 8. An order directing defendants to disgorge all deposits for which no moving services were ever provided. 9. An injunction ordering removal of all false advertising. 10. Attorneys' fees under 15 U.S.C. 1117(a) and 28 U.S.C. 1964(c).

The case settled. The terms are not public.

Federal RICO complaints against household goods moving brokers are rare. Most moving fraud litigation occurs in state small claims or county courts, where the amounts in controversy are small and the legal claims are limited to breach of contract. The Chanen complaint is notable for several reasons:

1. It was filed in federal court with federal subject matter jurisdiction under both the Lanham Act and RICO, and diversity jurisdiction (the amount in controversy exceeded $75,000).

2. It named specific individuals, their roles, their addresses, and their phone numbers, creating a public record of the network behind the corporate entity.

3. It documented specific fabricated testimonials on the company's website, with names, and alleged them to be false under the Lanham Act.

4. It identified the three-state corporate structure (Florida, Minnesota, New Jersey) that allowed the enterprise to present different faces to consumers in different markets while sharing the same DOT number.

5. It alleged a conspiracy dating back to at least August 2020, with predicate acts spanning more than two years.

6. It settled, meaning the defendants chose to resolve the claims rather than contest them at trial.

Value Added Moving (DOT 3488475) went from 3 FMCSA complaints in 2023 to 178 through October 2026. The owner, Victor Stanziale Jr., has since been charged with criminal battery (F.S. 784.03(1)(A)) and sued by an employee for assault. Two additional consumer lawsuits were filed in Broward County in 2026. The operation described in the 2022 RICO complaint continued.