Isn't chaos fun? While everyone and their brothers try to sort out this
Caribbean sportsbook fiasco, IGN has a few nuts and bolts for you to chew on. Following is a copy of all the complaints filed by the US Government. So, without further ado, lets have a look at these
buggers as well as the full release from the Dept. of Justice.
THOMAS C. RUBIN and DANIEL C. BECKER
Assistant United States Attorneys
Before: HONORABLE NAOMI REICE BUCKWALD
United States Magistrate Judge
Southern District of New York
- - - - - - - - - - - -
UNITED STATES OF AMERICA
S. CHESTER HUNTER and
A/k/a "Brian Jones,"
18 U.S.C. 371
COUNTIES OF OFFENSE:
NEW YORK AND ELSEWHERE
SOUTHERN DISTRICT OF NEW YORK, ss.:
LISA J. FERENCE, being duly sworn, deposes and says that
she is a Special Agent with the Federal Bureau of Investigation and
charges as follows:
1. From in or about 1997 , until on or about today’s
date, in the southern District of New York and elsewhere, S. CHESTER HUNTER
and BRIAN JANUS, a/k/a "Brian Jones," the defendant , and others known
and unknown, unlawfully, willfully, and knowingly did combine, conspire,
confederate, and agree together and with each other to commit an offense
against the United States to wit, to violate Title 18, United States Code,
2. It was a part and object of the conspiracy that
S. CHESTER HUNTER and BRIAN JANUS, a/k/a "Brian Jones," the defendants,
and others known and unknown, being engaged in the business of betting
and wagering,, unlawfully, willfully and knowingly, would and did use a
wire communication facility for the transmission in interstate and foreign
commerce of bets and wagers and information assisting in the placing of
bets and wagers on sporting events and contents, and for the transmission
of a wire communication which entitled the recipient to receive money and
credit as a result of bets and wagers and for information assisting in
the placing of bets and wagers, in violation of Title 18l United States
Code, Section 1084.
3. In furtherance of said conspiracy and to effect the object thereof,
S. CHESTER HUNTER and BRIAN JANUS, a/k/a "Brian Jones," the defendants,
and others known and unknown, committed the following overt acts in the
Southern District of New York and elsewhere:
a. On or about January 13, 1998, an undercover
agent in New York, New York, had a telephone conversation with
BRIAN JANUS, a/k/a "Brian Jones," the defendant, who identified
himself as a part owner and the operations manager of Galaxy
b. On or about February 4, 1998, S. CHESTER
HUNTER, the defendant, called an undercover telephone number in New
York, New York, and left a message on a telephone answering machine used
by an undercover agent identifying himself as managing director of Galaxy
(Title 18, United States Code, Section 371.)
The bases for my knowledge and the foregoing charge are, in part, as
4. I have been an FBI agent for two years.
past 15 months, I have been a member of the FBI's Computer Crimes squad
and am familiar with computers and the Internet.
5. I am familiar with the facts and circumstances
forth below from my participation in the investigation and from my conversations
with other law enforcement agents and witnesses. Because this Complaint
is being submitted for a limited purpose, I have not included details of
every aspect of this investigation. Where conversations or statements
are related herein, they are related in substance and in part.
6. During the course of this investigation, I received information from
various sources that Galaxy Sports was operating a sports betting business
over the Internet. As a result of this information, the FBI began an investigation
to determine, among other things, whether Galaxy Sports was using the Internet
or other fforms of wire communication facilities in interstate and foreign
commerce to conduct a sports betting business, and, if so, who was responsible
for that conduct.
7. Based on my experience on the PSI'A Computer Crimes
squad an well as various publications I have read, I know that the
Internet is an immense worldwide computer network used by millions of individuals
daily. The Internet in comprised of many smaller computer networks
that are connected to each other via telephone and other data lines.
The World Wide Web ("WWW") in a hypertext-based system that facilitates
the ability to find and access information on the Internet. Many
businesses, including Galaxy Sports, use the WWW to advertise, promote,
and provide information about their services. Typically, communications
over the Internet -- including the references in this Complaint to accessing
WWW pages -- take place over ordinary telephone lines through the use of
a modem. Those communications travel over ordinary telephone lines between
the points of origin (such as a computer server that is used to store and
transmit WWW pages) and the points of reception (much an the personal computer
of an individual who accesses a particular site on the WWW).
8. Using an undercover Internet account that can be
accessed at the FBI offices in New York, New York, I accessed the
web site for Galaxy, Sports, at www.galaxysports-com. The Galaxy Sports
web site revealed the following:,
a. Galaxy Sports is a sports wagering service that
accepts bets on various sporting events, including football, hockey,
baseball and basketball.
b. Galaxy sports offers a toll-free telephone number to call for information
concerning sports betting and to place bets.
c. In order to bet with Galaxy Sports, a bettor is required to open
an account and send a minimum deposit of $500. The deposit could
be sent via MastarCard, DiscoverCard, Visa, Western Union, bank wire, cashiers
check, money order or personal check..
9. On or, about October 9, 1997, an undercover FBI special agent posing
as a potential bettor (the "UC"), called Galaxy Sports' toll-free number
at (800) 835-7260. A person who identified himself as "Rod" stated
that Galaxy Sports, which is based in Curacao, accepts wagers over the
telephone only and not over the Internet. "Rod" explained that Galaxy
Sports only advertises on the Internet. "Rod" also explained that the minimum
deposit to open an account is $500, and that the minimum bet is $50.
During that conversation, the UC requested that promotional literature
be mailed to an undercover address in New York, New York.
10. On or about November 3, 19970 the UC received in Now York, Saw Yorkt
two separate envelopes from Galaxy Sports that contained color brochures
for Galaxy Sports. Although the return address on the envelopes listed
an address in Curacao, the envelopes were Postmarked "Rod North Texas MPO."
In addition, the postage meter
used to stamp the envelope bore the notation "Richardson, TX" and the postage
was from the United States Postal Service.
11. On or about November 17, 1997, the UC called (800) 835-7260, Galaxy
Sports' toll-free number, and spoke with an individual who identified himself
as "Clark." The UC asked "Clark"' for literature about setting up an account,,
and "Clark" stated that it would be sent out that week from Dallas.
"Clark" explained that Galaxy Sports only accepts bets over the telephone,
and does not provide the ability to place bets over the Internet.
"Clark" also explained that money could be sent to Galaxy Sports to open
an account by bank wire, credit card, cashier's check or Western Union
Quick Collect. In addition, "Clark" told the UC that CHESTER
HUNTER, the defendant, is the owner and CEO of Galaxy Sports and that
HUNTER lives in Dallas.
12. Later that same day, the UC opened an account with Galaxy Sports
by sending $600 by Western Union from New York, New York to the account
that "Clark" had provided.
13. Later that same day, the UC called (800) 835-7260 again and asked
for "Clark." Clark asked the UC what toll-free number the UC had called,
and mentioned that Galaxy Sports uses "about 40" toll-free numbers.
"C3.ark" confirmed that Galaxy Sports received the $600, and stated that
the UC's account would be credited $675, representing' a ton percent bonus
on the $600 plus reimbursement of the $15 Western Union transfer fee.
The UC provided "Clark" with a password to enable the UC to make bets in
14. On or about November 25, 1997, the UC called (800)
730-5035, another of Galaxy Sports' toll-free numbers, from the
FBI's office in New York, New York, and bet on two National Football
League ("NFL") games scheduled to be played on November 27 and December
l, 1997. The UC bet $55 that the Dallas Cowboys would beat the Tennessee
Oilers by more than 6.5 points, and $55 that the total points scored in
the Green Bay Packers vs. Minnesota Vikings
game would be less than 45. The UC lost the fisrst bet and won
the second bet, and $50 in winnings was credited to the UC's account
with Galaxy Sports.
15. On or about December 3, 1997, the UC called (800) 730-5033 from
the FBI’s office in New York, New York and bet on two NFL games scheduled
to be played an December 7, 1997. The UC bet $55 that the Green Day
Packers would beat the Tampa Bay Buccaneers by more than 3.5 points,
and $55 that the Philadpolphia Eagles would beat the New York Giants by
more then 5 Points- The UC won the first bet and lost the second bet, and
$50 in winnings was credited to the UC's account with Galaxy Sports.
16. During that telephone call, the UC requested that some money in
the UCI’s account be returned to the UC. The Galaxy Sports employee
informed the UC that the UC would have to call the customer service line
at a different toll-free number.
17. A short time later, the UC called the customer service toll-free
number and requested a $100 cashier's check be sent to the UC in New York,
New York, via Federal Express. The UC spoke to an individual who
identified himself as "Brian," who processed the UC's withdrawal request.
18. On or about December 8, 1997, the UC received a $100 check by Federal
Express in New York,. New York. The check was written on an
account of "Bank of Nevis Ltd." and was payable through the Bank of New
York in New York, New York. A letter signed by S. CHESTER HUNTER,
the defendant, who identified himself as the CEO of Galaxy Sportsbook,
accompanied that check. HUNTER's letter stated, in part: "We take
this opportunity to express our thanks for your participation with Galaxy
Sports. . . " HUNTER's letter went on to offer a $50 to $100 bonus
for each new account referred to Galaxy Sports, and stated "good luck this
19. On or about December 12, 1997, the Uc called (800) 730-5033 from
the FBI's office in New York, New York, and bet on two NFL games scheduled
to be played on December 14, 1997. The UC bet $55 that the Miami
Dolphins would beat the Indianapolis colts by more than 4 points, and $55
that the total ' points scored in the game between the Green Bay Packers
and the Carolina Panthers would be more than 37.5. The UC lost the first
bet and won the second bet, and $50 in winnings was credited to the UC's
account with Galaxy Sports.
20. On or about December 24,, 1997, UC called Galaxy Sports' customer
service toll-free number, (800) 866-7015, and requested that the remaining
account balance of $560 be sent to the UC in Now York,, Now York, via Federal
Express. The UC spoke to an
an employee who processed UC's withdrawal request. During that
conversation, the employee stated that the owner of Galaxy sports is CHESTER
HUNTER, the defendant, and that HUNTER is in Dallas.
21. On or about January 5, 1998 p the UC received by Federal Express
a $660 check, which was written on a check from the same account as that
referred to in paragraph 18 above. A letter signed by S. CHESTER
HUNTER, the defendant,, which was identical to the letter described In
paragraph 18 above accompanied that check.
22. on or about January 8, igge, the UC called one of Galaxy Sports'
toll-free numbers and asked to speak to CHESTER HUNTER. An individual
who identified himself as "Brian" answered the call, identified himself
as operations manager and said that HUNTER, the owner, was unavailable.
23. On or about January 13, 1998, the UC called one of Galaxy Sports'
toll-free numbers and asked to speak to CHESTER HUNTER. An individual
who identified himself as "Bill" said that HUNTER is in Dallas, and arranged
for the UC to speak with the general manager. An individual who identified
himself as "Brian" (who I believe to be BRIAN JANUS, the defendant), then
answered the call, and referred to himself as a "part owner" and "operations
manager." (Although BRIAN JANUS, the defendant, appeared in this conversation
to say that his last name is "Jones," in subsequent conversations he is
identified as BRIAN JANUS.) JANUS stated that HUNTER is the CEO and the
majority stockholder of Galaxy Sports. JANUS told the UC that although
Galaxy Sports' checks are written on checks of the Bank of Nevis, "they
may have a sister bank or some affiliation perhaps with, ahh, some banks
in the United States, perhaps like, uh, like in New York or the Bank of
Boston or something." JANUS also mentioned that he and all of the management
at Galaxy Sports are from the United States.
24. On or about February 4, 1998, the UC spoke to BRIAN JANUS, the defendant,
who said that he would have CHESTER HUNTER, the defendant, return the call.
25. Later that same day, I retrieved the following message left on an
answering machine attached to the undercover telephone number that had
been left for CHESTER HUNTER to call at the FBI's offices in New York,
"Uh, yes, uh, this is CHESTER HUNTER. I'm managing director of
Galaxy Sports returning a call, trying to determine what my well-paid,
well-trained staff can't do for you that I can. Anyway, give me a
call. I'll be glad to speak with you. I can be reached at 886-632-6739."
26. Later that same day, after receiving CHESTER HUNTER’s a message,
the UC attempted to reach HUNTER at the telephone number he left, but HUNTER
27. Later that same day, the UC called another of Galaxy Sports' toll-free
numbers and asked to speak with CHESTER HUNTERT the defendant. BRIAN
JANUS, the defendants got on the telephone and stated that he was the operations
manager. JANUS explained that "anything I say goes," and that HUNTER
had asked him to handle the bets made by the UC. JANUS also told
the UC that HUNTER was the "CEO" of the company, and that they service
almost 3,000 clients.
28. I have reviewed subscriber records for several of the toll-free
numbers used by Galaxy Sports, which reveal that all of the numbers are
provided by LCI International, an American
company. The subscriber to, three of the toll-f ree numbers is a company
located in Miami, Florida.
29. A review of the records for toll-free number (800) -835-7260 reveals
that the number was called thousands of times from locations all over the
United States, including numerous calls from New York, Now York.
I believe it is likely that many, if not all, of these calls, like those
from the UC, were from bettors (i) receiving information about sports betting
with Galaxy Sports or (ii) placing sports bets with Galaxy Sports.
30. I have been advised by an employee of LCI International that the
toll-free number (800) 730-5035 was called over 40,000 times between December
1997 to January 1998. 1 believe it in likely that many, if not all, of
those calls, like those from the UC, ware from bettors (i) receiving information
about sports betting with Galaxy Sports or (ii) placing sports bets with
31. An Internet search of interNIC4 lists CHESTER HUNTER, the defendant,
as "Administrative Contact" and "Billing Contact" for Galaxy Sports' website.
The InterNIC search also lists Galaxy Sports at an address in Dallas, Texas.
(InterNIC is a registry of domain names on the Internet. By executing
a command known as "WHOIS," it is possible to obtain information about
the companies and individuals who have registered particular domain names.)
According to other records I have located on the Internet, the e-mail address
listed for HUNTER is handled by a company located in Dallas, Texas.
32. I have reviewed records provided by the United States Customs Service
which reveal that an individual named "Cheater Hunter" has traveled to
Curacao 13 times in 1997 and one time in 1998.
WHEREFORE, deponent prays that warrants issue for the arrests of S.
CHESTER HUNTER and BRIAN JANUS, and that they be imprisoned or bailed
as the case may be.
Federal Bureau of Investigation