FBI Complaints - Island Casino

11 March 1998

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.


Approved:
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
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UNITED STATES OF AMERICA

-V-

ALLEN ROSS,
MIKE SAUL and
ORIN SLEEPER,

Defendants.

Violation of
18 U.S.C. 371

SEALED COMPLAINT

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:
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COUNT ONE

1. From in or about 1997 , until on or about today's date, in the southern District of New York and elsewhere ALLEN ROSS, MIKE SAUL and ORIN SLEEPER, the defendants , 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, Section 1084.

2. It was a part and object of the conspiracy that ALLEN ROSS, MIKE SAUL and ORIN SLEEPER, 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.




Overt Acts

3 In furtherance of said conspiracy and to effect the object thereof, ALLEN ROSSR MIKE SAUL and ORIN SLEEPER, ORIN SLEEPER the defendants and others known and unknown, committed the following overt acts in the Southern District of York and elsewhere.

a. On or about August 19970 ORIN SLEEPER, the defendant, sent an e-mail to an undercover agent in New York, New York, providing instructions on sending a wire transfer through a bank in New York, New York, to open an account to engage in sports betting.

b. On or about November 13, 1997, ALLEN ROSS, the defendant sent an e-mail to an undercover agent in New York, New York, stating that a sports betting account had been activated.

c. On or about February 12, 1998, an undercover agent in Neow York, New York had a conversation with MIKE SAUL, the defendant, in which SAUL explained that he is the general manager of Island Casino and he runs the operation from "top to bottom. "

(Title 16, United States Code, Section 371.)

The bases for my knowledge and the foregoing charge are, in part, as follows:

4. I have been an FBI agent for two years. For the

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 set

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 Island 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 Island Casino was using the Internet or other forms 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 FBI's 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 Island Casino, 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 island Casino, at www.islandcasino.com. The Island Casino web site revealed the following:

a. Island casino is a sports wagering service that accepts bets on various sporting events, including football, hockey, baseball and basketball. Island Casino first started marketing in the fall of 1996 .

b. Island Casino offers a toll-free telephone number, (800) 211-2931, to call for information concerning sports betting and to place bets.

c. In order to bet with Island Casino, a bettor is required to open an account (which could be done over the Internet) , and send a minimum deposit of $50. The deposit could be sent via Mastercard, Visa, Western Union, certified check, money order or by bank wire transfer. The Internet site also stated that "Island Casino only operates with United States of America Dollars" and that "all customer funds stay in a US Dollar account."

9. On or about August 15, 1997, acting in an undercover capacity, I sent an a-mail from the FBI offices in New York, Raw York, to an address that Island Casino provided in its webuite for questions about their service and asked for bank wire instructions to open an account.

10. On or about August l5, 1997, 1 received a response from ORIN SLEEPER, the defendant, who identified himself as being on the "Help Desk" at Island Casino. SLEEPER's e-mail instructed me to send a wire transfer to ABN-Amro Bank in Now York for further credit to an ABN-Amro Bank account in Curacao. The e-mail also noted that Island Casino's "legal name" is Worldwide Wagering NV.

11. On or about October 20, 1997, an undercover FBI special agent posing as a potential bettor (the "UC"), called (600) 211-29310 Island Casino's toll-free number. Two different undercover agents were used during this investigation. (I will refer to both agents an the "UC" for purposes of this affidavit.) A person who identified himself an "John" explained, among other things, that island Casino has been in business for two years and how a customer can open an account with Island Casino. "John" also stated that the company is owned by an American and that they have a United States contact in Ohio. "John" then transferred the call to "Orin" (who I believe to be ORIN SLEEPER, the defendant), who explained how to wire money to Island Casino. "Orin" stated that the minimum deposit to open an account in $500, and that the minimum bet is $50 over the telephone and $10 over the Internet.

12. On or about November 13, 1997, the UC accessed island Casino's web site and set up a betting account by filling out a form over the Internet.

13. Later that same day, the UC sent $600 by Western Union from Now York, New York, to Island. Casino in Curacao, Netherland Antilles, to open the account.

14. Later that same day, the UC received an a-mail from ALLEN ROSS, the defendant, who identified himself as "Casino manager, Island Casino." ROSS's e-mail stated that the UC's Island Casino account had been activated and that $720 (which included a 20 percent bonus on the amount deposited) had been credited to UC's account.

15. On or about November 21, 1997, the UC called (800) 211-2931, Island Casino's toll-free number, from the FBI's office in New York, Now York and bet an two National Football League ("NFL") games scheduled to be played on November 23, 1997. The UC bet $55 that the Tampa Bay Buccaneers would beat the Chicago Bears by more than 5.5 points, and $55 that the Minnesota Vikings would not lose to the New York Jets by more than 1 point. The UC lost both bets.

16. On or about November 25, 1997, the UC called (800) 211-2931, Island Casino's toll-free number, from the FBI's office in New York, Now York, and bet on two NFL games scheduled to be played an November 27 and December 1, 1997. The UC bet $55 that the Dallas Cowboys would beat the Tennessee Oilers by more than 6.5 points, and $55 that the Philadelphia Eagles would beat the Cincinnati Bangals by more than 4.5 points. The UC lost both bets.

17. On or about Decemberber 3, 1997, the UC called (600) 211-2931, Island Casino's toll-free number, from the FBI's office in New York, New York, and bet on two NFL games scheduled to be played on December 7, 1997. The UC bet $55 that the Green Bay Packers would beat the Tampa Bay Buccaneers by more than 3.5 points, and $55 that the Philadelphia Eagles would beat the New York Giants by more than 4.5 points. The UC won the first bet and lost the second bet, and $50 in winnings was credited to the UC's account.

18. On or about December 22,.1997, the UC called (800) 211-2931, Island Casino's toll-free number, from the FBI's office in New York, Now York, and told an unidentified female who answered the phone that the UC wanted $495 returned from the UC's account.

19. On or about January 9, 1998i the UC received by DHL courier in Now York, Now York, a $495 check written on an account of ABN-Amro Bank that was payable through a bank in New York, New York. The return address on the DHL label indicated that it was sent from Island Casino in the Netherland Antilles.

20. On or about February 12, 1998, the UC called (800) 211-2931, Island Casino's toll-free number, from the FBI's office in New York,, New York, and spoke with a woman who identified herself as "Rebecca.." "Rebecca" stated that she is ORIN SLEEPER's assistant, that SLEEPER is the head of customer services, and that SLEEPER went back to the United States because he is having physical therapy on his feet. "Rebecca" also stated that MIKE SAUL, the defendant, is the General Manager of Island Casino. SAUL then got on the telephone and stated that he is the General Manager of Island Casino and that he in the second highest person in the company. SAUL added that he runs the operation from "top to bottom," explaining that he is like the CEO and that ALLEN ROSS, the defendant, is like the chairman of the board. SAUL added that ROSS and SAUL have been best friends for 20 years.

21. On or about February 27, 1998, acting in an undercover capacity as a bettor, I called (800) 211-2931, island Casino's toll-free number, from the FBI's office in New York, New York', spoke to "Orin" (who I believe to be ORIN SLEEPER, the defendant) and asked to speak with ALLEN ROSSO the defendant. SLEEPER told an that ROSS was not available and that ROSS would call me back at an undercover telephone number at an FBI office in Now York, Now York.

22. Later that day, I received a telephone call from ALLEN ROSS, the defendant, at the undercover telephone number at an FBI office in Now York, Now York. ROSS told me that he is a "casino manager" of Island Casino and other on-line sports wagering sites and that ORIN SLEZPER,, the defendant, is in charge of customer service for Island Casino. ROSS provided me with information to place bets with Island Casino. ROSS also advised me that Island Casino has been in business for "One and three-quarters years," has been "on-line" since March 1997, and has "thousands" of customers.

23. I have reviewed telephone records, which reveal that the toll-free number (800) 211-2931 is provided by LCI International, an American company. The subscriber on the account is World Wagering Network, located in Fairlawn, Ohio. A review of the telephone records also reveals that this number was called thousands of times from locations all over the United 'States, including numerous calls from Now 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 Island Casino or (ii) placing sports bats with Island Casino.

24. An Internet search of InterNIC lists ALLEN ROSS, the defendant, as "Administrative Contact" and "Billing Contact" for island Casino's websites. (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 ROSS on InterNIC is handled by a company located in Cleveland, Ohio.

25. 1 have been advised by an agent with the United States Customs Service that an individual named "Orin Sleeper" traveled to Curacao on five separate occasions in 1997.

WHEREFORE, deponent prays that warrants issue for the arrests of ALLEN ROSS, MIKE SAUL and ORIN SLEEPER, and that they be imprisoned or bailed as the case may be.

LISA FERENCE
Special Agent
Federal Bureau of Investigation