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 NA0MI REICE BUCHWALD
United States Magistrate Judge
Southern District of New York
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UNITED STATES OF AMERICA SEALED COMPLAINT
-V- violation of
18 U.S.C. 371
BRAD COHEN and
JASON PERRY,
Defendants.
COUNTIES OF OFFENSE:
NEWYORK AND ELSEWHERE
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SOUTHERN DISTRICT OF NEW YORK, SO.:
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:
COUNT ONE
1. From in or about 1997, until on or about today’s date, in the Southern
District of Now York and elsewhere, BRAD COHEN and JASON PERRY, 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 BRAD COHEN and JASON
PERRY, 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 18,
United States Code, Section 1084,
OVERT ACTS
3. In furtherance of said conspiracy and to effect the object
thereof, BRAD COHEN and JASON PERRY, the defendants, and others known and
unknown, committed the following overt acts in the southern District of
Now York and elsewhere:
a. On or about November 7, 1997, JASON PERRY,
the defendant, sent an e-mail. to an undercover agent in New York, New
York.
b. On or about December 12, 1997, an undercover
agent in Now York,
New York, had a telephone conversation with BRAD COHEN, the defendant,
who was located in Colorado.
c. On or about December 15, 1997, BRAD COHEN,
the defendant, sent an e-mail to an undercover agent located in New York,
New York.
(Title 18, 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 Real Casino 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 Real 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 an my experience on the FBI’s Computer Crimes squad as well
as various publications I have read, I know that the Internet in an immense
worldwide computer network used by millions of individuals daily.
The Internet is 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
Real 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 (such as 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 Now York, Now
York, I accessed the web site for Real casino, at www.realcamino.com. The
Real Casino web site revealed the following:
a. Real Casino is a sports wagering service that accepts bets on various
sporting events, including football, hockey, baseball and basketball.
Bets could be placed via the Internet web site or over the telephone.
b.
In order to bet with Real Casino a bettor is required to open an account
(which could be done over the Internet), and send a minimum deposit of
$100. The deposit could be sent via Western Union, cashier's check,
money order or by bank wire transfer (to the Bank of Nova Scotia, New York
Agency, New York, Neow York, for credit to Scotianbank de Costa Rica S.A.,
for further credit to Informacion Real, S.A.).
9. On or about October 14, 1997, an undercover FBI special agent posing
as a potential bettor (the “UC”) -Li called Oil506-256-7300, the
telephone number of Real Casino in Costa Rica. A man who identified
himself as "Ronny" answered the telephone by, statinq that the UC had reached
the Casino Real and Sportabook. "Ronny" proceeded to give the UC
various information designed to assist the UC to place a bet with Real
Casino. "Ronny" told the UC that Real Casino's 'United States contact
was BRAD COHEN, the defendant, who could be reached in Colorado at (970)
476-0006t and that the president of the company was JASON PERRY, the defendant.
'$Ronny" added that COHEN would provide the UC with odds and whatever information
the UC needed to place bets. "Ronny" stated that Real- Casino required
a deposit of $100, and that there is a minimum hot of $10 if the bet is
placed over the Internet and a minimum bet of $50 for telephone wagers.
"Ronny" added that Real casino would accept payment via Western Union or
a bank wire, and stated that a bank wire should be sent to Chase Manhattan
Bank in Now York, Now York,.for credit to the Continental Bank of Panama,
for further credit to Real Casino.
10. On or about October 16, 1997, the UC, while in New York, New
York, opened a betting account with Real Casino by accessing Real Casino's
Internet site and by filling out a form located an that site.
11. On or about October 17, 1997,
the UC sent $500 by Western Union to meat the minimum deposit requirement
of Real Casino. The Western Union transfer was made out to "Informacion
Real."
12. On or about October 18, 1997, the UC received an email from
JASON PERRY, the defendant, who identified himself as "Sports Book Director"
of Real Casino, confirming that the $500 Western Union transfer had arrived.
The a-mail offered a toll-free telephone number, (800) 659-8007, for placing
bets.
13. On or about October 24, 1997, the UC accessed Real Casino's web
site from a computer located in Now York, Now York, reviewed point spreads
listed on the site, and placed two bets by clicking various items on the
site. The UC bet on two National Football League ("NFL") games scheduled
to be played on October 26, 1997. The UC bet $55 that the Minnesota
Vikings would not lose to the Tampa Bay Buccaneers by more than 3 points,
and $55 that the total points scored in the Buffalo Bills vs. Denver
Broncos game would be more than 42.5. The UC won both bets, and $100 in
winnings was credited to the UC's account with Real casino.
14. On or about October 31, 1997, the UC accessed Real Casino's
web site from a computer located in Now York, New York reviewed point spreads
found on the site and placed two bets by clicking various items on the
site. The UC bet on one National Basketball Association ("NBA") game
scheduled to be played on that same day and on one NFL game scheduled to
be played on November 2, 1997. The UC bet $55 that the Philadelphia
76ers would not lose to the Milwaukee Bucks by more than 1 point, and $55
that the Philadelphia Eagles would beat the Arizona Cardinals by more than
4 points. The UC lost both games.
15. On or about November 7, 1997, the UC accessed Real
Casino's web site from a computer located in New York, Now York, reviewed
point spreads found an the site, and placed two bets by clicking various
items on the site. The UC bet on one NEA game scheduled to be played
that day and on one NFL game scheduled to be played on November 9, 1997.
The UC bet $55 that the Los Angeles Lakers would beat the Now York Knicks
by more than 4.5 points, and $55 that the Denver Broncos would beat the
Carolina Panthers by more than 7 points. The UC won both bets, and
$'100 in winnings was credited to the UC's account with Real Casino.
16. on or about November 7, 1997 the UC received an e-mail from JASON
PERRY, the defendant, which listed his e-mail address as "jazonpgraalcasino.com.
" The e-mail, which was signed "JP, " provided information on getting Real
Casino to refund the western union transfer fee that the UC had paid.
17. On or about November 14, 19970 the UC accessed Real Casino's web
site from a computer located in New York, New York, reviewed point spreads
found on the site, and placed two bets by clicking various items on the
site, The UC bet on two NFL games scheduled to be played on November 16,
1997. The UC bet $55 that the Seattle Seahawks would beat the New
Orleans saints by more than six points, and $55 that the Pittsburgh Steelers
would beat the Cincinnati Bengals by more than 9 points. The UC lost
the first bet and won the second bet, and $50 in winnings was credited
to the UC’s account with Real Casino.
18. on or about November 21, 1997, the UC called telephone number 011-506-256-7300
from the FBI offices in New York-, Now York, and placed two beta over the
telephone. The UC bet an two NFL games scheduled to be played on
November 23, 1997. The UC bet $55 that the Tampa Say Buccaneers would
beat the Chicago Bears by more than 6 points, and $55 that the Minnesota
Vikings would not lose to the Now York Jets by more than I point.
The UC lost both bets.
19. I have reviewed telephone records, which reveal that telephone number
(970) 476-0006, which the UC was given to contact 13RAD COHZN, the defendant
in Colorado, in a telephone number in Vail, Colorado that is subscribed
to by Pangaea Systems LLC, 500 East Lionshead Circle 31, Vail, Colorado
81657. The billing information for that telephone number lists both
of the defendants, BRAD COHEN and JASON PERRY.
20. 1 have reviewed other telephone records, which reveal that telephone
number (800) 659-8007 is a toll-free number provided,' by Frontier Communications
Services Inc. The subscriber for this toll-free number is Informacion
Real, S.A., with an address of 500 E Lionshead Vail, Colorado 81657.
The subscriber name on the account in BRAD COHEN, the defendant, with the
telephone number (970) 476-0006. A further review of the telephone
records of (800) 659-8007 reveals that this number was called hundreds
of times from locations all over the United States, including numerous
calls from Manhattan and from the Bronx. believe it in likely that many,
if not all, of these calls, like those from the UC,, were from bettors
(i) receiving information about sports betting with Real Casino or (ii)
placing sports bets with Real Casino.
21. 1 have reviewed several newspaper articles in
which BRADM COHEN and JASON PERRY, the defendants, are quoted in
connection-with their business, Informacion Real.
22. On or about December 12, 1997, the UC placed a call from New
York, New York to (970) 476-0006, and asked for BRAD COHEN, the defendant.
COHEN answered the telephone "Real," and the UC proceeded to have a consensually-recorded
conversation with him, during which the following occurred:
a. The UC identified himself as a customer of Real casino and asked
about getting money back from his account.
b. COHEN identified himself as one of the managers of "Real." COHEN
identified JASON PERRY, the defendant, as, variously, "the overall manager,"
"one of the principals," and "the main person." COHEN said that the company
in all employee-owned, and that COHEN himself owns a part of the company.
c . COHEN said that PERRY manages the whole betting operation and is
presently in Costa Rica. COHEN said that JASON PERRY's e-mail address
is "Jasonp@realcasino.com."
d. COHEN staid that the company performs marketing from the United States.
The office in Colorado is an office that handles marketing and software
work for the company.
e. COHEN stated that the company has customers
in the United States and elsewhere.
f. COHEN told the UC that he would send an a-mail
detailing how the UC could geot his money back from his account.
23. On or about December 15, 1997, the UC received an e-mail from
"bbrad@realcasino.com," which further identified the sender as "Brad C."
The e-mail provided "information on withdrawing funds" and was signed
"Brad."
24. Later that day, I accessed Real Canino’s web site at www.realcalaino.com
and requested a bank wire transfer of the balance of my account with Real
Casino. On December 17, 1997, the UC received a wire transfer of
$487 in an undercover bank account. The wire transfer was received from
the Chase Manhattan Bank in New York, Now York, and the originating bank
of the wire transfer was Banco Continental in Panama.
25, 1 have reviewed records from the United States Customs Service,
which reveal that an individual named "Brad Cohen" traveled from Costa
Rica to the United States in 1997.
WHEREFORE, deponent prays that warrants arrests of BRAD COHEN
and JASON PERRY, and that they be imprisoned or bailed as the case may
be.
LISA J. FEFENCE
Special Agent
Federal Bureau of Investigation
sworn to before me this
day of March, 1998
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK