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 BUCHWALD United States Magistrate Judge
Southern District of New York
UNITED STATES OF AMERICA SEALED C0MPLAINT
-V-
Violation of
18 U.S.C. 371
DAVID BUDIN,
STEVE BUDIN and
SANDY BECHER,
Defendants.
COUNTIES OF OFFENSE:
NEW YORK AND ELSEWHERE
SOUTHERN DISTRICT OF NEW YORK, as.:
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 New York and elsewhere, DAVID BUDIN, STEVE BUDIN and SANDY
BECHER, the defendants,, and others known and unknown, unlawfully, wilfully
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 DAVID BUDIN, STEVE
BUDIN and SANDY BECHER, 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 contests, 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 bats and wagers, in violation of Title la,
United States Code, Section 1084.
OVERT ACTS
3. In furtherance of said conspiracy and to effect the object thereof,
DAVID BUDIN, STEVE BUDIN and SANDY BECHER, 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 6, 1998, SANDY BECHER the defendant, had a telephone
conversation with an undercover agent who was located in Now York, Now
York.
b. On or about January 22, 1996, -SANDY BECHER, the defendant, had a
telephone conversation with a different undercover agent who was located
in New York, Now 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 Is 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 SDB Global 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 SDB Global 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 palls Computer Crimes squad as 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 telephones and other data lines. The World Wide
Web ("WWW") Is a hypertext-based system that facilitates the ability to
find and access information on the' Internet. Many businesses, including
SDB
Global, 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 mite 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 SDB Global,
at www.sdbg.com. The SDB Global web site revealed the following:
a. SDB Global is a sports wagering service that
accepts bets on various sporting events, including football,
hockey, baseball and basketball.
b. SDB Global offers a toll free telephone number,
(888) 238-3279 -- which spells out "888-BET-EASY" -- to call for information
concerning sports betting and to place bets.
c. In order to bet with SDB Global, a bettor is required to open an
account (which could be done over the Internet) p and send a minimum deposit
of 11 500 American." The deposit could be sent via Western Union, Money
Gram, Visa, cashier's check or by bank wire transfer.
9. In or about the spring of 1997, an individual investigating sports
betting on the Internet ("Individual") accessed SDB Global's web site an
the WWW. Individual clicked on an icon on SDB Global's home page
and added Individual’s name to SDB Global's mailing list. Several
days later, individual received in Now York, New York, a letter and brochure
from SDR Global that advertised its Internet sports betting service.
Among other things, that promotional literature explained how to open an
account at SDB Global and described SDB Global's wagering limits.
The envelope in - which the letter and brochure wore 'sent bore the following
return address: "SDB Global, S.A., 82 Wall Street, New York, New York 10005."
In addition, the postage meter used on the envelope indicated that the
letter was stamped in New York, New York.
10. On or about October 15, 19970 an undercover FBI special agent posing
as a potential bettor (the "UC") called (888) BET-EASY. A person
who identified himself as "Paul" explained how a customer can open an account
with SDB Global. "Paul" also explained that SDB Global only accepts
wagers over the telephone and not over the Internet "to avoid problems
because in some states, uh, in the states, uh, there have been problems
with, uh, Internet wagering." The UC also requested that promotional literature
be mailed to an undercover address in New York, Now York.
11. On or about October 20, 1997, the UC received a letter from SDB
Global that contained the same promotional literature that Individual had
received several months earlier, as well as instructions on how to wire
money to SDB Global's bank account, which appears to be in Switzerland.
Those instructions direct customers to wire money to SDB Global via Bankers
Trust in New York, New York. The envelope in which SDB Global sent
the information bore a return address in Costa Rica. The postage
stamps, however, were from the United States. Postal Service, and
the letter was postmarked in Miami, Florida.
12. On or about November 19, 1997, the UC called (888) BET-EASY, SDB
Global's toll-free number, to set up a betting account and was transferred
to the customer service department. An employee in the customer service
department ("Employee #1") first asked what state UC was calling from.
When told New York, Employee #1 proceeded to set up the account and told
the UC that money could be sent via Western Union to the attention of "Mark
Cobb." Employee #1 gave the UC a personal identification number for
use in connection with the account. Employee #1 also told the UC
that SDB Global takes bets over the telephone only and does not accept
bets via the Internet or e-mail. Finally, Employee #1 explained that
the Internet can be used to check the betting lines.
13. Later that day, the UC sent $600 by Western Union from New York,
New York, to SDB Global, to the attention of "Mark Cobb," to open the account.
14. On or about November 21, 1997t the UC called (888) BET-EASY, SDB
Global's toll-free number, from the FBI offices in New York, New York,
and bet on two National Football League ("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 5 points, and $55 that the Jacksonville
Jaguars would beat the Cincinnati Bengals by more than 5.5 points.
The UC lost both bets.
15. On or about November 25, 1997, the UC called (888) BET-EASY,
SDB Global's toll-free number, from the FBI offices in New York, New York,
and bet on two NFL games scheduled to be played on 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 total points scored in
the Green Bay Packers vs. Minnesota Vikings game would be less than
45. The UC lost the first bet and won the second bet, and $50 in
winnings was credited to the UC's account with SDB Global.
16. On or about December 3, 1997, the UC called (888) BET-EASY, SDB
Global's toll-free number, from the FBI offices 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 with SDD Global.
17. During that telephone call, the UC requested that $100 of the money
in the UCI’s account be returned to the UC.
18. On or about December 6, 1997, the UC received a Federal Express
envelope in New York, New York, containing, a $100 check from an account
of "S.D.B. Global, Inc. - Bahamas," which was payable through a bank in
Miami, Florida. The return address on the Federal Express label indicated
that it was sent by "G. Mitchell" with SDB Global in North Miami
Beach, Florida. The label also listed an additional toll-free telephone
number. Telephone company records that I have reviewed indicate that
that toll-free number is subscribed to by SDB Global SA/ DAVID BUDIN, the
defendant, in Aventura, Florida.
19. On or about December 23, 1997, the UC called (888) BET-EASY, SDB
Global's toll-free number, from the FBI offices in New York, New York and
requested that the balance in the UC’s account be returned via bank wire.
"Ann" in the customer service department of SDB Global told the UC to fax
the bank wire instructions. "Ann" also told the UC that the owners of SDB
Global are STEVE BUDIN and DAVE BUDIN, the defendants. The UC then
asked to speak to a manager and was transferred to someone named "Mike."
The UC mentioned to "Mike" that he had received a brochure with a return
address in New York, and "Mike" told the UC that the brochure was probably
sent by "one of our marketers." "Mike" also told the UC that 'Steve" or
"Dave', was in Miami.
20. On or about January 6, 1998, the UC called (888) BET-EASY, SDB Global's
toll-free number, from the FBI offices in
New York, New York, and spoke to a person who identified himself as
the bookmaking manager. That person stated that STEVE BUDIN and
DAVID BUDIN, the defendants, are the owners of SDB Global.
21. Later that day, the UC called (888) BET-EASY, SDB Global's toll-free
number, from the FBI offices in New York, New York, and spoke to SANDY
BECHER, the defendant. BECHER identified himself as "one of the owners."
The UC asked BECHER if SDB Global had contacts in the United States, and
BECHER replied that "we have plenty of people all over the states and worldwide
that market for us." He also explained that "some of our marketing consultants
work out of Wall Street in New York City" and "that's probably where you
received the information from."
22,. On or about January 22, 1998, an FBI agent acting in an undercover
capacity ("UC-2") visited 82 Wall Street, New York, New York, the return
address listed on the envelope containing the SDB Global brochure that
Individual received last spring. When UC-2 entered the office, UC-2
mentioned that UC-2 wanted to speak. with someone about making a bet on
the Super Bowl, which was scheduled to be played later that week.
A woman named "Anna" stated that she did marketing for SDB Global but that
there was no one in the off ice at that time who could answer UC-2’s questions.
"Anna" then picked up the telephone, dialed (800) 649-1943, asked first
for "Steve" and then asked for "Sandy." "Anna" then handed the telephone
to UC-2. who proceeded to speak with an individual who identified himself
as SANDY BECHER, the defendant. BECHER told UC-2 that he is a lawyer
who is a member of the Florida bar and the American Bar Association.
BECHER then explained that SDB Global accepts money via certified check,
professional check or wire transfer, and that the company conducts its
banking business through two Florida-based employees of the Royal Bank
of Canada. UC-2 then asked what, the point spread was on the Super
Bowl, and BECHER replied that Green Bay was favored by 12 points.
BECHER then transferred UC-2 to an employee in the new account department
("Employee #2") to set up an account. Employee #2 then gave UC-2
a personal identification number for future betting transactions.
23. While UC-2 was in the office at 82 Wall Street, UC-2 picked up two
news releases issued on behalf of a company called Diversified Investors
Corporation, 82 Wall Street, New York, New York. The news releases,
both of which were dated December 24, 1996, state that Internet Marketing
Corp. is a subsidiary of Diversified Investors Corporation and "is the
marketing agent for SDB Global."
24. On or about February 12, 1998, the UC called (900) 649-1948 from
the FBI offices in New York, New York, and was transferred to one of the
bookmaking managers ("Employee #3"). Employee #3 said that he works
for STEVE BUDIN, the defendant, and that STEVE BUDIN owned the company.
The UC then told Employee #3 that the UC wanted to withdraw money from
the UC’s account, and Employee #3 transferred the call to the customer
service department. The UC then spoke to an employee and arranged
for the account balance of $380 to be sent in a bank check via Federal
Express to the UC's undercover address in New York, New York.
25. On or about February 23, 1998, the UC received a Federal Express
envelope at the undercover address in Now York, New York. The return
address listed on the label was "G. Mitchell, SDB GLOBAL, 82 WALL
ST, 8th FLR, NEW YORK, NEW YORK 10005. " Inside the envelope was a $380
check from an account of "S.D.B. Global, Inc. Bahamas," which was payable
through a bank in Miami, Florida.
26. A review of the Dun & Bradstreet report of SDB Global S.A. reveals
that the company is based in Miami, Florida, and that DAVID BUDIN, the
defendant, is the owner of the company.
27. A review of records relating to a toll-free number provided by SDB
Global an its fax number reveals that the subscriber of the number is SDB
Global S.A. in Avantura, Florida.
28. A review of records relating to the toll-free
numbers subscribed to by SDB Global (including (888) BET-EASY) reveals
that these numbers were called hundreds of times from locations all over
the United States, including numerous calls from New York, New 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 SDG Global or (ii) placing sports bets with SDB Global.
29. I have reviewed recent issues of two magazines, College & Pro
Football Newsweekly and Pro Football Weekly, which are distributed in the
Southern District of New York and elsewhere. Those magazines contain
several advertisements for SDB Global. Among the statements made in SDB
Global's advertisements are the following:
a. "Bet any sport…
Anytime… Anywhere."
b. "Pick up a phone and call our toll free number.
You can open your account on the spot."
c. "Account in private and secure. Not open to inquiry by
government agency."
d. "'Members only' internet access for up-to-the-minute scores/time
changes."
e. "Same bets, same odds, and the same payoffs as Las Vegas!"
f. "Virtually no limits
Call if over $300, 000.00."
30. 1 have reviewed information provided by the United States Customs
Service, which reveals that an individual named "David Budin" traveled
between Costa Rica and Miami one time in 1996, 13 times in 1997, and twice
in 1998; an individual named "Steve Budin" traveled between Costa Rica
and Miami three times in 1996, 16 times in 1997, and twice in 1998; and
an individual named "Sandy Becher" traveled between Costa Rica and Miami
five times in 1997 and once in 1998.
WHEREFORE, deponent prays that warrants issu6 for the arrests of DAVID
BUDIN, STEVE BUDIN and SANDY BECHER, and that they be imprisoned or bailed
as the case may be.
LISA J. FERENCE
Special Agent
Federal Bureau of investigation