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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SEALED
UNITED STATES OF AMERICA COMPLAINT
-V- Violation of
1a U.S.C. S 371
JAY COHEN and
STEVE SCHILLINGER,
Defendants.
COUNTIES OF OFFENSE:
NEW YORK AND ELSEWHERE
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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:
COUNT ONE
1. From in or about 1997, until on or about today's date, in the Southern
District of Now York and elsewhere, JAY COHEN and STEVE SCHILLING, 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 JAY
COHEN and STEVE SCHILLINGER, the defendants, and others known and
unknown,, being engaged in the business of betting and wagering,
unlawfully, wilfully and knowingly, would and did use a wire communication
facil-ity 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 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, JAY COHEN and STEVE SCHILLINGER, 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 May 10, 1997, STEVE SCHILLINGER the defendant, had a
telephone conversation with a private investigator in New York posing as
a potential bettor.
b. In or about December 1997, an employee of World Sports Exchange in
Antigua sent a $200 check by Federal Express to an undercover agent in
Now York, New York, posing as a bettor.
c. On or about December 8, 1997 JAY COHEN the defendant, had a telephone
conversation with an undercover agent in Now York, Now York.
(Title 28, 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 f or two years. For the past 15 months,
I have been a member of the FBI's Computer Crisis 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 World Sports Exchange, Ltd. ("World Sports Exchange")
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 World Sports Exchange was using the Internet or other
forms of wire communication facilitate 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 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”) is a hypertext-based system that facilitates the ability to
find and access information on the Internet. Many businesses, including
World Sports Exchange, 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 New York, New York, I accessed the web site for World Sports
Exchange, at www.wsex.com. The World Sports Exchange web site revealed
the following:
a. World Sports Exchange is a sports wagering service that accepts bets
on various sporting events, including football, hockey, baseball, and basketball.
The web site included “lines," or point spreads on various sporting events.
b. World Sports Exchange offers a toll-free telephone number, (800)
655-9739, to call for information concerning sports betting. In addition,
the web site indicated that sports bets could be placed with World Sports
Exchange through its web site, by using a computer.
c. In order to bet with World Sports Exchange, a bettor is required
to open an account (which could be done over the Internet), and send a
minimum deposit of $300. The deposit could be sent via Western Union
(to World Sports Exchange, care of JAY COHEN, the defendant, on the Caribbean
island of Antigua) , bank check or by bank wire transfer.
9. On or about October 7, 1997, an undercover FBI special agent posing
as a potential bettor (the “UC”) called (800) 655-97390 the toll-free number
for World sports Exchange. An unidentified male ("UM") answered the
telephone by stating "World
Sports Exchange." The UM proceeded to give the UC various
information designed to assist the UC to place a bet with World
Sports Exchange. The UM stated that World Sports Exchange
required a minimum bet of $10 if the bet in placed over the Internet
(except for $5 bets on "parlays") and a minimum bet of $50 for telephone
wagers. The UM added that World Sports Exchange would accept payment
via Western Union or a bank wire.
10. On or about October 16th 1997, the UC, while in New York, New York
opened a betting account with World Sports Exchange by accessing World
Sports Exchange's Internet site and by filling out a form located on that
site. Later that day, the UC sent $500 by Western Union in New York,
New York, to World sports Exchange in Antigua, to meet the minimum deposit
requirement of World Sports Exchange.
11. On or about October 17, 1997 the UC accessed World Sports Exchange's
web site, reviewed point spreads listed on the site, and placed three bets
by clicking various items on the site. The UC bet on three 'National
Football League ("NFL") games scheduled to be played on October 19, 1997.
The UC bet $55 that the Philadelphia Eagles would beat the Arizona Cardinals
by more than 8 points, $11 that the total points scored in the Jacksonville
Jaguars vs. Dallas Cowboys game would be less than 43, and $44 that the
Dallas Cowboys would beat the Jacksonville Jaguars by more than 4.5 points.
The UC lost all three bets.
12. On or about October 24, 1997, the UC accessed World Sports Exchange's
web site from a computer located in New York, New York, reviewed point
spreads listed 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
October 26, 1997. The UC bet $55 that the Denver Broncos would beat
the Buffalo Bills by more than 7 points, and $55 that the Philadelphia
Eagles would beat the Dallas Cowboys (there was no point spread).
The UC won the second of those two bets, and $50 in winnings was credited
to the UC’s account with World Sports Exchange.
13. On or about October 31, 1997, the UC accessed World Sports Exchange's
web site from a computer located in New York, New York, reviewed point
spreads listed 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 2, 1997. The UC bet $55 that the San Francisco 49ers would
beat the Dallas Cowboys by more than 7 points, and $55 that the New England
Patriots would beat the Minnesota Vikings (there was no point spread).
The UC tied the first bet and lost the second bet, and $55 was credited
to the UC’s account with World Sports Exchange.
14. On or about November 7, 1997, the UC accessed World Sports Exchange's
web site from a computer located in New York, New York, reviewed point
spreads listed 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 9, 1997. The UC bet $55 that the total points scored in
the Arizona Cardinals vs. Dallas Cowboys game would be lose than 38.5 points,
and $55 that the New York Giants would not lose to the Tennessee oilers
by more than three points. The UC won the first of those two bets,
and $50 in winnings was credited to the UC’s account with World Sports
Exchange.
15. On or about November 14, 1997, the UC called World Sports Exchange's
toll-free number, (800) 655-9739, from the FBI offices in New York, New
York, and placed two bets over the telephone. The UC bet on two National
Hockey League (“NHL”) games scheduled to be played later that day.
The UC bet $50 to win $52.50 that the Philadelphia Flyers would beat the
Florida Panthers, and $60 to win $50 that the Now Jersey Devils would beat
the Colorado Avalanche. The UC won both bets, and $102.50 in winnings
was credited to the UC's account with World Sports Exchange.
16. On or about December 3, 1997, the UC called World Sports Exchange's
toll-free number, (800) 655-9739, and requested that $200 of the money
in the UC’s account be returned to the UC. On or about December 8,
1997, the UC received by Federal Express a $200 check, which was payable
through the Chase Manhattan Bank in New York, New York.
17. On or about December 8, 1997, a UC placed a call to (268) 480-3888,
and asked for JAY COHEN the defendant. The UC proceeded to have a
consensually-recorded telephone call with COHEN, during which COHEN admitted
that he was president and one of the owners of World Sports Exchange.
18. On or about December 12, 1997, the UC called World Sports Exchange's
toll-free number, (800) 655-9739, and requested that the remainder of the
money in the UC's account be returned to the UC. On or about December
16, 1997, the UC received by Federal Express a $167.50 check, which was
written on a check from the Chase Manhattan Bank in New York, New York.
The check was accompanied by a letter from "Jay Cohen, President" that
stated: "Thank you for playing at The World Sports Exchange.”
19. I have reviewed various newspaper articles in which both JAY COHEN
and STEVE SCHILLINGER, the defendants,, are quoted in connection with their
business, World Sports Exchange.
20. I have spoken with a private investigator (the "PI') (not working
at the direction of the FBI), who told me that on or about May 10, 1997
the PI made a consensually-recorded telephone call with STEVE SCHILLINGER,
the defendant, at (800) 655-9739. I have reviewed a tape and draft
transcript of that call and have learned the following:
a. The male who answered the telephone identified himself an STEVE SCHILLINGER,
and asked the caller if he had read about World Sports Exchange in the
Wall Street Journal.
b. SCHILLINGER stated that he was one of the partners of World Sports
Exchange and that he was from San Francisco, where he worked on the Stock
Exchange.
c. SCHILLINGER told the PI that he could do all of his betting with
World Sports Exchange either over the telephone or through a computer.
d. SCHILLINGER told the PI that when World Sports Exchange has to pay
winning betters, it sends checks cut on a “New York” bank, Chase Manhattan
Bank.
e. SCHILLINGER told the PI that World Sports Exchange had approximately
400 customers, and that 150 of them were from New York.
21. I have reviewed telephone records, which reveal that (800)
655-9739 is a toll-free number provided by LDDS World Communications, a
telephone company located in Mississippi. The subscriber name for
(800) 655-9739 is Post Time Sports Ltd., 115 Perimeter Ctr., Suite 130,
Atlanta, Georgia, 30346.
22. The review of the telephone records of (800) 655-9739 also
reveals that this number was called thousands 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 these
from the UC, were from bettors (i) receiving information about sports betting
with World Sports Exchange or (ii) placing sports bets with World Sports
Exchange.
23. I have reviewed bank records relating to World Sports Exchange,
which reveal that numerous customers have wire-transferred thousands of
dollars from the United States, through Chase Manhattan Bank in New York,
New York,, to a bank account in the name of World Sports Exchange at Swiss
American Bank Ltd. in Antigua.
24. I have reviewed Pro Football Weekly, a magazine distributed in,
among other places, the Southern District of New York, which contains advertisements
for World Sports Exchange. One ad suggests that consumers "bet football
on-line at the World Sports Exchange," which, according to the ad, would
make a "good use for the Internet."
25. I have reviewed correspondence which reveals that World Sports Exchange
used an advertising agency in San Francisco, California, to coordinate
the placing of its advertisements in Pro Football Weekly magazine.
WHEREFORE, deponent prays that warrants issue for the arrests of JAY
COHEN and STEVE SCHILLINGER, and that they be imprisoned or bailed as the
case may be.
LISA FERENCE
Special Agent
Federal Bureau of Investigation