March 26 was D-Day for the next rash of criminal complaints against online
gaming operators. Another 7 individuals were targeted and IGN is offering
you the complaints against those folks as well as the full text of the US
Attorney's news release on the matter.
Approved:
THOMAS C. RUBIN and DANIEL C. BECKER
Assistant United States Attorneys
Before:
HONORABLE SHARON E. GRUBIN
United States Magistrate Judge
Southern District of New York
UNITED STATES OF AMERICA
-v-
BILL MOORE, a/k/a "Winston," Defendant
SEALED COMPLAINT:
Violation of
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:
COUNT ONE:
1. From in or about 1998, up to and including on or about March 18,
1998, in the Southern District of New York and elsewhere, BILL MOORE,
a/k/a "Winston," the defendant, co-conspirators S. Chester Hunter and
Brian Janus, a/k/a Brian "Jones," 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 BILL MOORE, a/k/a
"Winston," the defendant, co-conspirators S. Chester Hunter and Brian
Janus, a/k/a Brian "Jones," and others known and unknown, 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 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,
BILL MOORE, a/k/a "Winston," the defendant, and others known and
unknown, committed the following overt act in the Southern District of
New York and elsewhere:
a. On or about March 6, 1998, BILL MOORE, the defendant, told an
undercover FBI agent in New York, New York, how to open a sports
betting account.
b. On or about March 17, 1998, BILL MOORE, the defendant, told a
different undercover FBI agent in New York, New York, how to open a
sports betting account and provided the undercover agent with the
betting lines on eight NCAA basketball games scheduled to be played
later that week.
(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 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 (which has claimed to be located in Curacao) is 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. As a result of the investigation,
on March 2, 1998, I swore out a complaint and obtained arrest warrants
charging S. Chester Hunter and Brian Janus, a/k/a Brian "Jones," who are
owners of Galaxy Sports, with conspiracy to violation Title 18, United
States Code, Section 1084. A copy of that complaint, which is
incorporated by reference herein, is attached as Exhibit 1.
7. On or about March 4, S. Chester Hunter was arrested in Dallas,
Texas. On that same date, I called Brian Janus, a/k/a "Brian Jones,"
and advised him that an arrest warrant has been issued against him.
Janus has not yet surrendered.
8. Since that time, FBI agents have been monitoring Galaxy Sports’ web
site on the Internet and its toll-free telephone numbers and have
determined that it has continued to operate in the sports betting
business and has continued to use wire communication facilities in
interstate and foreign commerce to facilitate that business.
9. On or about March 6, 1998, an undercover FBI special agent posing as
a potential bettor (the "UC-1"), called (800) 730-5035, one of Galaxy
Sports’ toll-free numbers, from the FBI offices in New York, New York,
spoke to an employee of Galaxy Sports, and asked for information about
setting up an account to bet on a sporting event. The Galaxy Sports
employee told the UC-1 to call a different toll-tree number, (800)
497-2331, and ask for "Bill."
10. A short time later, the UC-1 called (800) 497-2331, asked for
"Bill," and spoke to an individual who identified himself as BILL MOORE,
the defendant. MOORE told the UC-1 that a minimum deposit of $500 is
required to open an account. MOORE said that Galaxy Sports has a
toll-free number so that customers can find out their account balance,
got the latest betting lines, and place bets. When the UC-1 mentioned
that he wanted to place bets on the NCAA tournament, MOORE stated:
“Absolutely. Sure. We’ve taken a ton of it already today. If you want
to play tonight, I’ve got a huge board to select from.” MOORE told the
UC-1 that Connecticut was favored by 12 points against Rutgers. MOORE
also told the UC-1 that the UC-1. could wire money to open an account,
or MOORE could open an account in ten minutes if the UC-1 had a Visa
card.
11. On or about March 17, 1998, another undercover FBI special agent
posing as a potential bettor (the "UC-2") . called (800) 497-2321,
Galaxy Sports’ toll-free number from the FBI offices in New York, New
York, and spoke to BILL MOORE, the defendant. MOORE told the UC-2 that
he handles all new accounts and that the easiest way to open an account
is with a Visa card and a $500 minimum deposit. MOORE told the UC-2
that Galaxy Sports also accepts Western Union money transfers, but
"don’t tell them [Western Union] that you arc sending money to an
offshore sportsbook." (I have been advised that Western Union recently
terminated service to Galaxy Sports because of its illegal sports
betting business. Therefore, I believe that Bill MOORE, the defendant,
directed the UC-2 not to tell Western Union that the UC-2 was sending
the money to an offshore sportsbook because MOORE knew Western Union
would not process that illegal wire transmission.) MOORE asked the
UC-2 for a password for the account, and for the UC-2’s address and
telephone number. The UC-2 gave MOORE an undercover address and phone
number in New York, New York. MOORE stated that Galaxy Sports has 2,700
clients during the basketball season, and he gave the UC-2 the betting
lines on the eight NCAA basketball games scheduled for later in the
week. MOORE also stated that Galaxy Sports accepts bets only over the
telephone and not over the Internet.
12. The UC-2 then arranged for $500 to be sent to Galaxy Sports via
Western Union, pursuant to the instructions that BILL MOORE, the
defendant, had provided.
13. On or about March 18, 1998, the UC-2 called (800) 497-2331, Galaxy
Sports’ toll-free wagering line, from the FBI offices in New York, New
York, and spoke to BILL MOORE, the defendant, who initially identified
himself as “Winston.” The UC-2 told MOORE that he had transferred $500
into an account at Galaxy Sports, and MOORE opened up a betting account
with a credit of $593 (representing the $500 deposit plus $43 in
transfer fees and a $50 bonus) - The UC-2 then placed bets over the
telephone on three games scheduled to be played later that day. The UC-2
bet $55 to win $50 that Georgia Tech would not beat Penn State by more
than seven points, $55 to win $50 that Minnesota would beat Marquette by
more than six points, and $50 to win $58 that the Ottawa Senators would
not beat the New York Islanders by more than .5 goals. The UC2 won the
first and third bets and lost the second bet, and $52 in winnings was
credited to the UC-2’s account with Galaxy Sports.
WHEREFORE, deponent prays that a warrant issue for the arrest of BILL
MOORE, and that he be imprisoned or bailed as the case may be.
LISA J. FERENCE
Special Agent
Federal Bureau of Investigation
Sworn to before me this
day of March, 1998.
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK