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:
JOSEPH V. DE MARCO
Assistant United States Attorney
Before:
HONORABLE HENRY B. PITMAN
United States Magistrate Judge
Southern District of New York
UNITED STATES OF AMERICA
-v-
LAURENCE R. STOFAN, Defendant
SEALED COMPLAINT:
Violation of
18 U.S.C. 371
COUNTIES OF OFFENSE:
NEW YORK AND ELSEWHERE
SOUTHERN DISTRICT OF NEW YORK, ss.:
JOSEPH A. LA TORRE, being duly sworn, deposes and says that he 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 17,
1998, in the Southern District of New York and elsewhere, LAURENCE R.
STOFAN, the defendant, 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 LAURENCE R. STOFAN,
the defendant, 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 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,
LAURENCE R. STOFAN, the defendant, and others known and unknown,
committed the following overt acts in the Southern District of New York
and elsewhere:
a. On or about March 12, 1998, LAURENCE R. STOFAN had two telephone
conversations with a with an undercover FBI 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 f or 3 years. 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 f or 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 only unless otherwise
indicated.
5. During the course of this investigation, I received information from
various sources that a business known as Global Sports Network ("GSN")
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 GSN 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.
6. Based on knowledge I obtained by speaking with various FBI agents
involved in the investigation of crimes committed through the use of
computers, I know that the Internet is 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 GSN, 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).
7. On or about March 12, 1998, using an undercover Internet account that
can be accessed at the FBI offices in New York, New York, another FBI
agent assigned to this case accessed the web site for GSN, at
http://199.95.251.71/gsn/. The GSN web site revealed, among other things, the following:
a. GSN is a sports wagering service that accepts bets on various
sporting events, including basketball.
b. GRC offers a toll-free telephone number, (888) GSN-1646, to call for
information concerning sports betting, and to open a betting account.
8. On or about March 12, 1998, an undercover FBI agent posing as a
potential bettor (the "UC") called (888) GSN-1646. A male who
identified himself as "Larry" answered the telephone and confirmed that
the UC had reached GSN. "Larry" stated that GSN accepted bets for
sporting events; that GSN requires a $300 minimum deposit to open an
account; that $25 was the minimum amount for a wager; and that the UC
could wager whatever amount he wanted—for example, $1000. "Larry"
stated that he was physically located in Cliffside Park, New Jersey, and
that GSN has a toll-free telephone number to allow its customers to
place bets. "Larry" added that the UC could open an account with GSN
using Western Union to transfer the funds to GSN; gave the UC Western
Union's toll-free number; and told the UC to direct Western Union to
wire the UC’s funds to an individual named "Pasquale Novello" in the
Dominican Republic. "Larry" further stated that after the UC had
obtained a control number from Western Union, the UC should call "Larry"
again, who would give the UC a toll-free telephone number in the
Dominican Republic where the bets would be placed. "Larry" stated that
the bets could not be placed in New Jersey.
9. Later that same day, the UC directed Western Union to send $300 to
"Pasquale Novello" in the Dominican Republic. Thereafter, the UC called
"Larry" again from the FBI office in New York City, as instructed, and
provided "Larry" with the control number for the Western Union $300
transfer. "Larry" then gave the UC telephone number (888) 889-2312;
told the UC to call that number; and instructed the UC on how to open
the wagering account. "Larry" also told the UC that he would be the
person to contact if the UC had any problems in connection with placing
the bets.
10. Later that same day, the UC, while in New York, New York, opened a
betting account with GSN by calling (888) 889-2312, and by providing
information to the person who answered the telephone. At that time, the
UC bet on three National Collegiate Athletic Association ("NCAA")
basketball games scheduled to be played the following day.
Specifically, the UC bet $25 that St John’s University would beat
Detroit-Mercy by more than 1 point; $25 that Clemson would not beat
Western Michigan by more than 8 points; and $25 that UCLA would not beat
Miami-.Florida by more than 6 points. The UC won two of the three bets
and lost one bet, and was credited approximately $23 as a result of
these three wagers.
11. On or about March 13, 1998, the UC called (888) 889-2312 from the
FBI offices in New York, New York, and, over the telephone, bet on two
National Basketball Association ("NBA") basketball games scheduled to be
played later that day. Specifically, the UC bet $50 that the Boston
Celtics would not beat the Detroit Pistons by more than 2 points, and
$25 that the Indiana Pacers would beat the Milwaukee Bucks by more than
12 points. The UC won both bets, and his GSN account was credited with
approximately $75.
12. On or about March 16, 1998, the UC called (888) 889-2312 from the
FBI offices in New York, New York and spoke with an individual who
identified himself as "Patrick." The UC discussed placing additional
bets with GSN, and asked to speak with the owner of GSN in connection
with placing these additional bets. In response, "Patrick" confirmed
that "Larry" from New Jersey—who the TJC had previously spoken to—was
the owner Of GSN.
13. In the course of my investigation of GSN, I obtained a copy of a GSN
informational brochure which had been mailed to Tampa, Florida. The
brochure listed GSN's return address as 234 Crescent Lane, Cliffside
Park, New Jersey 07010. On or about March 16, 1998, an FBI agent
assigned to the Newark field office drove by 234 Crescent Lane in
Cliffside Park. In front of that address, the agent observed a 1984
Cadillac Seville (the "Cadillac") with New Jersey license plates. A
check of that license plate number with the New Jersey Department Of
Motor Vehicles revealed that the Cadillac was registered to an
individual named LAURENCE R. STOFAN, the defendant, residing at 234
CreSCent Lane, Cliffside Park, New Jersey.
WHEREFORE, deponent prays that a warrant issue for the arrest of
LAURENCE R. STOFAN, and that he be imprisoned or bailed, as the case may
be.
JOSEPH A. LA TORRE
Special Agent
Federal Bureau of Investigation
Sworn to before me this
20th day of March, 1998
HENRY B. PITMAN
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK