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-
WILLIAM SCOTT a/k/a "Billy Scott" a/k/a "Bill Scott, " and
JESSICA DAVIS
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 18,
1998, in the Southern District of New York and elsewhere, WILLIAM SCOTT,
a/k/a "Billy Scott," a/k/a "Bill Scott, " and JESSICA DAVIS, 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 WILLIAM SCOTT, a/k/a
"Billy Scott," a/k/a "Bill Scott, " and JESSICA DAVIS, 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 bets and wagers, in violation of
Title 18, United States Code, Section 1084.
OVERT ACT:
3. In furtherance of said conspiracy, and to effect the object thereof,
WILLIAM SCOTT, a/k/a "Billy Scott," a/k/a "Bill Scott, " and JESSICA
DAVIS committed the following overt act in the Southern District of New
York and elsewhere:
a. On or about March 17, 1998, WILLIM SCOTT, a/k/a "Billy Scott," a/k/a
"Bill Scott" had a telephone conversation 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 World Wide Tele-Sports
("WWTS") 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 WWTS 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 WWTS, 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 WWTS, at
http://www.wwrs.com. The WWTS web site revealed, among other things, the following:
a. WWTS is a sports wagering service that accepts bets on various
sporting events.
b. WWTS offers a toll-free telephone number, (800) 555-2902, 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 (800) 555-2902. An unidentified male
("C1") answered the telephone and confirmed that the UC had Reached
WWTS. C1 stated that WWTS accepted bets for sporting events; that WWTS
requires a $500 minimum deposit to open an account; and that $50 was the
minimum wager amount. C1 added that the UC could open an account with
WWTS using Western Union to transfer the funds to WWTS; and told the UC
to direct Western Union to wire the UC’s funds to British American
Insurance in Antigua. C1 further stated that after the UC had obtained
a control number from Uestern Union, the UC should call WWTS back to
obtain a personal identification number ("PIN") which would enable him
to place bets.
9. Later that same day, the UC directed Western Union to send $500 to
British American Insurance in Antigua. Thereafterm the UC called WWTS’s
(800) 555-2902 toll-free number from the FBI office in New York City,
and provided the WWTS representative who answered the phone ("C2") with
the control number for the Western Union $500 transfer. In that same
conversation, the UC, opened a betting account with WWTS. C2 also
provided the UC with two toll-free numbers, (800) 203-4203 and (800)
203-8188, which the UC could call to place bets with WWTS.
10. In a subsequent conversation later that same day, placed by the UC
to one of WWTS’s toll-free betting numbers from the FBI offices in New
York, New York, the UC bet on three National Collegiate Athletic
Association ("NCAA") games scheduled to be played the following day.
Specifically, the UC bet $50 that St. John’s University would beat
Detroit-Mercy by more than 1.5 point; $50 that Clemson would not beat
Western Michigan by more than 8 points; and $50 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 $45 as a result of
these three wagers.
11. On or about March 13, 1998, the UC called one of WWTS’s toll-free
betting numbers and, over the telephone, bet on one National Basketball
Association ("NBA") basketball game 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 3 points. The UC won the bet, and
his WWTS account was credited with approximately $50.
12. On or about March 16, 1998, the UC called one of WWTS’s toll-free
betting numbers from the FBI offices in New York, New York, and spoke
with an individual ("C3"). The UC discussed concerns with bets he had
placed with WWTS, and asked to speak with the owner of WWTS. In
response, C3 offered to put UC in touch with "the boss," but later
stated that "the boss" was presently busy and could not speak to UC. UC
asked for the name of "the boss"; C3 responded that "the boss" was
"Billy Scott."
13. In the course of my investigation of WWTS, I reviewed excerpts of a
newspaper article which appeared in the sports section of the Atlanta
Journal and Constitution on or about December 28, 1997, concerning
telephone/Internet sports betting. The article describes the business
operations of several business engaged in telephone/Internet sports
betting, including the business operations of WWTS. In particular, the
article describes Billy Scott as the "maestro of World Wide Tele-sports.
" In addition, in the course of my investigation, I reviewed excerpts
of a newspaper article which appeared in the Pittsburgh Post-Gazette on
or about August 13, 1997, concerning, among other things, WWTS's
involvement in gambling activities; this article identified William
Scott as the owner of WWTS. Finally, I have also reviewed excerpts of a
newspaper article which appeared in the St. Petersburg Times on or about
November 16, 1997, concerning offshore gambling through the Internet,
This article describes WWTS as being engaged in the business of Internet
gambling, and further describes WWTS as "a burgeoning cyber-casino and
sports betting company owned by Bill Scott, an American."
14. On or about March 17, 1998, the UC called one of WWTS’s toll-free
betting numbers from the FBI offices in New York, New York, and asked
the woman who answered the telephone ("C4") if he could speak to the
owner, which the UC said he thought was "Billy Scott." C4 confirmed
that "Bill Scott" was the owner, and transferred the UC’s call to
another woman ("C5"). C5 asked the UC why he wanted to speak with
SCOTT; the UC said that he wanted to be sure that there would be no
problem placing bets, because the UC had heard that other betting houses
had experienced legal problems. C5 assured the UC that there would be
no problem placing bets, since WWTS was owned by Antiguan investors and
operated by Antiguan individuals. C5 confirmed to the UC that she was
in charge at WWTS. The UC continued to ask to speak with SCOTT, and C5
connected UC's call to SCOTT.
15. When the UC spoke with SCOTT, SCOTT denied being the owner or
proprietor of WWTS, but stated to the UC that he was the person who was
"sitting at the front desk" at WWTS at that time. SCOTT added that WWTS
was owned by unnamed trustees who were Antiguan, and that WWTS employed
over 100 individuals. The UC expressed his concern about having lost
money following the shutdown of SDB two weeks earlier; SC0TT stated to
the UC that he had heard that SDB paid all of the persons to whom SDB
owed money.
16. Later that same day, the UC called one of WWTS Is toll-free betting
numbers from the FBI offices in New York, New York, and asked to speak
to the woman who he had previously spoken with who told the UC that she
was in charge (i.e. C5); the person to whom the UC spoke (C6) confirmed
that "Jessica" was in charge, and connected UC to "Jessica." When the UC
spoke to "Jessica," Jessica" denied being in charge, but recalled
speaking to the UC previously. Among other things, the UC and
"Jessica' discussed opening a betting account of approximately
$120,000; Jessica told the UC that WWTS's operations director would call
the UC back to discuss this subject.
17. Later that same day, "Jessica" called the UC at the UC's undercover
telephone number in New York, New York to discuss the UC's desire to
open a betting account of approximately $120,000 at WWTS. Jessica told
the UC that WWTS could not accept wager amounts that large; that the
maximum wager WWTS accepted was $1000; and that she would have to check
to determine whether a bettor could open a betting account of $120,000
through which bets could be placed.
18. In the course of my investigation, I reviewed a videotape of a news
telecast broadcast by WPTV-NBC of West Palm Beach, Florida in or about
October 1997 concerning offshore betting through the Internet. The
island of Antigua was featured in the telecast as one place where such
offshore wagers could be made; WWTS was featured as a firm which
accepted wagers. In the course of this telecast, JESSICA DAVIS, the
defendant, of WWTS, discussed WWTS's casino gambling operations. Based
on my review of this videotape, and the audio tapes of the UC's
conversations with "Jessica" referred to above, the "Jessica" in the
audio tapes appears to be the same "JESSICA DAVIS" interviewed by
WPTV-NBC. In addition, in the course of my investigation, I reviewed a
newspaper article which appeared in The New York Times on or about
January 31, 1998, concerning offshore Internet sports betting. The
article describes the business operations of WWTS, among others, and
describes JESSICA DAVIS as the president of WWTS. In this article,
DAVIS describes WWTS’s sports betting operations.
19. On or about March 18, 1998, the UC called one of WWTS's toll-free
betting numbers and asked the woman who answered the telephone ("C7") if
he could speak to JESSICA DAVIS, the defendant. C7 agreed to put the
UC’s call through, and transferred the UC to another individual ("C8")
in the executive offices of WWTS. C8 then transferred the UC to
"Jessica" who the UC recognized as the "Jessica" with whom he had been
speaking on previous occasions (i.e. C5). "Jessica" however, denied
being JESSICA DAVIS, the defendant; claimed that three persons named
Jessica worked at WWTS; and claimed that she was merely a secretary to
another individual at WWTS.
WHEREFORE, deponent prays that warrants issue for the arrest of WILLIAM
SCOTT, a/k/a "Billy Scott," a/k/a "Bill Scott," and JESSICA DAVIS, and
that they 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