affidavit

Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 of 32 Pageid#: 4

4. l am submitting this affidavit for the lim ited purpose of showing probable cause for therequested criminal complaint and arrest warrant. l have not included every fact I havelearned during this investigation.

5. The USDA OIG and tlw VABC are investigating WALTER DALE STUMBO ($GD.STUMBO'') and others for engaging in activities relating to illegal animal-fightingventures in violation of 7 U.S.C. j 2156 (a) including sponsoring or exhibiting an animalin, attending, or causing an individual who has not attained the age of 16 to attend, ananimal fighting venture. ln addition, D. STUM BO'S animal-fighting venture is in violationof 18 U.S.C. j 1955 (a): Whoever conducts, ûnances, manages, suptrvises, directs, orowns all or part of an illegal gambling business.

' f the United States Code prohibits sponsoring or exhibiting an6. Title 7, Section 2156 (a) oanimal in, attending, or causing an individual who has not attained the age of 16 to attend,an animal fighting venture. This section also pertains to cock fighting.

Title 18, Section 1955 (a) of the United States Codes prohibits conducting, financing,managing, supervising, directing, or owning all or part of an illegal jambling business. Anillegal gambling business means a gambling business which: (b)(1)(1) is a violation of the

2 litical subdivision in which it is conducted, (ii) involves five or morelaw of a State or po

persons who conduct, finance, manage, supervise, direct, or own all or part of suchbusiness, and (iii) has been or remains in substantially continuous operation for a period inexcess of thirty days or has a gross revenue of $2,000 in any single day. This investigationwill show that the lllegal gambling business outlined herein was conducted by numerousindividuals including, but not limited to, D. STUMBO, JOSHUA STUMBO ($$J.

1 ' ((7 U .S.C. j 21 56(a)(3) provides With respect to fighting ventures involving live birds in a Statewhere it would not be in violation of the law, it shall be unlawful under this subsection for aperson to sponsor or exhibit a bird in the fighting venture only if the person knew that any bird inthe fighting venture was knowingly bought, sold, delivered, transported, or received in interstateor foreign commerce for the purpose of participation in the fighting venture.'' Kentucky RevisedStatute 525.1 30 provides that a person is guilty of cruelty to animals in the second degree whenhe subjects any animal to or causes cruel or injurious mistreatment through abandonment,articijates other than as provided in KRS 525.125 in causing it to fight for pleasure or profh(lncludlng, but not limited to being a spectator or vendor at an event where a four (4) leggedanimal is caused to fight for pleasure or profk), mutilation, beating, torturing any animal otherthan a dog or cat, tormenting, failing to provide adequate food, drink, space, or health care. SeeMunn v. Kentucky, 889 S.W.2d 49 (Ky. App. 1994) (birds are included in statutory definition offkanimal'' so prosecution under 525.125 is appropriate for engaging in cockfighting activities).

2 Kentucky Revised Statute 528.030 provides that a person is guilty of promoting gambling inthe second degree when he knowingly advances or profits from .

unlawful gambling activity.Kentucky Revised Statute 528.040 provides that a person is guilty of conspiracy to promotegambling when he conspires to advance or profit from gambling activity


STUMBO''), SONYA STUMBO (((S. STUMBO''), WESLEY DEAN ROBINSON (G$D.ROBINSON'D, four unidentiGed white females and one unidentified white male.

8. Cock fighters often participate in cockfighting çdderbies'', where large numbers of cockfighters will pit their roosters against one another for the entertainment of others and toenrich themselves. Cock fighting spectators gamble on the outcomes of the cock fights,and the owners of the anim als stand to gain financially tithcr through their own wagers,through an arrangement with the host of the cock fight, or through the enhanced value oftheir winning gamecocks.

Typical cock ûghts employ the use of weapons that are attached to the backs of the birds'

legs. Roosters have a natural bony spur on back of their leg. This spur is used by therooster to cause injury to other animals when it kicks with 1ts leg. This is the rooster'sprimary means of intlicting injuly Cock ighters shave the bird's natural spur down to asmall point, and then supplement the birds fighting ability by attaching a gaffe or knife tothe bird's leg. The gaftk is a Iong curved spear, while the knives are pointtd bladessharpened on one or both sides in various lengths. These metal implements are attached toa small, soft leather collar that has a hole in it. This collar, and the attached weapon, arewrapped around the bird's ankle and fit by means of the collars hole over the shaved downspur of the bird. These weapons are also called gaffs, long heels, short heels, jaggers,bayonets, Texas Twisters, socket knives, long knives, short knives, slashers, postizas inother parts of the country and world.

10. Due to the enhanced stabbing and slashing ability bestowed upon the birds by the man-made weapons, cock Eghting is an extremely painful, bloody, and deadly event. Birds arestabbed, slashed open, eviscerated, and partially decapitated. Birds that lose a match mostoften die. lt is not uncommon for winning birds to die shortly after a fight or be unable tocontinue in the derby because of m ortal wounds.

Cock fighters take pride in their gamecocks and breed them as others m ight breed non-fighting animals. Cock fighters select their animals for the traits they value - size,toughness, and aggression - and may enhance the performance of the animals usingveterinary drugs. Cock fighters then train their gamecocks to fight, often to the death.

12. Owners/operators of cock fighting arenas, called Eipits'', hold organized fights where manypeople can fight their trained birds against the fighting birds of other people. Thesearena's

, depending on the level of sophistication, will have multiple pits to host çémainfights'' and drag pits to accommodate fights in the m ain pit that have lasted too long andlost the interest of the spectators. These arenas will often have pennanent stadium-styleseating, electricity, plumbing, concessions, and ample parking for participants andspectators.

l 3. Owners often have schedules professionally printed that show the dates of the fights thatpeople can enter and spectate. Owners distrlbute these schedules by various means toenhance participation and attendance at their organized fights.


l4. Owners charge participants a set fee to enter his or her birds into a derby. This fee may beanywhere from one hundred dollars to tens of thousands of dollars, depending on the event.The winner of the derby is the person whose birds have the best overall win/loss record.This person wins the tspot'' or fees collected by the other participants. lf multiple people tiewith the best win/loss record then the pot is split between them .

Owners enrich themselves by keeping a percentage of the pot, charging participants forextra ddoptions'' or Ssinsurance'' (which may increase a participant's chance of winning moremoney), charging spectators to park at the pit, charging a fee for spectators to get into theevent, selling food and drinks at the event, selling gafrs and other bird fighting supplies,charging vendors to set up booths at the pit, charging premiums for preferred seating,charging annual rentals of VlP room s at the pit Iocation, and charging annual fees for birdkeeps at the pit location. A keep is a wooden hut with multiple compartments to house andsegregate a contestant's fighting birds while they attend the event.

ORIGIN AND M EANS OF THE INW STIGATION

16. The VABC, with the assistance of the Spotsylvania County Sheriff's Department beganinvestigatinj targets in the Wise County, Virginia area in 2012 for the illegal manufactureof untaxed llquor. The VABC has observed a strong relationship in the past between theculture of manufacturing untaxed liquor and the culture of animal fighting in the rural partsof Virginia. The investigation quickly identifed people in the W ise County area who were

ingrained in the bird fighting culture. Due to the Virginia state law making cock fijhting afelony, many Virginia bird fighters were travelling across state lines to fight their blrds inKentucky. At this point the VABC contacted USDA OIG for assistance conducting aninterstate investigation. As part of this investigation it was discovered in 2013 that D.STUMBO was operating a continuous animal ûghting exhibition (cock fighting pit) inKentucky frequented by spectators and bird fighters from Virginia and other states.

17. USDA investigated D. STUM BO in various ways, including by using an undercover VABCagent (herein referred to as UCl), and an undercover Spotsylvania County Sheriff's Deputy(herein referred to as UC2) that were introduced to the Gghting pit under the control of D.STUMBO. The UCs went to this yit on multiple occasions between February 2013 andApril of 2014. The UCs used audlo and video equipment covertly to record parts of their

visits to the ûjhting pit. Both UC agents and the Virginia ABC agents that assisted withthis investigatlon were deputized as Special Deputy U.S. M arshal's in the Western Districtof Virginia.

FACTS TO SUPPORT PROBABLE CAUSE

l8. On 2/23/13 the UC agents travelled to the described pit in KY. lt is called BlG BLUESPORTSMEN'S CLUB ($$B1G BLUE''), and is located in McDowell, KY atlongitude/latitude 37.449489/-82.766925 (The UCs were equipped with GPS trackingdevices). Outside the building they encountered an unidentified male working security.The security guard let them pay a $20.00 parking fee/membership fee to get in, but onlyafter mentioning the name of a prominent Virginia bird fighter and BlG BLUE member


CCD. ROBlNSON''I, who had vouched for them, and whose name security had writtendown in expectation of the UCs arrival.

The UCs observed vehicle tags from South Carolina, Nol'th Carolina, Ohio, Virginia,Georgia, Tennessee, Ktntucky and W est Virginia.

The UCs observed a large number of wooden buildings and trailers where the ightingcocks are maintained prior to Gghting on the surrounding parking lot. The sghtingderby is located in a large blue metal building that has an arena type setting inside.There is a large caged sghting pit in between the seats. There are numerous rooms onthe inside of the building that allow members to store there fighting cocks in. Theserooms all have secured doors to them. There is a full service restaurant inside that hasmany tables and seats for patrons. In the restaurant area, there is a secured glass cabinetthat has many products such as penicillin, strychnine, and other ItX type products thatare used for the fighting cocks. These products are for sale. There are also severalgambling slot machines that appeared to be in operational condition in the restaurant 'area. There are many signs posted on the inside of the building that warn cell phones,cam eras and/or video equipment is not allowed. There are also pictures posted on thewalls of known government informants that have been identified. The main fightingarena seats approximately 400 people and there are many drag pits that are in thehallways as you enter the building.

The UCs went inside the m ain pit building where they had their photos taken and hadlaminated lDs issued to them so they could return in the future. At one point during thisinvestigation, S. STUM BO, who was running the ID statioh, said they had over 6000members stored on their computer system.

The UC's encountered D. ROBINSON here, who was sham ening gaffs for people andrunning a b00th selling gaffs. The UCs had previously met D. ROBIN SON at his home inPound, VA. The UCs had observed D. ROBW SON 'S gaff making workshop at his home.D. ROBINSON stated he had already sold out of a1l the gaffs he had brought from VA.

At the beginning of the event a w/m subject wearing a blue t-shirt and blue jeans was incharge of the pit. This w/m subject went over numerous rules and was speaking from amicro-phone inside the main arena. The UCs were unable to identify who this subjectwas during this operation. This subject was later identified by additional contacts andmatching DL photos to UC video as D. STUM BO.

The UC's watched multiple organized fights at this pit, which had stadiunï seating, VlPseating, concessions, main pits, drag pits, parking, bird keeps for rent, and fighting suppliesfor sale. M ost of the patrons at the fight were gambling on the outcomes of the fights.Individual bets in excess of $700.00 were often observed. The UCs also observed childrenat the fight. There appeared to be about 300 spectators at this event.

The UCs observed many spectators placing bets on the fighting cocks to include thehandlers in the arena. While conducting this operation, UC 1 lost $50.00 on a bet in the


drag pit and UC2 won $65.00 in the main arena. UC1 observed several subjects winapproximately $700.00 while betting on these fights.

The UCs observed many fights in the main arena and the drag pits that involvedgruesome, bloody fights often to death of a fighting cock. The dead fighting cocks wereplaced in a 50 gallon metal barrel inside the building near the entrance and drag pit area.The UCs also observed several dead fighting cocks that wcre outside in the parking lotarea near the private keeps.

On 3/21/13 UC1 was at the residence of JONATHAN ROBINSON (d$J. ROBINSON'')and D. ROBINSON in Pound, VA. UCl asked Dean if he/she could purchase a pair offighting gaffs and get his/her knife sharpened. Dean agreed to this and they went insideD. ROBIN SON'S workshop. J. ROBIN SON assisted D. ROBIN SON in preparing UC1a set of fighting gaffs. After the gaffs were m ade, UC1 purchased the set from D.ROBINSON for $80.00. During this transaction D. ROBINSON bragged to UCl aboutthe amount of m oney he m ade m anufacturing and selling fighting gaffs at B1G BLUE inKY. D. ROBINSON advised that he would average about $1,500.00 a weekend whenhe traveled to B1G BLUE to sell them. At a standard price of $80.00 a set, that wouldmean D. ROBIN SON was selling about 19 sets of gaffs at BlG BLUE each weekend.

20. On 4/13/13 UCl and UC2 met with J. ROBm SON at his home in Pound, VA. J.ROBINSON is the adult son of D. ROBm SON, who also resides at this location. The twoUCs helped J. ROBINSON prepare and load 7 fighting roosters into J. ROBINSON'S truck.UCl Accompanied J. ROBINSON in the vehicle and J. ROBINSON took the two UCsacross the state line to BIG BLUE in KY.

They arrived at BlG BLUE at approximately 7:00am . The front gate was open with nosecurity employee on duty; however the second check point was controlled by a w/msubject. This w/m subject collected $40.00 for a parking fee and allowed them toproceed into the pit area.

Once at the facility, they unloaded the fighting cocks from J. ROBINSON'S truck into asecured keep maintained by J. ROBIN SON . He advised UC1 that he rented this keepfor $700.00 a year and paid the pit owner the rental fee. UC 1 observed approximately100 private keeps outside the main pit in the parking lot where J. ROBINSON 'S keepwas Iocated. There were also numerous keeps located throughout the building complex;all of these keeps were secured with locks.

After this, the UCs helped J. ROBIN SON prepare the cocks in the proper cages andweigh the cocks and place bands on their legs with designated numbers. An unknownw/m B1G BLUE em ployee later came by and placed bands on the seven fighting cocks'legs. UC2 recorded the correct leg band information on a sheet of paper and anem ployee later verified the bands and the weight of each cock.

After this activity, the UCs went with J. ROBIN SON to register the fighting cocks forthe derby. They went inside the large building and up the stairs to the control table that


announced and controlled the Gghts. This table is beside a large board that shows thederby entries and attached a number to the handler and their corresponding cocks.

There were two w/f employees and one w/m subject working at this table. J.ROBINSON later verified that the w/m subject that collected their registration money atthe table was J. STUM BO, adult son of D. STUM BO. UC 1 handed J. ROBINSON$270.00 to cover the entry fee for the derby, and J. ROBINSON paid the admission to J.STUM BO. J. STUM BO collected the money and provided J. ROBINSON with ahandler num ber and recorded the Cl's fighting cocks' inform ation. The fighting cockswere designated as number (39) and J. ROBINSON was provided a sheet of paper withthe number (39) written on it. UC1 attached this paper number showing (39) to the backof J. ROBINSON 'S shirt. This number corresponded with the entry num berrepresenting the UCs fighting cocks on the board.

On this date, J. ROBINSON also handled fighting birds for another bird owner. Thissecond owner was identified as BO BRANHAM (QIBRANHAM''). UC1 observed J.ROBIN SON prepare, handle, fight and place bets on BRANHAM 'S fighting cocks.

UC1 observed the two w/f employees and J. STUM BO monitor and control al1 them oney paid for the entry fees and document the handler and fighting cocks information.They kept the board updated throughout the derby with the winning and losing recordsshowing the handler numbers in a column with the wins and losses. After the CIsentered their fighting cocks, they went back to the keep. J. ROBINSON explained thathe would be the handler and be in the pit with the fighting cocks and place a1l the betsfor the day. UC2 and UC1 were there as spectators in the general seating area wherethey could observe the fights. UC 1 and UC2 were able to comm unicate with J.ROBIN SON prior to each fight.

Around this time the parking lot was getting very full and many subjects wereunloading fighting cocks into their keeps and conducting business with the control tableinside the pit.

UC 1 began to observe the many different vehicle state tag numbers. UC 1 observed thefollowing state tags at this event; North Carolina, Virginia, W est Virginia, M aryland,Georgia, South Carolina, M ichigan, Ohio, and Kentucky.

J. ROBIN SON asked the UCs if they wanted to fight in a ''hack'' fight. A ''hack fight'' isa practice fight that you can fight and gam ble on; however, it does not count in thederby standings. The UCs agreed to fight one of their fighting cocks in this event. Thishack fight event lasted about two hours and they lost this fight and their m oney that waswagered on the fight.

The UCs observed that the crowd was alm ost full at this time and approxim ately 250subjects were attending the derby. UC 1 noticed the pit owner, identified as D.STUM BO, carry a lot of m oney around and then observed him take several m oney bagsoutside and put the money in a white Suv/-rahoe Kentucky tag number 4663 DN (Thisvehicle is registered to W ALTER STUM BO and SONYA K . STUM BO, 773 Frasures


Dr, McDowell, KY). There was a license plate frame on the front tag number that read''Josh Stum bo 28 racingf'. UC1 provided this tag number to the cover team and lateralerted them when a w/f subject left the pit in this subject vehicle. The driver of thisvehicle was later identified by KY driver's license photo as SONYA STUMBO (S.STUM BO), wife of D. STUM BO.

Cover team m ember Special Agent Beverly W hitmer of tht Virginia ABC along withSpecial Agent Pamela Schwartz of USDA-OIG picked up this vehicle traveling fromthe pit north bound on Doty Branch at the intersection of Doty Branch and Rt 680/122.The vehicle carrying S. STUM BO then took a right on 680/122 and travelled severalhundred yards to where 122 continued south and 680 split off to the left in an easterlydirection. The vehicle took the left onto 680. The agents did not imm ediately followthe vehicle down route 680, as they were unfam iliar with the area and feared followingthe subject down a dead end road. ln actuality, at this point 680 goes in a south eastdirection for .9 m iles then turns straight into Frasure's Creek Rd.

As pointed out in prior paragraphs, this white SUV is registered to STUM BO residencelocated at 773 Frasure's Creek Rd, M cDowell, KY. S. STUM BO, D. STUM BO, and J.STUM BO all have KY driver's licenses that list 773 Frasure's Creek Rd, M cDowell,KY as their address of record.

After waiting for a period to allay suspicion, the agents eventually travelled down Rt680 towards Frasure's Creek Rd. As they travelled the .9 m ile stretch of 680 leading toFrasure's Creek, they encountered the same white SUV, KY tag 4663 DN, travellingfrom the direction of Frasure's Creek, past the agents, in a Northwest direction backtowards the pit.

During the derby UC l asked J. ROBINSON about how much money the pit owner (D.STUMBO) would make on a derby. J. ROBINSON advised that D. STUMBO made alot of m oney from parking fees, keep rental, and the restaurant that was operated insidethe building (pit). The restaurant served a full breakfast and a lunch menu. Thisrestaurant rem ained busy all day and made a large am ount of money. UC1 alsoobserved D. STUM BO collect money on several occasions from the restaurantemployees. This m oney was placed in m oney bags and later put in the white SUVk'rahoe that was parked near the restaurant door. On several occasions UC1 observed J.STUM BO take what appeared to be plastic bags of money and put it into a white GM CSilverado 4-wheel drive truck.

lt was very apparent to UC1 that the STUM BO fam ily was in control of the operation atthis facility. D . STUM BO was constantly w alking around, giving orders to theemployees, and collecting a large am ount of money. D. STUM BO announced the rulesprior to the derby starting. At the end of the derby, D. STUM BO announced the winnersand handed out the trophy.

After observing all the large amounts of money that was in the possession of theSTUM BO'S during this operation, UC l asked J. ROBIN SON how do the STUM BO'Skeep this m uch money safe during a two day derby? He advised UC1 that D . STUM BO


would take the money back to his residence and secure it in a safe. He would then takeit back to the pit on the following day to pay out the winners of second day of the derby.

During this derby, UC1 observed D. ROBINSON working, selling, and fixing fightinggaffs at a work table inside the building. UC2 later purchased a set of fighting gaffs forfighting purposes from D. ROBINSON. UC1 observed many subjects purchase fightinggaffs from D. ROBINSON and paying with cash. UCl also observed some of thesesubjects use the purchased gaffs in the fights on this day.

While UC1 was in the parking lot area he/she observed an Asian male subject handlinga brief case full of money inside his vehicle. The vehicle showed a M ichigan tagnumber.

UC l observed several people using the slot m achines in the kitchen area. He/sheobserved several subjects put money in the slot machines, however, he/she did notobserve anyone collect any money from these slot m achines. UC1 had a conversationwith a w/f who advised him/her that the slot machines worked and that she had wonmoney in the past from playing these slot machines.

The UCs participated in a five-cock recorded derby and there were approxim ately 86entries on that day. The UCs, with J. ROBm SON handling the birds in the pit, won a11five fights. At the end of the derby it was declared there was a 4-way tie.

During this operation, UC 1 directly observed over 40 cock fights. Before the UCs'cocks fought. J. ROBIN SON asked how much m oney the UCs wanted to bet. J.ROBINSON then set up the bets w ith the opposing handler and would collect themoney or pay the m oney out after the fight. UCs observed side betting on these fights aswell, which m ade it difficult to record and observe al1 the transactions. These side betsoccurred in the m ain fighting pit and the drag pits. UC 1 observed several fights in thedrag pit that were going for $2000.00 or more a fight. UC1 lost approximately $100.00in side bets in the drag pits.

UC1 observed that m ost of the cocks that fought in the drag pits were killed and placedin metal barrels. On one occasion UC 1 observed a Hispanic male put a severely injuredcock in the m etal disposal barrel that was still alive. This cock was still moving andbreathing. UC 1 attempted to get video of this activity.

At the end of the cock-fighting derby, D . STUM BO announced the 4 winning team sand called thtm to the center of the m ain fighting pit. lt was decided that all 4 winningteams would split the cash pot. UC1 observed J. ROBIN SON go to the control table andreceive the m oney that he won from the fights. J. ROBINSON walked over to UCl andUC2 and handed UC 1 the US currency that they won.

J. ROBINSON advised them that they owed him a handler fee of $1,170.00. UC1handed over $1.170.00 to J. ROBINSON while in the keep, in the presence of UC2.UC l attempted to video this payment to J. ROBINSON. UC 1 also paid out $50.00 toTimothy M ullins, who appeared to be under 18 years of age and who assisted J.


ROBIN SON in affixing the fighting gaffs on the cocks. UC 1 had already tippedTimothy $50.00 prior to this payment because UC1 thought he was leaving.

As fighting cock %lowners'', the undercover agents were left with $3,380.00 from thepot. The undercover agents also won $300.00 in side bets on this day. The total cashwinnings, after pay-outs, were $3,680.00.

At the end of the derby, the UCs assisted J. ROBINSON with the loading of the fightingcocks into J. ROBINSON'S truck and transported them back to W ise County, Va.

21. On 06/07/13 at approximately 5:55 pm , UC1 and UC2 arrived at the ROBINSON residencein the Pound area of W ise County, Virginia. J. ROBINSON and D. ROBINSON were inthe work shop on the property making fighting gaffs.

The UCs had a conversation with D. ROBINSON and he informed them he was preparingand sharpening gaffs to take to the BlG BLUE derby in Kentucky on Saturday.J. ROBINSON was assisting his father in working on the fighting gaffs.

During this visit UC1 talked with D. ROBINSON about the STUM BO family and their pitoperation at the BIG BLUE in KY. UCl engaged D. ROBINSON in conversation aboutthe large amount of money that could be made in the cock fighting business.

D. ROBINSON started talking about the large amounts of money that Hispanic peoplewould bring to the pit to gamble with. During this conversation, UCl asked him how theSTUM BO family kept from getting robbed and losing the Iarge amounts of money made atthe pit. D. ROBINSON advised UC1 that during a two day derby, the STUM BOS wouldsecure much of the cash at their residence so as not leave a large am ount of cash on siteovernight. D. ROBINSON then went on and talked about the Mexican Mafia (a large, wellorganized criminal gang and drug cartel) and that this organization had been to BlG BLUEin the past to bet on birds and fight birds.

UC 1 again mentioned that it was amazing that the pit had never been robbed. D.ROBINSON responded that the STUM BOS ran a'vel'y tight operation and had securitymeasures in place.

While the UCs were at this location, two unknown w/m subjects arrived in a truck withTennessee tags. The two males told the UCs they were there to pick up some fighting gaffsthat would be used in a cock fight at another pit on Saturday in Kentucky. UCl laterobserved one of the w/m subjects hand D. ROBm SON some money (US Currency).

J. ROBINSON took the UCs down to the outside keeps and showed them their purchasedfighting cocks. Their condition seemed to be fine and UCl asked J. ROBINSON aboutwhen they could stage another fight. UCl explained that he/she would be in town nextweek and would like to stage a private fight in Virginia. J. ROBINSON advised that hewould see what he could set up and get back with UCI. W hile checking on the sghtingcocks, UC1 asked J. ROBINSON how much money UC1 owed him for feeding and caringfor the fighting cocks. They agreed on $50.00 and UCl paid this money to J. ROBINSONfor his services and feed.


The UCs then went back to the main keep with J. ROBINSON and checked the conditionof the fighting cocks that J. ROBINSON was taking to Kentucky on Saturday to fight.While in the keep, UCl asked J. ROBINSON whether he had any pills or marijuana to sellhim/her. J. ROBIN SON advised that he was going to town at dark time and would try toget some pills and marijuana. J. ROBINSON said to call him back after 9:00pm and if hehad some, he would meet the UC in town and sell them to him/her.

On 6/8/13, At approximately 5:05am , UC 1 and UC2 arrived at the residence of J.ROBIN SON and D. ROBINSON . They met with J. ROBINSON and assisted hiin inloading 13 fighting cocks in vehicles to take to Kentucky to engage in animal fighting atB1G BLUE. They loaded 7 fighting cocks into J. ROBINSON 'S truck and 6 fighting cocksinto 6IPAUU S'' SUV. UC1 was able to video this activity and also the tag numbers on bothvehicles used to transport these fighting cocks to Kentucky. A review of the video by thisam ant shows that the black Ford Explorer under the control of CTAUL'' bore Virginia tagZD 2744. That vehicle tag is registered to a 2004 black Ford truck in the names of PaulFarm er and Nina Farmer, residing at 4009 Coeburn Rd, Coeburn, Virginia.

After loading the fighting cocks, J. ROBINSON advised the UCs they had to meet anotherperson and also pick up TIMMY MULLINS (the minor boy from the 4/13/14 derby) at thePizza Plus located in the town of Pound, Virginia. UC1 and UC2 followed J. ROBINSONto this location and they met up with an older w/m subject who identised himself asJIMMY WILLIS CWlLLlS''). WILLIS was driving a Ford pick-up tnlck VA tag # JXN-7792. This plate is registered to a black 2004 Ford in the name of Jim my Crate W illis, Box41 8, Clintwood, VA, DOB 8/7/38.

W ILLIS rode with J. ROBINSON and they then went to pick up T. M ULLINS at hisresidence. After everyone was organized, UC 1 and UC2 followed J. ROBINSON, T.M ULLINS, PAUL FARM ER, and W ILLIS to the BlG BLUE pit in Kentucky.

The group, with the UCs, arrived at the Kentucky pit at approximately 7:00am. After goingthrough the check points, the UCs encountered the same w/m subject from prior derbies atthe second check point. This male was screening subjects and checking for parking permits.This w/m subject collected their money ($20.00) and allowed them to enter the pit.

On this visit, UC1 noticed that there were several pictures of known informants that wereposted on the second check point shelter. UC2 had lost his parking penuit card and wasrequired to pay additional money ($20.00) to enter. UC2 had a conversation with this w/msubject about this and was advised that D. STUMBO, the pit owner, made this decision andsecurity guard had to enforce it.

After entering and parking at the pit Iocation, UC 1 immediately began to check for vehicletags from different states. UC1 observed vehicles from the following states; Virginia, W estVirginia, Kentucky, North Carolina, Ohio, South Carolina, Georgia, and Tennessee.

UC 1 and UC2 were able to observe and assist in unloading the 13 fighting cocks that weretaken from the ROBINSON residence that morning in Pound, Virginia. These fighting


cocks were placed in a private keep outside the pit and prepared for fighting purposes by J.ROBINSON, T. M ULLINS and PAUL FARM ER.

As the morning went on, the pit began to t5ll up. There were 98 total entries on this day andthe entry fee was $250.00 (98 x $250.00 = $24,500). At the peak of the day, UC1 observedapproximately 300 subjects in attendance at this cock fight.

As in the past, D. STUM BO, his wife S. STUM BO and son J. STUM BO wem settingthings up and showing that they were in control of this operation. S. STUM BO was makingannouncements on the microphone and S. STUM BO was operating the picture ID cardsstation that are used to make the cards that are used as parking permits and membershipcards. UCl observed J. STUM BO working with the ladies that were collecting the entryfees and handling the paperwork in the pit.

During this operation, UC 1 observed over 50 cock fights. He/she observed gamblingactivity between subjects in the main arena and drag pit. This included many cash pay outsof large amounts of US currency. UC1 placed bets on several cock fights and lostapproximately $40.00 during the day.

There were many controversial issues in the drag pits, where some handlers becameagitated and almbst had physical contact. The referees had to call D. STUM BO on manyoccasions to calm the situation dpwn and in some cases, remove a handler who violatedrules.

During this operation, UC 1 observed D. ROBINSON sharpening tlghting gaffs that werebeing used in the cock fights. UC1 also observed many subjects paying D. ROBINSONcash and picking up fighting gaffs from him that were placed in plastic bags.

UC 1 observed several bloody cock fights in the drag pit where the cocks fought to death.On one occasion, one of PXUL FARM ER'S fighting cocks was blinded in one eye after thefight but still alive. J. ROBm SON instructed the boy TIM M Y M ULLm S to finish thecock off. TIM M Y M ULLINS attempted to choke the cock to death and placed him in ametal barrel. UC2 later observed the fighting cock still alive and moving around in thedisposal barrel.

UC1 also observed several young boys that appeared to be under ten years old, handlingfighting cocks and placing the dead cocks in barrels after the fights.

W hile in the kitchen area, UC l overheard a conversation between D. STUM BO and severalunknown Hispanic subjects. D. STUMBO was explaining to the men why the words''parking permit'' were on the club membership photo ld's. D. STUM BO told the men thatthe $20.00 parking permit fee was the same as a membership fee. The reason he did notput the club name on the membership card/parking permit was to avoid trouble with 1awenforcement if police came into possession of the photo ID card. He told the men that byriot revealing the club identity, law enforcement would have no idea what the ID card wasfor.


UC l and UC2 later had a convcsation with S. STUM BO about why UC2 had to pay anadditional $20.00 to enter the derby since he/she already had an ID card/club membership.S. STUM BO advised that she had over 6000 club members logged in her computer systemand that there was no way she could go through that m any pictures to find a lost ID card.

S. STUM BO also confirmed that the $20.00 parking permit fee was like an admission feeanyway, and that all members had to pay the $20.00 fee to get into the facility. UC2 thenprovided his new ticket stub to S. STUM BO and obtained a new club membership photoID card.

S. STUMBO advised that the dld membership photo ID cards had the words ''Big BlueSportsman Club'' on them and they later removed that wording to read ''parking permit.''M rs. Stumbo advised that this change in wording on the ID card was made to avoidattention from law enforcement if they came into possession of the ID card.

UC l later had a similar conversation with D. STUM BO, and he advised the same thing,that the parking permit was the same as a club membership card and that the wording''parking permit'' was used to avoid trouble with law enforcement if they came intopossession of the ID card.

D. STUMBO advised that the $20.00 parking permit fee was the same as paying anadmission fee and that it was closely m onitored and controlled by him .

UC 1 also had a conversation with D. STUM BO about explaining the triple option plan. D.STUM BO provided UC1 with a blue match card and explained this triple option process.The blue match card is a professionally printed card that shows the date of each derby heldat Big Blue during the 2013 fighting season, the number of birds each entrant can fight atthe derby, what kind of weapons the birds will be allowed to use, and how much insuranceoptions will cost an entrant if they wish to pay the house for that benefit.

23. On 06/12/1 3 at approximately 5:20 pm, UC1 arrived at the ROBINSON residence locatedin tht Pound area of W ist County. UCl made contact with J. ROBINSON and assistedhim in feeding and watering the fighting cocks. J. ROBINSON took UCl to the main keepand showed the UC the fighting cocks he was going to take to Kentucky to fight in thecoming weekend. J. ROBINSON advised UCl that his cousin was coming over to spar .some fighting cocks and he invited UC1 to stay and watch.

Not long after UC1 arrived, a pick-up truck arrived bearing Virginia tag XVP3069, with J.ROBINSON'S cousin and wife. They were identised as ROGER CANTRELL (R.CANTRELL) and LADONNA CANTRELL (fçL. CANTRELL''). UCl was able to gettheir physical descriptions on audio/video, along with the vehicle description/tag number.This tag comes back registered to Roger Cantrell, 9605 Caribou Rd., Pound, VA.

During a conversation between UC1 and R. CANTRELL, he advised that he was on federalprobation from a federal drug investigation in Kentucky. R. CANTRELL advised that hepulled time in the Beckley, West Virginia prison. R. CANTELL advised UC l he was a bigtime cock fighter ''in the day'' and he wanted to gd back into the business. He has beenlaying low since he was on federal probation, but he was preparing to fight cocks this


com ing weekend at another pit in Kentucky. UCl overheard J. ROBINSON and R.CANTRELL talking about getting R.CANTRELL back into the BIG BLUE PlT inKentucky. R. CANTRELL asked J. CANTRELL to 1lk to D. STUM BO about letting himcom e back to his pit.

W hile talking with R. CANTRELL, PAUL FARM ER showed up driving a new appearingSilverado 4 X 4 pick-up truck. UC1 attempted to video this truck and tag number. UC1observed some chicken cages used to transport fighting cocks in the front passenger seat ofPAUL FARM ER'S truck. J. ROBINSON , PAUL FARM ER, R. CANTM LL, L.CANTRELL, and UC 1 a1l went to the main keep on the ROBINSON property and sparred5 sets of fighting cocks.

J. ROBINSON and R. CANTRELL placed the rubber boxing gloves on the birds beforeeach Gght. It was apparent R. CANTELL was trying to pick out some fighting cocks totake to a derby. After spaning these fighting cocks, R. CANTELL picked out the best twoand advised that he would be back later.

' UCl then went with J. ROBINSON and assisted him in feeding the fighting cocks thatwere outside the keep connected to barrels. W hile feeding the cocks, J. ROBINSONshowed UC 1 approximately 20 marijuana plants that he was growing. These plants werevery sm all and placed in plastic conliners. They were hidden well, as the UC had firstwalked past them without seeing them. These marijuana plants were located behind J.ROBINSON'S trailer.

24. On 06/13/1 3 at approximately 6:37pm , UC 1 anived at the ROBINSON residence in Pound,VA. There was a w/m subject named ROGER LAST NAME UNKNOWN CIROGERLNU'') that UC 1 had never seen before. ROGER LNU was picking up some fighting gaFsfrom D. ROBINSON. UC1 attempted to get his physical description and vehicle tagnumber on video. The vehicles in this video depict a blue pickup truck with a Kenm ckyplate 270NAT, and a red pickup truck with Virginia plate 288511M . The Kentucky plate isregistered to Pamela S. Bartley, P.O. Box 215, Ashcamp, Kentucky. The Virginia tag isregistered to Roger Lee W illis, 9547 M cFalls Rd, Pound, Virginia.

W hile there, D. ROBm SON had a conversation with UCl about the M exican M afiasending a hit man to the area looking for a local cock sghter that was laundering money.During this conversation with D. ROBINSON, he advised UCl that many people in thisarea did not believe in banks and hid their money on their personal property. D .ROBINSON described a close friend that had m ade a hidden compartment in the bedroomftoor of his house.

UC1 brought up the fact that he/she had seen an Asian male subject with a brief case full ofmoney at the B1G BLUE PIT in Kentucky. D. ROBm SON advised that was a commonoccurrence and that there were large amounts of m oney gambled during cock ûghts at BIGBLUE.

25. On 06/27/13 at approxim ately 6:30 pm, UC1 arrived at the ROBINSON residence inPound, VA. UC 1 met with J. ROBIN SON who advised that he would not be able to go out


with UC l that evening. J. ROBINSON advised that his son decided to come home and hewould have to stay with him . UCl assisted J. ROBINSON in feeding the chickens whilehe prepared some traps to attempt to catch some predators that were killing some of hischickens.

After this work they both went to the main keep and prepared some of the fghting cocksfor the upcoming weekend fight in Kentucky. J. ROBFNSON advised UCl that thefighting season was almost over due to the molt season. J. ROBINSON showed UC1evidence where his Gghting cocks were beginning to lose their feathers. J. ROBINSONexplained that the molt season lasted until mid-November.

UC1 asked J. ROBIN SON when they could flght their cocks again. J. ROBINSON advisedUCl that his last entry to fight cocks would be July 13th, and that the next best time theywould be able to fight birds would be in January or February of 2014. J. ROBINSONcontinued to explain that the m olt season was coming early this year and he m ight not begoing back to Kentucky until late fall.

UC1 asked J. ROBINSON about the pills he/she had ordered and J. ROBINSON advisedthat thty wtre still not in. J. ROBINSON txplained that his fricnd was getting the pillsdirectly from a subject named RUSSELL PEAKS (SCPEAKS''). He said that PEAKS hadrecently pulled time for selling drugs and was back in business again. J. ROBINSON toldUC1 to check back with him on Friday morning and he would 1et UC1 know if the pillsarrived.

26. On 06/28/13, at approximately 9:00am, UC 1 made contact with J. ROBINSON by phone.J. ROBINSON advised UC1 that the pills still were not in and that when they arrived hewould keep one or two for UCl to buy on UC1 's next visit. UCl thanked J. ROBW SONand told him he/she would attempt to make the July 13th derby in Kentucky.

On 07/1 1/13 at approximately 9:25 pm , UC1 and UC2 arrived at the ROBINSON residencein Pound, VA. J. ROBINSON invited them in. During this visit, the CIs observed four longguns that were being stored in J. ROBINSON 'S bedroom, which is right next to the kitchen.J. ROBINSON advised that he was waiting on a shipment of ''Roxie'' pills and that if theycame in, he would be able to sell UC1 a few . UCs left at approximately 9:46pm and told J.ROBINSON that they would come back on Friday. J. ROBINSON mentioned that theyhad an injured fighting cock that needed to be put down due to the eye injury that camefrom a previous cock fsght in KY.

28. On 07/12/13, at approximately 12:20 pm, UCl and UC2 arrived at the ROBINSONresidence in Pound, VA. Here the UCs met with J. ROBINSON and R. CANTRELL.They were both inside J. ROBINSON 'S trailer. J. ROBINSON invited the UCs inside.

During this visit, UC1 and UC2 had a conversation with J. ROBINSON about the guns inhis bedroom. J. ROBm SON took the UCs into his bedroom and showed them the gunsand explained the history on some of them. Also during this visit, R. CANTRELLexpressed interest in working for UC1's fictitious automobile repossession company andlater completed an application providing a1l of his personal information.


UC1 had a detailed conversation with R. CANTRELL about his involvem ent incockGghting. R. CANTRELL told UC1 that he was one of the best cockighting handlersin the area and that he was connected to some M exican cartel gang members. Rogeradvised that in the past, before he went to federal prison, his M exican conucts would tlyhim from W ise County with ûghting cocks to M exico to handle and flght the gamecocksfor them.

R. CANTRELL explained that his M exican friends were preparing to set him up inAlabama with a home and facility to raise, train and prepare gamecocks for derbies inM exico and abroad.

R. CANTRELL explained that his federal probation would be over in November and thathe was going to get back into the cockfighting business full time.

During this visit J. ROBINSON suggested that they all have a cockfight using real gaffs onthe property. J. ROBm SON again suggested that the injured cock that the UCs hadpurchased and that ROBINSON was training and maintaining, needed to be put down andwas taking up space and feed for no gain. J. ROBINSON suggested that the UCs Gght theinjured cock and another injured cock that they had. UC1 did attempt to get out of fightingthe cocks; however, J. ROBINSON and R. CANTRELL were putting pressure on UC1 andUC2 to have this fght. .

J. ROBINSON and UC2 went to get the gamecocks and gaffs. W hen they returned, R.CANTRELL and J. ROBW SON prepared these selected gamecocks for the fight andplaced gaffs on them in front of the UCs. UCl and UC2 later conducted this fight in ashady spot on the ROBINSON property under the supervision of J. ROBINSON and R.CANTRELL.

R. CANTRELL also was involved in handling one of the fighting cocks and J. ROBINSONwas acting as the referee and coaching UCl and UC2 during this cock fight.

J. ROBINSON advised that this was a good idea since both gamecocks needtd to be putdown anyway. The fighting cock UC1 was handling was severely injured and suffocatingon his own blood. J. ROBFNSON instructed UC1 to suck the blood out of the cock to keepthe cock alive to continue the fight.

At the end of the fight, J. ROBINSON took the gamecock that UC1 was fighting andsmashed the gamecock's head against a tree to kill it. At this time, the group saw someolder unknown female subjects and kids on the property that were observing this activity.J. ROBINSON requested that UC 1 take the dead gamecock and hold it in a manner to makeit look still alive. UC1 later placed the dead fighting cock in a barrel near the buildingwhere the ROBINSON'S m anufacmred the fighting gaffs. Before leaving the ROBINSONresidence, J. ROBINSON made several phone calls attempting to set up drug and untaxedliquor buys for UCl .

29. On 08/09/13, at approxim ately 1 :40 pm, UC1 visited J. ROBINSON at his home in Pound,VA . J. ROBm SON was home and invited UC1 inside. They had a brief conversationabout the upkeep of the fighting cocks and untaxed liquor. UC1 asked J. ROBINSON


whdher or not he had any pills for sale and ht advised that they could go down the road toPEAKS' residence and buy some ''Roxie's'' from him .

J. ROBm SON and UCl then went to PEAKS' residence down the road and UC1 handed J.ROBINSON $100.00 and told him to get as many pills as he could. W hile sitting in thevehicle, UC 1 observed several marijuana plants in 5 gallon buckets that were beside theoutbuilding on the PEAKS' property. They were approximately 4 feet tall and appeared ingood condition.

UC1 observed J. ROBINSON go inside the residence of PEAKS and they both later cameout and walked behind the trailer. UC1 observed PEAKS and J. ROBm SON make hand tohand contact that appeared to be a drug buy.

J. ROBINSON later walked back and got into UC1's vehicle. UC1 asked J. ROBINSONwhether or not he got the pills and J. ROBINSON advised that he purchased $100.00 worthof Roxie pills from PEAKS.

J. ROBINSON then suggested that the UCs go back to his trailer. They arrived back atthe ROBINSON residence at approximately 2:30pm. Once inside the trailer,J. ROBINSON advised that he was going to keep one of the Roxie pills for his part ingetting them and suggested that they both snort the bigger pill that was purchased.

J. ROBINSON explained that the larger Roxie pill was $40.00 and the two other smallerpills were $30.00 a pill. Before UC1 could respond, J. ROBINSON had crushed up thelarge Roxie pill on a paper plate and shrted Gxing a straw to snort the powder from the pill.W hile J. ROBINSON was preparing a second straw, UC1 placed his/her right hand downand pinched as much powder as he/she could into his/her fingers and simulated snorting theremaining powder. J. ROBm SON had prepared two lines of powder and after UC1simulated snorting the one line, he/she allowed him the take the remaining powder UC1had left over and add it to his line of powder. UC 1 then observed J. ROBW SON snort theremaining Roxie powder.

J. ROBINSON told UC 1 that PEAKS could get as many pills as they wanted and that theywere aIl strong pills in the oxycodone family. J. ROBINSON also informed UC1 thatPEAKS was recently busted for selling drugs and pulled time in prison.

Later, UC1 went with J. ROBINSON to pick up his kids and purchase some chicken feed.W hen they arrived back at the ROBINSON residence, UC1 assisted J. ROBm SON infilling up the chicken feed containers.

30. On 10/10/13 at approximately 7:05, UC1 arrived at the ROBm SON residence in Pound,VA. J. ROBIN SON wanted to take UCl down to where the fighting cocks were locatedand show UC1 the condition of the birds that the UCs had previously purchased.

J. ROBINSON brought a small bag of marijuana and a ceramic smoking device with himand smoked some marijuana while they were down there. J. ROBINSON offered UC1some hits of his marijuana; however, UC1 advised J. ROBINSON that due to recentlyfailing a drug test at work, he/she could not do any illegal drugs for a while.


J. ROBm SON advised that he recently purchased over one ounce of good, homegrownlocal marijuana and that most people that were growing ''pot'' in their area had alreadyharvested the crop due to cold weather and a recent frost.

They walked around the property and checked the condition of the fighting cocks and theyappeared to be in good condition. J. ROBINSON advised that the cock fights in Decemberthrough February were not so good and that m any times there were not enough entries tomake going to Kentucky worth his while.

J. ROBINSON boasted on the fact there would be several nine-cock derbies and the W orldCup held at the B1G BLUE facility late in the spring of 2014.

Later, UC1 talked with D. ROBINSON and had him sharpen some knives UC1 had.D. ROBINSON told UC 1 he was already getting some fighting gaff orders to fill and hecould not wait until his business started up again.

Jonathan told UCl to come back in the morning and they would finish checking out thefighting cocks due to dark time setting in. UCl left the ROBINSON residence atapproximately 7:41pm .

31 . On 1 0/1 1/13 at approximately 1 l :08 am, UC1 arrived at the ROBINSON residence andmet with J. ROBINSON. W hile there J. ROBINSON showed UC1 a large clear plastic bag

of marijuana that appeared to be over one ounce. UCl later purchased a quarter bag ofmarijuana from J. ROBINSON for $25.00. Before and after this drug buy UC1 observedweapons in the residence in close proximity to where the drug buy occurred.

On 12/1 1/13 at approxim ately 6:24 pm, UC1 traveled to the property of the ROBINSONfam ily. D. ROBm SON and J. ROBINSON were eating dinner at D. ROBINSON 'S houseand invited UC1 in. UC1 had a lengthy conversation with both of them about the welfareof the purchased fighting cocks and inquired about the 2014 cockfighting season. UC1 alsoprovided a payment of $100.00 for the feed and service of taking care of tht fighting cocks.J. ROBINSON accepted this payment and put the money in his wallet. Since it was dark,UC1 advised that he/she would com e back on the following day and see the fighting cocks.

On 12/12/13 at approximately 10:33 am , UC1 arrived at the ROBINSON residence.He/she made contact with J. ROBINSON and D. ROBINSON and checked on thecondition of the purchased fighting cocks.

They a11 talked about the upcoming cock fighting season and J. ROBINSON said it wouldnot be worth the UC's tim e fighting until mid-M arch 2014. J. ROBINSON advised thatdu< to thc hard winter, weathcr conditions, and cold temperatures the cockfighting would

be very slow until the weather warmed up in the spring tim e.


During this visit, UC1 engaged D. ROBINSON in a conversation about illegal dogfighting.UC 1 asked D. ROBINSON if he ktww whert UC1 could buy a dog for fighting purposes.

D. ROBINSON advised that he knew several subjects that were into dogfighting and hecould set up UC 1 with one of them if he/she wanted.

Dean also talked about the W orld Cup cockfghting derby that is going to be htld at the

BIG BLUE in Kentucky this year (2014). D. ROBINSON and J. ROBINSON both talkedabout the large amount of money that would be there during this event and that the derbywinners would make a large amount of money. UC 1 then left the ROBW SON residence atapproximately 12:00p

34. On 02/20/14 at approximately 5:30 pm, UC1 arrived at the ROBW SON residence. HereUCl made contact with J. ROBINSON and D. ROBINSON in D. ROBINSON 'S workshop where they were both manufacturing and working on fighting gaffs. UCl observed avery large numbtr of boxes and bags full of fighting gaffs in this shop.

D. ROBINSON said he was very busy working on custom er orders for fighting gaffs. Hementioned one customer from Kentucky that was on his way to pick up over $700.00 worthof gaffs. Later in the day, UCl observed this customer come to pick up the order from D.ROBIN SON.

During this conversation, D. ROBm SON told UC1 that the owner of the BIG BLUE,D. STUM BO, had panicked and canceled the weekend sght of Febnzary 22, 2014, due tothe concern over the recent federal house bill that dealt with animal fighting.

According to D. ROBINSON, D. STUM BO had to seek legal guidance before deciding tocontinue to operate his pit in KY. D. ROBm SON advised that after consulting legaladvice, D. STUM BO decided that he would continue to operate his cockfighting operation.However, it was too Iate in the week to reschedule the February 22, 2014 fight.

According to both ROBINSON, the Farm Bill used the word ''animal'' instead of ''fowlf',and that som ehow affected the outcome of the 1aw that was passed. The ROBINSONSadvised that fighting cocks were not labeled as ''anim als'' but as ''fowlf', therefore the newlaw was weak and would not affect their fighting operations in KY.

J. ROBm SON invited UC1 to another pit in Redbush, KY to sght on February 22, 2014.He stated that this pit was smaller, but since other pits were scared to continue fighting,there should be a good turnout in Redbush. UCl told J.ROBINSON that UCl and UC2would be back the next day to visit and check on the fighting cocks. UC1 left J.ROBINSON'S residence at approximately 7:00pm .


35. On 02/22/14 at approximately 1 :00 pm, UC1 and UC2 m et with J. ROBINSON at hisresidence in Pound, VA. The UCs assisted J. ROBINSON in watering and feeding thechickens on the property. There were approximately 400 chickens on the propertyaccording to J. ROBINSON .According to UC1's observations, there were inadequateliving conditions for al1 the birds on the property. There was little water and beddingavailable for all the birds that UC l observed. M any were restrained by a cord connected toa plastic barrel. The barrels, which were supposed to act as shelter, were heavily saturatedby water on the ground.

J. ROBINSON suggested that they spar some of the fighting cocks to see what theircondition was. UC 1 put the plastic fighting muffs on the spurs of two selected Gghtingcocks. UC1 observed J. ROBINSON and UC2 spar these two fighting cocks.

W hile UC1 was having a conversation with J. ROBINSON about the W orld Cup cock fightat the BIG BLUE pit in Kentucky, J. ROBINSON said the entry fee is expected to bebetween $3,000.00 and $5,000.00 per entrant. J. ROBINSON advised that this would be thebiggest fight of the year and there would be a large amount of money there.

After taking care of the birds and sparring them, tht UCs and J. ROBINSON wtnt to thekeep to select and Ioad the fghting cocks that J. ROBINSON would fight at the derby inthe REDBUSH, Kentucky pit. (Note: J. ROBINSON was taking the UCs to a secondaryorganized fighting pit in Kentucky because of D. STUM BO cancelling the weekend fight atBIG BLUE. See 2/20/14).

W hile near the keep, UC1 observed R. CANTRELL arrive and he later assisted in selectingand loading the fighting cocks into J. ROBINSON'S truck. After the fghting cocks wereloaded onto J. ROBINSON'S trtzck, J. ROBINSON placed the fighting gaffs in UC1 's truckand told UCl to carry them to the pit. (J. ROBINSON did not want the gaffs and birds inthe same vehicle due to the criminality of animal fighting)

J. ROBINSON and R. CANTRELL rode together in J. ROBINSON'S truck, while UC1 andUC2 traveled in UC1 's truck. The group made a brief stop at R. CANTRELL'S residence,then UCl and UC2 followed J. ROBINSON and R. CANTRELL to Redbush, KY to attendthe cockGghting derby.

The group left R. CANTRELL'S residence in the Pound area of VA at approximately3:00pm . They arrived at the pit in REDBUSH, Kentucky approximately 5:50pm . This pitis off of Salyer Branch Rd in Flatgap, KY 4121 9. The GPS that the UCs were carrying putthem at a standing structure located approximately at longitude/latitude 37.937648,-82.960725.

UC 1 describes the entry to the pit location in REDBUSH as a long dirt road that goes up avery steep incline to a tlat location at the top where the pit is located. There are two gateslocated on this road and they b0th are able to be secured by a lock. At the top of the hillwhere the pit is located, there is a building used as a checkpoint. There was a w/m subjectstanding near this location and he collected $20.00 a person for an admission fee to attend


this cock fightinj derby. He provided them a ticket each and a piece of paper and told themto show this agaln if they attended another ûght at this pit.

The pit is inside a metal building that has numerous keeps surrounding the exterior of thebuilding as well as keeps inside the building. They entered this building and observed arestaurant area in the front where cock fighting supplies were also being sold. There wasalso an area in the rear of the building where an unknown w/m subject was selling andsharpening fighting gaffs. The main fighting pit was in the center of this subject building.There appeared to be a seating capacity for approximately 300 subjects in this mainfighting pit. There were also several drag pits located on the side of this building.

UC2 assisted J. ROBINSON in paying the entry fee and handling setting up a keep forJ. ROBm SON'S ûghting cocks. The person that appeared to be running and controlling thispit operation was later identified as having the last name of SPENCER. SPENCER wascollecting the entry fees and announcing the rules and calling on the handlers during thisentire animal fight. Some of SPENCER'S activities were recorded by the UCs.

W hile UC2 was assisting J. ROBINSON and R. CANTRELL, UC1 made observations inthe parking lot and attempttd to obtain video of important features of this fighting pit. UC1also observed and attempted to get video of vehicle tags in the parking lot. There weresigns up everywhere prohibiting the use of cell phones, cam eras and any video equipment.This made it difficult and unsafe to have the audio/video equipm ent on at all times. UC1observed vehicle tags from the following states in attendance at this Gght; VA, GA, W V,KY, M l, FL. SC, NC, M E.

During these cock fighfs, UC 1 observed a large amount of illegal gambling goinj on. Thisillegal gambling occurred in the main pit and the drag pits. UC1 later lost $70.00 ln bets inthe drag pits. He/she observed many subjeds winning very large amounts of cash duringthese cock fights. UCl attempted to video as much illegal gambling as possible whileconsidering officer safety. There were video cameras set up all throughout the building.

UC1 observed the J. ROBINSON, R. CANTRELL, TIMM Y MULLINS (minor), andPEAKS fighting cocks during this derby. They were a11 filmed lghting cocks during thisinvestigation and acted as handlers/owners.

During this cockfight, UC1 observed and detected a large amount of illegal drug use going

on along with consumption of alcohol in the jarking lots. UC1 also observed several veryyouthful appearing subjects in attendance durlng this fight. There were approximately threehundrid subjects attendinj this cock fight. He/she observed a very large number ofsuspected employees monltoring the inside and outside of the pit. They all seemed to beconcerned about 1aw enforcement raiding the event. UC l had several conversations withsubjects that were talking about the new federal laws that were passed making it illegal toattend animal fighting events. Due to the large amount of entries at this fight, UC1 was toldthe fights would continue into the early morning hours.

At approximately 1 1 : 04pm, UC1 and UC2 left the fighting pit and attempted to leave.W hen they made it to the bottom of the road, they realized that the main gate was locked.


They waited there for a while and were later met by an employee of the pit who opened thegate for them. He made the comment that the gate was secure to keep law enforcement outand to protect the pit from a police raid. The UCs then exited the area.

On 03/20/14 at approximately 6:30 pm, UC1 arrived at the ROBINSON residence locatedin the Pound area of W ise County, Virginia. UC1 made contact with J. ROBINSON at thislocation and found out that J. ROBINSON had been very sick over the past week and wascancelling his trip to fight birds in Kentucky during the coming weekend. J. ROBINSONadvised UC1 that he was not able to properly train and take care of the fighting cocks in thekeep or have them ready for the weekend derby,

J. ROBINSON provided UC1 with additional information on the new protocol for the BIGBLUE pit in Kentucky. J. ROBIN SON stated due to fear of law enforcem ent raids, theSTUM BOS were locking the front gate to the pit at 9:00nm, and then placing a bulldozer infront of the gate to prevent any vehicles from coming in or going out without the pit'scontrol. J. ROBINSON said when they went back to the BIG BLUE pit, UC1 should beprepared to stay until the fight was completely over. He advised UC1 that the STUMBOSmay not open their pit in 2015 due to fear of the new laws related to animal fighting. UC1left the ROBINSON residence at approximately 8:00pm.

37. On 03/21/14, at approximately 4:30pm, UC1 and J. ROBINSON travelled to an animalfeed and hardware store in the town of Pound, Virginia. This store is nm by JIM MY

STANLEY C%STANLEY'D. UC1 has been to this business in the past with J. ROBINSONto purchase and pick up chicken feed and supplies.

J. ROBINSON told UC1 that STANLEY was a client and that he was also a cocktighting

handler for STANLEY.

STANLEY had approximately 300 chickens on a property on 1 1 128 Birchfield Road,Route 634, Pound, Virginia. J. ROBINSON told UC1 that this property was owned bySTANLEY'S father, who was recently deceased.

After feeding and watering these chickens, UC1 and J. ROBINSON went back to theROBINSON residence, also located in the Pound area of W ise County. UC1 assisted J.ROBINSON with the care of these chickens as well.

During this operation J. ROBINSON also told UC1 that part of a bird client's duties was to

pay the entry fees at derby fights throughout the fighting season whether the handler (inthis case J. ROBINSON) was using the client's birds or not.

J. ROBINSON told UC1 that STANLEY paid a lot of his entry fees for fights in Kentuckyand was a very close business partner. During this conversation, J. ROBIN SON asked ifUC 1 could put up the entry fee for the Kentucky State Chnm pionship at BIG BLUE. UC1


asked how much the entry fee was and J. ROBINSON advised him/her that it was$1,800.00. UC1 told J. ROBINSON he/she would check with UC2 and let him know. J.ROBINSON advised that he needed to know by Sunday evcning if the UCs could put uppart or all of the entry fee money.

After the work was done, UC 1 had a conversation with M RS. ROBW SON, FIRST NAM EUNKNOW N, and D. ROBFNSON about the cockûghting business in Kentucky. Both D.ROBINSON and M RS. ROBW SON told UC1 they looked for this to be the last year ofcockfighting in Kentucky until the voters could repeal the new animal sghting laws.

D. ROBm SON said the STUM BOS were attempting to ûnd another location to move towhere they could continue to fight legally. D. ROBINSON m entioned that D. STUM BOwas looking to move his pit to a nearby lndian reservation.

UC l asked D. ROBW SON what new security features had been put in place to secure thefights at the BlG BLUE pit in Kentucky. D. ROBW SON said that D. STUM BO wasIocking the front gate at 9:00am on derby days and then parking a bulldozer in front of themain road to prevent law enforcement from driving in vehicles to raid the pit.

During this visit, UCl observed D. ROBW SON working on sghting gaffs and preparinghis work order of gaffs to take to the upcoming derby fight at the B1G BLUE pit inKentucky.

D. ROBINSON emphasized the large amount of money that would be made from the

Kentucky State Championship in April and the World Cup Derby in May (at BIG BLUE).UC1 left the ROBFNSON residence at approximately 8:30pm .

38. On 04/03/14, at approximately 3:20 pm, UC1 and UC2 arrived at the ROBINSONresidence located in the Pound area of W ise County, Virginia.

The UCs found D . ROBINSON and J. ROBINSON in tht stand-alone workshop on theproperty. D. ROBINSON and J. ROBINSON were both manufacturing and finishedfighting gaffs. UC2 asked D. ROBINSON how many sets of gaffs he would be taking toBlG BLUE in Kentucky to sell at the tdstate Championship'' derby the next day. D.ROBINSON said he would be bringing 38 sets and he would sell them with no problem .D. ROBINSON estimated that he would make about $4000.00 from the sales.W hile at the ROBINSON residence, UCl was asked to assist in watering the fightingcocks. UC1 watered over two hundred chickens and many did not have any water at all. ltwas very obvious that they had not been watered in a while, as they consumed a largeamount of water immediately as he/she filled up their containers.


UC2 was asked to assist J. ROBIN SON and D . ROBINSON with manufacturing thefighting gaffs in the workshop. J. ROBINSON showed UC2 how to cut and sew theleather for the ankle cuffs and how to sandblast the newly made metal parts. UC2 asked D.ROBINSON what metal he used to make the gaffs. D. ROBINSON said he used silvernickel. He paid about $500.00 for 200 pounds of it and had already used about 100 poundsof that this year. UC1 observed J. ROBINSON and D. ROBINSON manufacturing thefighting gaffs in the workshop.

UC2 asked J. ROBINSON and D. ROBINSON about the change in the Federal Law aboutcock fighting. J. ROBm SON stated he was aware of the change and that he had spokenwith D. STUM BO about the same. J. ROBINSON said D. STUM BO told him he wasclosing the cock fighting pit this year if the 1aw didn't change back to make it legal inKentucky.

Sometime after 6:42 pm , UCl and UC2 assisted J. ROBINSON to load the sghting cockson to his truck. The three of them left for Kentucky at approximately 7:27pm.

They arrived in M cDowell, KY, at the BlG BLUE pit at approximately 9:00pm. The gateto the pit was locked and they were unable to get the Gghting cocks up to J. ROBINSON'Scock house at B1G BLUE. UCl observed J. ROBINSON call his father's home phone. Hismother answered tht phone, wife of D. ROBm SON . He asked his m other for D.STUM BO'S home telephone number and mobile telephone number. She gave them to J.ROBIN SON over the phone and he called D. STUM BO at both locations to no avail. J.ROBINSON then left UC1 and UC2 at the front gate and walked up to his cock house toset the thermostat. They left the pit at approximately 10:30 pm and traveled back to theROBINSON residence.

After they arrived back at the ROBINSON 'S, UC1 and UC2 helped put the fighting cocksback in the keep. J. ROBINSON advised UC1 and UC2 to meet him Friday morning at5:00am in Pound, VA across from STANLEY'S feed and hardware business. The UCs leftat approximately 12:10 am.

39. On 04/4/14 at approximately 5:45am, UCl and UC2 met w ith J. ROBINSON and W ILLISin a parking 1ot across from STANLEY'S feed and hardware business. UC1 verised thatthe fighting cocks were in the back of J. ROBINSON'S truck and J. ROBINSON later wentacross the road to pick up STANLEY. They a1l left the Pound area at approximately5:57am , and traveled to M cDowell, Kentucky to the BlG BLUE pit. UC1 and UC2 droveUC1 'S vehicle and followed J. ROBW SON, STANLEY, and W ILLIS to the BlG BLUEpit.


They all arrived at the B1G BLUE pit in M cDowell, Kentucky at approximately 7:25am ,and had to pay $25.00 a person to enter the pit. There was a bulldozer parked at the secondgate as described by J. ROBm SON as an extra security measure to block the gate once thecockfights started. The man that collected the money advised that there were no newmem bers being accepttd at this time. UC1 observed a metal m oney box in the shed at thesecond gate where currency was being stored from the admission fee. UCs had to providetheir previously obtained club membership parking pass prior to entry to this event.

Once inside the BIG BLUE compound, UC1 observed a large number of vehiclesregistered in the following states; W V, VA, SC, NC, GA, KY, AL, FL, TX, 'I'N, IL, AR,M I and M A. There were approximately 70 vehicles there when the UCs anived. Therewere a large number of handlers setting up their keeps and unloading their fighting cocks.

D. STUM BO, J. STUM BO, and S. STUM BO were a1l present at the event. S. STUM BOwas supervising the restaurant area and D. STUM BO was preparing the main fighting pitwhile J. STUM BO was collecting the money for entry fees and processing the handler'sinformation. UC1 observed J. ROBW SON unload his fighting cocks and place them in hiscock house that he rents.

UC 1 then went into the main pit and asked J. STUM BO what the entry fee for this derbywas and he advised $1,700.00. It was decided earlier that morning that the UCs would pay$850.00 for the entry fee, STANLEY would pay the additional $850.00, and WILLISwould pay the $50.00 insurance fee. STANLEY approached UC1 and asked for his/hermoney. UCl did not have the proper change, so he/she handed STANLEY $900.00. UC1later followed STANLEY to the registration table and observed him pay the entry fee to J.STUM BO. J. STUM BO took the entry fee money and recorded the handler's information.J. STUMBO placed the money in a gray metal money box (approximately 14'' X 10''). UC 1observed numerous other handlers pay J. STUM BO their entry fee as well. D. STUM BOwas also there when the UCs paid their entry fee and he was helping J. STUM BO handlethe money and other paperwork related to the cock fighting derby.

After STANLEY paid the entry fee, he handed UC1 back $50.00 and told him/her if theywon the derby they would split the winnings four ways. The Gghting cocks that fought onthis day were STANLEY'S cocks and J. ROBINSON was the handler .'l-here were 49 totalentries m ade for this Kentucky State Championship cocksghting event. UCl observed overtwo hundred people attending this cock fighting derby, and by the end of the event therewere approximately one hundred vehicles in the parking lot. The fight record forSTANLEY'S ighting cocks on April 4th was 1-3. (UCI was advised by J. ROBINSONafter the derby concluded that STANLEY'S birds went 4-0 on the second day of the derbythat the UCs did not attend. J. ROBINSON was the handler for STANLEY'S birds on thesecond day as well).

th 'a jsUC1 observed one suspected minor handle fighting cocks in the main pit on April 4 .

minor was TIM M Y M ULLINS who is believed to be approximately 16 years of age. UC1also observed PEAKS handle fighting cocks in the pit on April 4th.


UC1 placed several bets on April 4th in the main pit and drag pits and lost approximately$100.00 on the total for the day. UC1 observed numerous amounts of betting going onbetween the patrons attending the cockfights and the handlers as well. He/she observed onewhite male subject lose $ l ,500.00 on one fight in the main pit. UC 1 attempted to get theillejal gambling on audio/video.

UC1 also observed several bloody cock ights and attempted to get many of these fights onvideo as well. On several occasions during these fights, the handlers had to ring the neck ofthe birds to put the fighting cocks down. The restaurant stayed full all day and servedbreakfast, lunch, and a $14.00 steak and potato special dinner.

UC1 also observed several subjects playing the gambling/poker slot machines in therestaurant area. UC1 observed D. ROBIN SON und his wife operating D. ROBISON'Sfighting gaff table. UC1 observed both D. ROBINSON and his wife accept cash forshap ening gaffs as well as for the sale of new gaffs. UC1 has observed M RS.ROBINSON assisting D. ROBINSON with this sales operation every time he/she has beento BIG BLUE.

D. STUM BO provided a lengthy speech to the audience prior to the opening fight askingfor support to overturn the new farm bill that was recently passed. ln this speech, D.STUM BO stated that everyone attending this fight could get arrested for attending a cockfight and charged with a federal crime. He further stated that there were people inKentucky government that were changing the federal law but couldn't publicly come outand say it. He mentioned Alison Grimes and Greg Stumbo by name. D. STUM BO handedout copies of some recent articles in support for the cock fighters by some lawmakers inKentucky. UC1 obtained a copy of these articles. ln these handouts it clearly states that thenew farm bill makes it a federal crime to attend a cockfight.

tjy 'During the April 4 cock fight, PEAKS won $1,500.00.

The money collected on April 4th appeared to stay in possession of the STUM BOS. Therewas a laptop computer on the registration table where J. STUM BO was collecting themoney, and UC1 observed him use this computer. The UCs left the derby at approximately5:42pm, before the derby concluded for the day. The main gate and the second gate weresecured until the last fight was over and UC1 did observe the bulldozer blocking the secondentrance gate/check point where the admission fee is collected.

40. During the summer of 2013 UC2 received from J. ROBINSON a printed 2013/2014 fightschedule for the BlG BLUE pit. This schedule shows the cock fighting derbies scheduledfor each Saturday from December 7, 2013 through July 26, 2014, as well as the 2-dayderbies that occur on Fridays and Saturdays.

tb d 21St f 2013 and JanuaryOne day derbies are listed as taking place on December 7 an o ,

th th th th st th th nd st th th nd th th4 , 1 1 , 1 8 , 25 , February 1 , 8 , 15 , 22 , M arch 1 , 8 , 15 , 22 , 29 , April l 2 ,th th th th st th st th th th th19 , 26 , M ay 17 , 24 , 31 , June 14 , 21 , 28 , and July 12 , 19 , and 26 of 2014.


There are three 2-day derbies in 2014 listed on this schedule. These derbies are outlined onthe schedule with a black box. The first day of the derby occurs on a Friday and the secondday on a Saturday. The z-day derbies are titled with specific names.

The 2-day derbies listed on this schedule are the 6IKY STATE CHAM PIONSHIP'' on Aprilth d 5th ç 2014 the CSW ORL,D CHAM PION SHIP'' on M ay 2nd and 3rd of 2014 and the4 an o

, ,

CSHAW AIIAN SHOW '' on June 6th and 7th of 2014. SEE SCHEDULE BELOW :


As outlined by the undercover agent's during this investigation, both J. ROBm SON and D.ROBINSON have stated that during two-day derbies D. STUM BO brings the rem aininghalf of the cash pot to his house after the first day of fighting for safe keeping. The moneyis then brought back to the pit at some point during the second day to pay out the secondday winners.

The UC agents have observed D. STUM BO during a one day derby collecting moneythroughout the day and placing that money in a white SUV registered to him and S.STUM BO. lt was then observed that S. STUM BO entered this vehicle with the cash in itand drove the vehicle in the direction of 773 Frasure's Creek Rd, the STUM BO residence.

The UC agents have observed J. STUM BO, D. STUM BO, and S. STUM BO handling largeamounts of cash. The UC agents have never seen the cash taken from the registration tableand put into a safe on prem ises. They have only seen that cash placed in a vehicle underthe control of D. STUM BO and S. STUM BO.

lnformation given to the UCs by D. ROBW SON and his son J. ROBINSON has proven tobe highly accurate during this investigation.

Both ROBINSONS had informed the UCs of the new security measures being taken at BIGBLUE after the passing of the 2014 Farm Bill. This new law made it a federal crime tospectate an animal fight. They told the UCs that there would be a bulldozer parked in frontof the gate to keep 1aw enforcement from raiding the pit. They told the UCs that oncepeople arrived in the m orning and the registration period was closed they would not beallowed to leave until the fight was over, nor would additional people be allowed to show

up. (It states clearly on the BlG BLUE schedule that registration closes at 9 am.) Both ofthese facts were proven true during visits to the pit.

ln the experience of this affiant and the experience of other USDA agents and lawenforcement offkers who investigate organized animal fighting, the BlG BLUE pit inKentucky is one of the largest, most organized, and lucrative illegal cock fightingenterprises in the United States.

The printed schedule for BIG BLUE lists 34 days of organized animal Gghts during the2013/2014 season. Based on calculations done by this affiant using information gainedduring this investigation, it can be estimated that those 34 days of fighting will generateover 1 million dollars in cash. There are anywhere from 50 to 200 participants at anygiven derby, with anywhere from 100 to 300 spectators.


For this entire operation, D. ROBINSON has been identified as the only vendor authorizedby D. STUM BO to sell tsghting gaffs, long knives, and short knives in a retail capacity at

these events. D. ROBINSON himself stated that he makes over $1 ,500.00 a day runninghis sales operation.

Unfortunately, there are many people in this country still engaged in the practice of makesghting gaffs, Iong knives and shol't knives. There are many people that would covet D.ROBINSON'S position as the sole distributor of these devices at one of the biggestorganized cock fighting derbies in the United States. However, it is D. ROBW SON thathas the personal relationship with the STUM BO family that allows him to hold andmaintain this coveted retail position.

As seen by the UCs, J. ROBINSON was easily able to call his parent's house and get D.STUM BO'S hom e and mobile phone num bers. J. ROBINSON did not hesitate to call D.STUM BO at home late at night. J. ROBINSON, says himself that he speaks to D.STUM BO directly, as he did when telling UC2 about tht conversation ht and D. STUM BOhad about the new federal animal fighting law making it a crime to spectate a cock fight.

Furthennore, on the first trip to BIG BLUE m ade by the UCs in 2013, they were able togain admission to the B1G BLUE pit and obtain a covert ûçparking Pass''N embership photoID only because D. ROBIN SON had notified the security officer at the entrance gate to letthem in. D. ROBINSON 'S name alone was enough to get them access to a l million dollarillegal entep rise that uses locked gates, security, and photo lDs to secure the premises.

These facts show a relationship between the ROBINSON family and the STUM BO familythat gives D. ROBm SON 'S and J. ROBm SON'S information about the BlG BLUE pit acredence that would not be normally afforded to a casual observer of fights at the thislocation.

CONCLUSION

41 . Based upon m y knowledge and experience and that of the other law-enforcement agentswith whom I have consulted and the facts that l have described, l believe that there isprobable cause that WALTER DALE STUM BO, JOSHUA STUM BO, SONYA STUM BO,JONATHAN ROBm SON, and W ESLEY DEAN ROBINSON conspired, in violation ofTitle 1 8, United States Code, Section 37l , to (1) knowingly sponsor or exhibit an animal inan animal fighting venture, in violation of 7 U.S.C. j 2156(a) and (2) conduct, finance,manage, supervise, direct, or own all or part of an illegal gambling business, in violation ofl 8 U.S.C. j 1955(a).


Respectfully su ' ed. z''

Stanley Wo' onskiSpecial Agent, United States Department of AgricultureOffice of the Inspector General

Subscribed and sw rn to before me on this 39 day of , 2014.

Hon. es P. JonesUnited States District udge


affidavit

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