E-FILED 2023 AUG 01 11 :57 AM STORY - CLERK OF DISTRICT COURT

Defendant: EYIOMA UWAZURIKE

CASE NO.: 2023010833
Page 1 of4

IN THE
IOWA DISTRICT COURT FOR STORY COUNTY
STATE OF IOWA
VS
Before the Presiding
EYIOMA UWAZURIKE
Judge or Magistrate
Defendant
Iowa District Court

DOB : - SSN: -
Address: 9300 E Mineral Ave, # 143
Centennial, Colorado 80112 Criminal No. 2023010833

COMPLAINT

The Defendant, EYIOMA AKUNNA UWAZURIKE

is accused of the crime of TAMPERING WITH RECORDS
in that the Defendant did, on or between the dates of 02/07/2021 - 7/ 10/2022, in Story County, Iowa, DID KNOWINGLY
AND INTENTIONALLY FALSIFY PERSONAL ELECTRONIC SPORTS WAGERING RECORDS BY
CONCEALING ms PERSONAL IDENTITY IN SAID RECORDS WITH THE INTENT TO DECEIVE OR
CONCEAL A WRONGDOING KNOWING HE HAD NO PRIVILEGE OR RIGHT TO DO SO,
in violation of Section 715A.5 of the Iowa Criminal Code.

Signature

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Subscribed in my presence and sworn to before me this first day of Aufust, 2023
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N otaryi¼blic,-Stat,e of Iowa
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 E-FILED 2023 AUG 01 11 :57 AM STORY - CLERK OF DISTRICT COURT

Defendant: EYIOMA UWAZURIKE

CASE NO.: 2023010833
Page 2 of 4

STA TE OF IOWA) ss. EYIOMA UWAZURIKE

Story County)
AFFIDAVIT
The undersigned, being first duly sworn, states the following in support of probable cause to believe the offense
charged hereon has been committed and that the Defendant has committed it:
In 2018, the Professional and Amateur Sports Protection Act (PASPA), also known as the Bradley Act, was
judicially overturned by the United States Supreme Court. This landmark decision effectively eliminated federal restrictions,
allowing for the legalization of sports wagering. Consequently, individual states were granted the authority to legalize and
regulate sports wagering within their jurisdictions. Iowa joined this movement in May 2019, becoming the 11th state in the
nation to legalize sports wagering. Currently, there are nineteen licensed sportsbooks operating in the State of Iowa.

In Iowa, authorized sports wagering operates within a framework defmed by specific state laws, rules, and
regulations. Private companies offering sports wagering services must obtain a license to operate from the Iowa Racing and
Gaming Commission (hereafter referred to as IRGC). Licensed sports wagering companies are required to adhere to a
comprehensive set of regulations drafted by IRGC, which aims to ensure the integrity of gambling activities and facilitate
proper taxation (IAC 49 l-13.1(99F)). IRGC is also responsible for approving the "Terms of Use" drafted by licensed sports
wagering companies, which establishes enforceable conditions for customers who utilize their wagering platforms. Licensed
companies are expected to make reasonable effo1is to enforce procedural safeguards and prevent unacceptable and unlawful
activities on their platforms.

Iowa code chapters 99F and 99E detail several criminal prohibitions pertaining to sportsbook and fantasy sports
wagering. Persons under the age of2 I are prohibited from participating in gambling activities within the state. Individuals are
also prohibited from knowingly allowing someone under the age of2 l to place wagers in the state. Any actions that could
potentially manipulate or alter the outcome of a game or contest, thereby compromising the integrity of wagering lines, are
prohibited.

Iowa code Chapter 80.25A designates the Iowa Division of Criminal Investigation (DCI) as the primary criminal
investigative and enforcement agency for the purpose of enforcement of chapters 99D, 99E and 99F. Additionally, the DCI
routinely assists gaming authorities by investigating and reporting violations of gaming rules and regulations established by
the IRGC. As part of their regular duties, DCI agents also conduct background investigations on licensed gambling
companies and their operations.

All sportsbook operators have developed user terms that must be accepted by every customer during the account
registration process. To use services provided by the operator, all users must acknowledge they will abide by tenns which
prohibit the following:

a) Wagering by a coach, athletic trainer, official, player, or any other individual participating in an authorized sporting event
where wagers are accepted

b) Wagering by a person employed (both paid or volunteer) in positions that involve direct contact with coaches, players,
athletic trainers, officials, athletes, or participants in an authorized sporting event where wagers are accepted.

c) Wagering as an agent or proxies for others.

d) Wagering in the sport that the customer is an athlete or an affiliated participant. This also includes professional or amateur
athletes, sports agents, coaches, team owners, team employees, referees, or league officials, and their immediate family
members.

e) Wagering by individuals under 21 years of age

In early 2023, an investigation initiated by agents with the Iowa Division of Criminal Investigation (DCI) uncovered
evidence ofEYIOMA UWAZURIKE (DOB ■--■ conducting ilJicit wagering activities on the FanDuel sportsbook
platfonn. EYIOMA UWAZURIKE attended Iowa State University and was a player on the football team during the 2016-
20 17, 2017-20 18, 2018-2019, 2019-2020, 2020-2021 and 2021-2022 seasons. EYIOMA UWAZURIKE was selected by the
Denver Broncos in the fowth round of the 2022 NFL draft and is still on their roster of players.
 E-FILED 2023 AUG 01 11 :57 AM STORY - CLERK OF DISTRICT COURT

Defendant: EYIOMA UWAZURJKE

CASE NO.: 2023010833
Page 3 of 4

EYIOMA UWAZURlKE engaged in a scheme with RACHEL LOUISE FRANCIS (DOB - enabling
UWAZURIKE to disguise his identity and manipulate online/mobile transactions in order to create the appearance that sports
wager transactions conducted by UWAZURIKE were made by FRANCIS.

This deception enabled EYIOMA UWAZURIKE to conceal his unlawful gambling activities from law enforcement
and other regulatory bodies.

His actions contravened various legal and regulatory frameworks, including:

A) Violation of licensed Sportsbook User Terms and Conditions: UWAZURJK.E's wagers on FanDuel also violated the
platform's User's Tenns, as well as rules and regulations administered by the Iowa Racing and Gaming Commission.
FanDuel explicitly prohibits individuals from signing up for an account while underage or utilizing the service under
another's name.

B) Breach of University and NCAA Policies: EYIOMA UWAZURIKE's use of an account associated with a non-
athlete individual allowed him to circumvent scrutiny and sidestep university and NCAA policies regarding student-athlete
sports wagering conduct. By using the identity of another, UWAZURJK.E was able to avoid detection and the potential
consequences of participation in a prohibited activity.

C) Unfair Wagering and Conflict of Interest: EYIOMA UWAZURIKE placed bets on Iowa State University athletic
events, including games and events sponsored by the NCAA and university. This raised concerns regarding unfair wagering
advantages, potential access to insider knowledge of athletic participants, and the potential for collusion-related activities.

D) Tax Implications: EYOIMA UWAZURJK.E's fraudulent activities also shielded him from potential state and federal
tax implications. By concealing his identity during his sports wagering transactions, any tax responsibilities would fall on the
staud-in's name listed on the account.

When placing wagers on the FanDuel platform, an individually unique "Wage Identifier" digital record is generated.
This number is a digital record utilized by FanDuel to distinguish one wager from all others. Each wager placed by FanDuel
generated a "Wage Identifier" digital record. Each "Wage Identifier" identified below correspond to a specific timestamped
wager placed by UWAZUR1K.E. The "Wage Identifier" listed are not all inclusive ofUWAZURIKE's sports wagering
activity; however, they all meet the following conditions:

1) Wagers routinely and consistently placed from UWAZURIKE's personal iPhone.

2) Wagering transactions that required possession ofUWAZURIKE's protected iPhone to unlock and access his FanDuel
account using a specific usemame and password.

3) Corresponded to EYIOMA UWAZURIKE's known locations, including his university residence and areas of the
university not routinely open to the public

4) Involved prohibited wagering activity related to sporting events, such as NCAA-sanctioned contests and events sponsored
by the Iowa State Athletic Department.

5) Transacted within Story County, Iowa.

The following "Wager Identifier" were transacted on an iPhone controlled by EYIOMA UWAZURIKE utilizing the
name RACHEL FRANCIS and the FanDuel User ID of 13763550.

FanDuel Wager Identifier:

13378133.53
13181223.53
6582292.526
6395654.526
6312590.526
 E-FILED 2023 AUG 01 11:57 AM STORY - CLERK OF DISTRICT COURT

Defendant: EYIOMA UWAZURIKE

CASE NO.: 2023010833
Page 4 of 4
5662608.526
5594198.526
5366612.526
3415582.526
2788741.526
2556011.526
2543639.526
2441095.526
534048.526
According to subpoenaed records, this FanDuel account (13763550), which was controlled by EYIOMA
UWAZURlKE, completed approximately 801 mobile/online sports wagers. These sports wagers collectively totaled over
$21,361. Four wagers were placed on Iowa State University football games, including the following 2 games UWAZURIKE
participated in:

09/11/2021 Iowa at Iowa State

10/02/2021 Kansas at Iowa State
Additionally, the account placed approximately 32 wagers on NFL Denver Bronco events and individual NFL
Bronco players. At the time the wagers were placed, UWAZURlKE had been drafted to the Broncos. These wagers included
the following NFL games:

09/12/2022 Week 1 Denver Broncos at Seattle Seahawks

09/18/2022 Week2 Houston Texans at Denver Broncos
09/25/2022 Week3 San Francisco 49ers at Denver Broncos
12/11/2022 Week 14 Kansas City Chiefs at Denver Broncos
12/18/2022 Week 15 Arizona Cardinals at Denver Broncos

Affiant

JOE ERION
COMMISSION NO. 747559
MY COMMISSION EXPIRES
Notary Public, State oflowa
The foregoing Complaint with attached affidavit having been filed before the undersigned, it appears from said
Complaint and Affidavit that there is probable cause to believe an offense has been committed and that the Defendant
committed the offense.

Dated this - - - - - day of - - - - - - ' 2023.

BY THE COURT:
Judge/Magistrate