E-FILED 2023 AUG 10 11 :18 AM STORY - CLERK OF DISTRICT COURT

Defendant: ISAIAH LEE

CASE NO.: 20230 10880
Page 1 of 4

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

DOB: - SSN: -
Address: 2222 STORM STREET
AMES, IA 50014 Criminal No. 2023010880

COMPLAINT

The Defendant, ISAIAH M LEE

is accused of the crime of TAMPERING WITH RECORDS,
in that the Defendant did, on or between the dates of 09/21/2021-0l/22/2023, in STORY County, Iowa, DID KNOWINGLY AND
INTENTIONALLY FALSIFY PERSONAL ELECTRONIC SPORTS wAGERING RECORDS BY CONCEALING ms
PERSONAL IDENTITY 1N SAID RECORDS WITH THE INTENT TO DECElVE OR CONCEAL A WRONGDOING
KNOWING HE HAD NO PRIVILEGE OR RIGHT TO DO SO,
in violation of Section 715A.5 oftbe Iowa Criminal Code.

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Subscribed in my presence and sworn to before me this / 0 .•---· of August, 2023.
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 E-FILED 2023 AUG 10 11:18 AM STORY - CLERK OF DISTRICT COURT
Defendant: ISAIAH LEE
CASE NO.: 2023010880
Page 2 of 4

STATE OF IOWA) ss. ISAIAH LEE

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 oflowa.

In Iowa, authorized sports wagering operates within a framework defined 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 ofregulations
drafted by IRGC, which aims to ensure the integrity of gambling activities and facilitate proper taxation (IAC 491-13 .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 efforts 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.
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 terms 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 of ISAIAH LEE conducting illicit wagering activities on the FanDuel sportsbook platform. ISAIAH LEE was a football
player for Iowa State University during the 2018-2019, 2019-2020, 2020-2021, 2021-2022, 2022-2023 seasons.

ISAIAH LEE engaged in a scheme with KAYLA COGGESHALL CAMERON enabling LEE to disguise his identity and
manipulate online/mobile transactions to create the appearance that sports wager transactions conducted by LEE were made by
CAMERON.

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

His actions contravened various legal and regulatory frameworks, including:

 E-FILED 2023 AUG 10 11:18 AM STORY - CLERK OF DISTRICT COURT
Defendant: ISAIAH LEE
CASE NO.: 2023010880
Page 3 of 4

A) Violation of licensed Sportsbook User Terms and Conditions: ISAIAH LEE's wagers on FanDuel also violated the platform's
User's Terms, 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: ISAIAH LEE'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, ISAIAH LEE was able to avoid detection and the potential consequences of participation in prohibited activity.

C) Unfair Wagering and Conflict ofinterest: ISAIAH LEE placed bets on games and events sponsored by the NCAA. LEE
placed 21 wagers on Iowa State University Football events while he was a Iowa State Football player. 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: ISAIAH LEE'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 stand-in's name listed on the
account.

When placing wagers on the FanDuel platform, an individually unique "Wager 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
"Wager Identifier" digital record. Each "Wager Identifier" identified below correspond to a specific timestamped wager placed by
LEE. The "Wager Identifier" listed are not all inclusive ofLEE's sports wagering activity; however, they all meet the following
conditions:

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

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

3) Corresponded to ISAIAH LEE'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" digital records were transacted on an iPhone controlled by ISAIAH LEE utilizing the name
KAYLA CAMERON and the FanDuel account of 13749049.

FanDuel Wager Identifiers:

27382480.53
27379793.53
26949729.53
14362591.53
14157872.53
9159855.526
9159822.526
4094697.526
3496669.526

According to subpoenaed records, this FanDuel account (13749049), which was controlled by ISAIAH LEE, completed 115
mobile/online sports wagers totaling over $885. The account made 21 wagers involving the following Iowa State University Football
events which LEE participated in:

10/16/2021 Iowa State at Kansas State

10/23/2021 Oklahoma State at Iowa State
11/06/2021 Texas at Iowa State - Money line Wager for Texas and against Iowa State
 E-FILED 2023 AUG 10 11:18 AM STORY - CLERK OF DISTRICT COURT
Defendant: ISAIAH LEE
CASE NO.: 2023010880
Page 4 of 4

11/13/2021 Iowa State at Texas Tech

11/20/2021 Iowa State at Oklahoma
11/26/2021 TCU at Iowa State
12/29/2021 Iowa State at Clemson
09/03/2022 SE Missouri at Iowa State
09/10/2022 Iowa State at Iowa
09/17/2022 Ohio at Iowa State
09/24/2022 Baylor at Iowa State
10/01/2022 Iowa State at Kansas

ISAIAH LEE and KAYLA CAMERON were both interviewed, and both were cooperative with DCI investigato
rs. LEE
acknowledged he had created a FanDuel account utilizing his fiancee's, KAYLA CAMERON, personal
information.
CAMERON acknowledged LEE had a FanDuel account in her name and that it was improper for LEE to
place bets because
he is an NCAA athlete. CAMERON told DCI investigators she does not have a betting application on her
phone and has never placed
a sports bet.

,(vi Affiant
Subscribed and sworn to before me this /O day of August, 2023.

/j~~IAL.s,~ JOE ERiQ;,1

:z .... ~ COMMISSION NO. 747559 \j \_/
-I< Ill I )f MY. C0fv1_MISS/ON EXPir?E,. ,.--t----"c- ----::-'lti= c--~""-'.., ___;_ _ _ _ _ _ _ _ _ _ __
IOW1' 1
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