This action might not be possible to undo. Are you sure you want to continue?
4. l am submitting this affidavit for the lim ited purpose of showing probable cause for the
requested criminal complaint and arrest warrant. l have not included every fact I have
learned 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-fighting
ventures in violation of 7 U.S.C. j 2156 (a) including sponsoring or exhibiting an animal
in, attending, or causing an individual who has not attained the age of 16 to attend, an
animal fighting venture. ln addition, D. STUM BO'S animal-fighting venture is in violation
of 18 U.S.C. j 1955 (a): Whoever conducts, ûnances, manages, suptrvises, directs, or
owns all or part of an illegal gambling business.
' f the United States Code prohibits sponsoring or exhibiting an 6
Title 7, Section 2156 (a) o
animal 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. An
illegal 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 more law of a State or po
persons who conduct, finance, manage, supervise, direct, or own all or part of such
business, and (iii) has been or remains in substantially continuous operation for a period in
excess of thirty days or has a gross revenue of $2,000 in any single day. This investigation
will show that the lllegal gambling business outlined herein was conducted by numerous
individuals 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 State
where it would not be in violation of the law, it shall be unlawful under this subsection for a
person to sponsor or exhibit a bird in the fighting venture only if the person knew that any bird in
the fighting venture was knowingly bought, sold, delivered, transported, or received in interstate
or foreign commerce for the purpose of participation in the fighting venture.'' Kentucky Revised
Statute 525.1 30 provides that a person is guilty of cruelty to animals in the second degree when
he 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) legged
animal is caused to fight for pleasure or profk), mutilation, beating, torturing any animal other
than a dog or cat, tormenting, failing to provide adequate food, drink, space, or health care. See
Munn v. Kentucky, 889 S.W.2d 49 (Ky. App. 1994) (birds are included in statutory definition of
fkanimal'' 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 in
the 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 promote
gambling when he conspires to advance or profit from gambling activity
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 2 of 32 Pageid#: 5
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 cock
fighters will pit their roosters against one another for the entertainment of others and to
enrich 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 of
their 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 the
rooster to cause injury to other animals when it kicks with 1ts leg. This is the rooster's
primary means of intlicting injuly Cock ighters shave the bird's natural spur down to a
small point, and then supplement the birds fighting ability by attaching a gaffe or knife to
the bird's leg. The gaftk is a Iong curved spear, while the knives are pointtd blades
sharpened on one or both sides in various lengths. These metal implements are attached to
a small, soft leather collar that has a hole in it. This collar, and the attached weapon, are
wrapped around the bird's ankle and fit by means of the collars hole over the shaved down
spur 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 in
other 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 are
stabbed, slashed open, eviscerated, and partially decapitated. Birds that lose a match most
often die. lt is not uncommon for winning birds to die shortly after a fight or be unable to
continue 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 using
veterinary 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 many
people can fight their trained birds against the fighting birds of other people. These
depending on the level of sophistication, will have multiple pits to host çémain
fights'' and drag pits to accommodate fights in the m ain pit that have lasted too long and
lost the interest of the spectators. These arenas will often have pennanent stadium-style
seating, electricity, plumbing, concessions, and ample parking for participants and
l 3. Owners often have schedules professionally printed that show the dates of the fights that
people can enter and spectate. Owners distrlbute these schedules by various means to
enhance participation and attendance at their organized fights.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 3 of 32 Pageid#: 6
l4. Owners charge participants a set fee to enter his or her birds into a derby. This fee may be
anywhere 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 tie
with the best win/loss record then the pot is split between them .
Owners enrich themselves by keeping a percentage of the pot, charging participants for
extra ddoptions'' or Ssinsurance'' (which may increase a participant's chance of winning more
money), charging spectators to park at the pit, charging a fee for spectators to get into the
event, 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 bird
keeps at the pit location. A keep is a wooden hut with multiple compartments to house and
segregate 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 began
investigatinj targets in the Wise County, Virginia area in 2012 for the illegal manufacture
of untaxed llquor. The VABC has observed a strong relationship in the past between the
culture of manufacturing untaxed liquor and the culture of animal fighting in the rural parts
of 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 a
felony, many Virginia bird fighters were travelling across state lines to fight their blrds in
Kentucky. At this point the VABC contacted USDA OIG for assistance conducting an
interstate investigation. As part of this investigation it was discovered in 2013 that D.
STUMBO was operating a continuous animal ûghting exhibition (cock fighting pit) in
Kentucky 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 VABC
agent (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 and
April 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 with
this investigatlon were deputized as Special Deputy U.S. M arshal's in the Western District
FACTS TO SUPPORT PROBABLE CAUSE
l8. On 2/23/13 the UC agents travelled to the described pit in KY. lt is called BlG BLUE
SPORTSMEN'S CLUB ($$B1G BLUE''), and is located in McDowell, KY at
longitude/latitude 37.449489/-82.766925 (The UCs were equipped with GPS tracking
devices). 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 only
after mentioning the name of a prominent Virginia bird fighter and BlG BLUE member
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 4 of 32 Pageid#: 7
CCD. ROBlNSON''I, who had vouched for them, and whose name security had written
down 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 ighting
cocks are maintained prior to Gghting on the surrounding parking lot. The sghting
derby 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 on
the inside of the building that allow members to store there fighting cocks in. These
rooms all have secured doors to them. There is a full service restaurant inside that has
many tables and seats for patrons. In the restaurant area, there is a secured glass cabinet
that has many products such as penicillin, strychnine, and other ItX type products that
are used for the fighting cocks. These products are for sale. There are also several
gambling 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 the
walls of known government informants that have been identified. The main fighting
arena seats approximately 400 people and there are many drag pits that are in the
hallways as you enter the building.
The UCs went inside the m ain pit building where they had their photos taken and had
laminated lDs issued to them so they could return in the future. At one point during this
investigation, S. STUM BO, who was running the ID statioh, said they had over 6000
members stored on their computer system.
The UC's encountered D. ROBINSON here, who was sham ening gaffs for people and
running a b00th selling gaffs. The UCs had previously met D. ROBIN SON at his home in
Pound, 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 in
charge of the pit. This w/m subject went over numerous rules and was speaking from a
micro-phone inside the main arena. The UCs were unable to identify who this subject
was during this operation. This subject was later identified by additional contacts and
matching DL photos to UC video as D. STUM BO.
The UC's watched multiple organized fights at this pit, which had stadiunï seating, VlP
seating, concessions, main pits, drag pits, parking, bird keeps for rent, and fighting supplies
for 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 children
at 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 the
handlers in the arena. While conducting this operation, UC 1 lost $50.00 on a bet in the
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 5 of 32 Pageid#: 8
drag pit and UC2 won $65.00 in the main arena. UC1 observed several subjects win
approximately $700.00 while betting on these fights.
The UCs observed many fights in the main arena and the drag pits that involved
gruesome, bloody fights often to death of a fighting cock. The dead fighting cocks were
placed in a 50 gallon metal barrel inside the building near the entrance and drag pit area.
The UCs also observed several dead fighting cocks that wcre outside in the parking lot
area near the private keeps.
On 3/21/13 UC1 was at the residence of JONATHAN ROBINSON (d$J. ROBINSON'')
and D. ROBINSON in Pound, VA. UCl asked Dean if he/she could purchase a pair of
fighting gaffs and get his/her knife sharpened. Dean agreed to this and they went inside
D. ROBIN SON'S workshop. J. ROBIN SON assisted D. ROBIN SON in preparing UC1
a 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 about
the amount of m oney he m ade m anufacturing and selling fighting gaffs at B1G BLUE in
KY. D. ROBINSON advised that he would average about $1,500.00 a weekend when
he traveled to B1G BLUE to sell them. At a standard price of $80.00 a set, that would
mean 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 two
UCs 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 UCs
across the state line to BIG BLUE in KY.
They arrived at BlG BLUE at approximately 7:00am . The front gate was open with no
security employee on duty; however the second check point was controlled by a w/m
subject. This w/m subject collected $40.00 for a parking fee and allowed them to
proceed into the pit area.
Once at the facility, they unloaded the fighting cocks from J. ROBINSON'S truck into a
secured keep maintained by J. ROBIN SON . He advised UC1 that he rented this keep
for $700.00 a year and paid the pit owner the rental fee. UC 1 observed approximately
100 private keeps outside the main pit in the parking lot where J. ROBINSON 'S keep
was 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 and
weigh the cocks and place bands on their legs with designated numbers. An unknown
w/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 an
em 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 for
the derby. They went inside the large building and up the stairs to the control table that
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 6 of 32 Pageid#: 9
announced and controlled the Gghts. This table is beside a large board that shows the
derby 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 at
the 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 a
handler num ber and recorded the Cl's fighting cocks' inform ation. The fighting cocks
were designated as number (39) and J. ROBINSON was provided a sheet of paper with
the number (39) written on it. UC1 attached this paper number showing (39) to the back
of J. ROBINSON 'S shirt. This number corresponded with the entry num ber
representing the UCs fighting cocks on the board.
On this date, J. ROBINSON also handled fighting birds for another bird owner. This
second 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 the
m 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 records
showing the handler numbers in a column with the wins and losses. After the CIs
entered their fighting cocks, they went back to the keep. J. ROBINSON explained that
he would be the handler and be in the pit with the fighting cocks and place a1l the bets
for the day. UC2 and UC1 were there as spectators in the general seating area where
they 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 were
unloading fighting cocks into their keeps and conducting business with the control table
inside the pit.
UC 1 began to observe the many different vehicle state tag numbers. UC 1 observed the
following 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'' is
a practice fight that you can fight and gam ble on; however, it does not count in the
derby standings. The UCs agreed to fight one of their fighting cocks in this event. This
hack fight event lasted about two hours and they lost this fight and their m oney that was
wagered on the fight.
The UCs observed that the crowd was alm ost full at this time and approxim ately 250
subjects 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 bags
outside and put the money in a white Suv/-rahoe Kentucky tag number 4663 DN (This
vehicle is registered to W ALTER STUM BO and SONYA K . STUM BO, 773 Frasures
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 7 of 32 Pageid#: 10
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 later
alerted them when a w/f subject left the pit in this subject vehicle. The driver of this
vehicle 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 with
Special Agent Pamela Schwartz of USDA-OIG picked up this vehicle traveling from
the 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 several
hundred yards to where 122 continued south and 680 split off to the left in an easterly
direction. The vehicle took the left onto 680. The agents did not imm ediately follow
the vehicle down route 680, as they were unfam iliar with the area and feared following
the subject down a dead end road. ln actuality, at this point 680 goes in a south east
direction 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 residence
located 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 Rt
680 towards Frasure's Creek Rd. As they travelled the .9 m ile stretch of 680 leading to
Frasure's Creek, they encountered the same white SUV, KY tag 4663 DN, travelling
from the direction of Frasure's Creek, past the agents, in a Northwest direction back
towards 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 a
lot of m oney from parking fees, keep rental, and the restaurant that was operated inside
the building (pit). The restaurant served a full breakfast and a lunch menu. This
restaurant rem ained busy all day and made a large am ount of money. UC1 also
observed D. STUM BO collect money on several occasions from the restaurant
employees. This m oney was placed in m oney bags and later put in the white SUV
k'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 C
Silverado 4-wheel drive truck.
lt was very apparent to UC1 that the STUM BO fam ily was in control of the operation at
this facility. D . STUM BO was constantly w alking around, giving orders to the
employees, and collecting a large am ount of money. D. STUM BO announced the rules
prior to the derby starting. At the end of the derby, D. STUM BO announced the winners
and handed out the trophy.
After observing all the large amounts of money that was in the possession of the
STUM BO'S during this operation, UC l asked J. ROBIN SON how do the STUM BO'S
keep this m uch money safe during a two day derby? He advised UC1 that D . STUM BO
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 8 of 32 Pageid#: 11
would take the money back to his residence and secure it in a safe. He would then take
it 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 fighting
gaffs at a work table inside the building. UC2 later purchased a set of fighting gaffs for
fighting purposes from D. ROBINSON. UC1 observed many subjects purchase fighting
gaffs from D. ROBINSON and paying with cash. UCl also observed some of these
subjects 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 handling
a brief case full of money inside his vehicle. The vehicle showed a M ichigan tag
UC l observed several people using the slot m achines in the kitchen area. He/she
observed several subjects put money in the slot machines, however, he/she did not
observe anyone collect any money from these slot m achines. UC1 had a conversation
with a w/f who advised him/her that the slot machines worked and that she had won
money in the past from playing these slot machines.
The UCs participated in a five-cock recorded derby and there were approxim ately 86
entries on that day. The UCs, with J. ROBm SON handling the birds in the pit, won a11
five 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 the
money or pay the m oney out after the fight. UCs observed side betting on these fights as
well, which m ade it difficult to record and observe al1 the transactions. These side bets
occurred in the m ain fighting pit and the drag pits. UC 1 observed several fights in the
drag pit that were going for $2000.00 or more a fight. UC1 lost approximately $100.00
in side bets in the drag pits.
UC1 observed that m ost of the cocks that fought in the drag pits were killed and placed
in metal barrels. On one occasion UC 1 observed a Hispanic male put a severely injured
cock in the m etal disposal barrel that was still alive. This cock was still moving and
breathing. 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 s
and called thtm to the center of the m ain fighting pit. lt was decided that all 4 winning
teams would split the cash pot. UC1 observed J. ROBIN SON go to the control table and
receive the m oney that he won from the fights. J. ROBINSON walked over to UCl and
UC2 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. UC1
handed 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 to
Timothy M ullins, who appeared to be under 18 years of age and who assisted J.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 9 of 32 Pageid#: 12
ROBIN SON in affixing the fighting gaffs on the cocks. UC 1 had already tipped
Timothy $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 the
pot. The undercover agents also won $300.00 in side bets on this day. The total cash
winnings, after pay-outs, were $3,680.00.
At the end of the derby, the UCs assisted J. ROBINSON with the loading of the fighting
cocks 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 residence
in the Pound area of W ise County, Virginia. J. ROBINSON and D. ROBINSON were in
the work shop on the property making fighting gaffs.
The UCs had a conversation with D. ROBINSON and he informed them he was preparing
and 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 pit
operation at the BIG BLUE in KY. UCl engaged D. ROBINSON in conversation about
the 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 people
would bring to the pit to gamble with. During this conversation, UCl asked him how the
STUM BO family kept from getting robbed and losing the Iarge amounts of money made at
the pit. D. ROBINSON advised UC1 that during a two day derby, the STUM BOS would
secure much of the cash at their residence so as not leave a large am ount of cash on site
overnight. D. ROBINSON then went on and talked about the Mexican Mafia (a large, well
organized criminal gang and drug cartel) and that this organization had been to BlG BLUE
in 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 security
measures in place.
While the UCs were at this location, two unknown w/m subjects arrived in a truck with
Tennessee tags. The two males told the UCs they were there to pick up some fighting gaffs
that would be used in a cock fight at another pit on Saturday in Kentucky. UCl later
observed 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 purchased
fighting cocks. Their condition seemed to be fine and UCl asked J. ROBINSON about
when they could stage another fight. UCl explained that he/she would be in town next
week and would like to stage a private fight in Virginia. J. ROBINSON advised that he
would see what he could set up and get back with UCI. W hile checking on the sghting
cocks, UC1 asked J. ROBINSON how much money UC1 owed him for feeding and caring
for the fighting cocks. They agreed on $50.00 and UCl paid this money to J. ROBINSON
for his services and feed.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 10 of 32 Pageid#: 13
The UCs then went back to the main keep with J. ROBINSON and checked the condition
of 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 sell
him/her. J. ROBIN SON advised that he was going to town at dark time and would try to
get some pills and marijuana. J. ROBINSON said to call him back after 9:00pm and if he
had 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 in
loading 13 fighting cocks in vehicles to take to Kentucky to engage in animal fighting at
B1G BLUE. They loaded 7 fighting cocks into J. ROBINSON 'S truck and 6 fighting cocks
into 6IPAUU S'' SUV. UC1 was able to video this activity and also the tag numbers on both
vehicles used to transport these fighting cocks to Kentucky. A review of the video by this
am ant shows that the black Ford Explorer under the control of CTAUL'' bore Virginia tag
ZD 2744. That vehicle tag is registered to a 2004 black Ford truck in the names of Paul
Farm 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 another
person and also pick up TIMMY MULLINS (the minor boy from the 4/13/14 derby) at the
Pizza Plus located in the town of Pound, Virginia. UC1 and UC2 followed J. ROBINSON
to this location and they met up with an older w/m subject who identised himself as
JIMMY 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, Box
41 8, Clintwood, VA, DOB 8/7/38.
W ILLIS rode with J. ROBINSON and they then went to pick up T. M ULLINS at his
residence. 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 going
through the check points, the UCs encountered the same w/m subject from prior derbies at
the 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 were
posted on the second check point shelter. UC2 had lost his parking penuit card and was
required to pay additional money ($20.00) to enter. UC2 had a conversation with this w/m
subject about this and was advised that D. STUMBO, the pit owner, made this decision and
security guard had to enforce it.
After entering and parking at the pit Iocation, UC 1 immediately began to check for vehicle
tags from different states. UC1 observed vehicles from the following states; Virginia, W est
Virginia, 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 were
taken from the ROBINSON residence that morning in Pound, Virginia. These fighting
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 11 of 32 Pageid#: 14
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 and
the entry fee was $250.00 (98 x $250.00 = $24,500). At the peak of the day, UC1 observed
approximately 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 setting
things up and showing that they were in control of this operation. S. STUM BO was making
announcements on the microphone and S. STUM BO was operating the picture ID cards
station that are used to make the cards that are used as parking permits and membership
cards. UCl observed J. STUM BO working with the ladies that were collecting the entry
fees and handling the paperwork in the pit.
During this operation, UC 1 observed over 50 cock fights. He/she observed gambling
activity between subjects in the main arena and drag pit. This included many cash pay outs
of large amounts of US currency. UC1 placed bets on several cock fights and lost
approximately $40.00 during the day.
There were many controversial issues in the drag pits, where some handlers became
agitated and almbst had physical contact. The referees had to call D. STUM BO on many
occasions to calm the situation dpwn and in some cases, remove a handler who violated
During this operation, UC 1 observed D. ROBINSON sharpening tlghting gaffs that were
being used in the cock fights. UC1 also observed many subjects paying D. ROBINSON
cash 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 the
fight but still alive. J. ROBm SON instructed the boy TIM M Y M ULLm S to finish the
cock off. TIM M Y M ULLINS attempted to choke the cock to death and placed him in a
metal barrel. UC2 later observed the fighting cock still alive and moving around in the
UC1 also observed several young boys that appeared to be under ten years old, handling
fighting 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 several
unknown 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 that
the $20.00 parking permit fee was the same as a membership fee. The reason he did not
put the club name on the membership card/parking permit was to avoid trouble with 1aw
enforcement if police came into possession of the photo ID card. He told the men that by
riot revealing the club identity, law enforcement would have no idea what the ID card was
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 12 of 32 Pageid#: 15
UC l and UC2 later had a convcsation with S. STUM BO about why UC2 had to pay an
additional $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 system
and 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 fee
anyway, and that all members had to pay the $20.00 fee to get into the facility. UC2 then
provided his new ticket stub to S. STUM BO and obtained a new club membership photo
S. STUMBO advised that the dld membership photo ID cards had the words ''Big Blue
Sportsman 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 avoid
attention 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 into
possession of the ID card.
D. STUMBO advised that the $20.00 parking permit fee was the same as paying an
admission 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 held
at Big Blue during the 2013 fighting season, the number of birds each entrant can fight at
the derby, what kind of weapons the birds will be allowed to use, and how much insurance
options 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 located
in tht Pound area of W ist County. UCl made contact with J. ROBINSON and assisted
him in feeding and watering the fighting cocks. J. ROBINSON took UCl to the main keep
and showed the UC the fighting cocks he was going to take to Kentucky to fight in the
coming 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 get
their 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 federal
probation from a federal drug investigation in Kentucky. R. CANTRELL advised that he
pulled time in the Beckley, West Virginia prison. R. CANTELL advised UC l he was a big
time cock fighter ''in the day'' and he wanted to gd back into the business. He has been
laying low since he was on federal probation, but he was preparing to fight cocks this
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 13 of 32 Pageid#: 16
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 in
Kentucky. R. CANTRELL asked J. CANTRELL to 1lk to D. STUM BO about letting him
com e back to his pit.
W hile talking with R. CANTRELL, PAUL FARM ER showed up driving a new appearing
Silverado 4 X 4 pick-up truck. UC1 attempted to video this truck and tag number. UC1
observed some chicken cages used to transport fighting cocks in the front passenger seat of
PAUL 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 sparred
5 sets of fighting cocks.
J. ROBINSON and R. CANTRELL placed the rubber boxing gloves on the birds before
each Gght. It was apparent R. CANTELL was trying to pick out some fighting cocks to
take to a derby. After spaning these fighting cocks, R. CANTELL picked out the best two
and advised that he would be back later.
UCl then went with J. ROBINSON and assisted him in feeding the fighting cocks that
were outside the keep connected to barrels. W hile feeding the cocks, J. ROBINSON
showed UC 1 approximately 20 marijuana plants that he was growing. These plants were
very sm all and placed in plastic conliners. They were hidden well, as the UC had first
walked past them without seeing them. These marijuana plants were located behind J.
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 CIROGER
LNU'') that UC 1 had never seen before. ROGER LNU was picking up some fighting gaFs
from D. ROBINSON. UC1 attempted to get his physical description and vehicle tag
number on video. The vehicles in this video depict a blue pickup truck with a Kenm cky
plate 270NAT, and a red pickup truck with Virginia plate 288511M . The Kentucky plate is
registered to Pamela S. Bartley, P.O. Box 215, Ashcamp, Kentucky. The Virginia tag is
registered 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 afia
sending 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 this
area 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 bedroom
ftoor of his house.
UC1 brought up the fact that he/she had seen an Asian male subject with a brief case full of
money at the B1G BLUE PIT in Kentucky. D. ROBm SON advised that was a common
occurrence and that there were large amounts of m oney gambled during cock ûghts at BIG
25. On 06/27/13 at approxim ately 6:30 pm, UC1 arrived at the ROBINSON residence in
Pound, VA. UC 1 met with J. ROBIN SON who advised that he would not be able to go out
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with UC l that evening. J. ROBINSON advised that his son decided to come home and he
would have to stay with him . UCl assisted J. ROBINSON in feeding the chickens while
he prepared some traps to attempt to catch some predators that were killing some of his
After this work they both went to the main keep and prepared some of the fghting cocks
for the upcoming weekend fight in Kentucky. J. ROBFNSON advised UCl that the
fighting season was almost over due to the molt season. J. ROBINSON showed UC1
evidence where his Gghting cocks were beginning to lose their feathers. J. ROBINSON
explained that the molt season lasted until mid-November.
UC1 asked J. ROBIN SON when they could flght their cocks again. J. ROBINSON advised
UCl that his last entry to fight cocks would be July 13th, and that the next best time they
would be able to fight birds would be in January or February of 2014. J. ROBINSON
continued to explain that the m olt season was coming early this year and he m ight not be
going back to Kentucky until late fall.
UC1 asked J. ROBINSON about the pills he/she had ordered and J. ROBINSON advised
that thty wtre still not in. J. ROBINSON txplained that his fricnd was getting the pills
directly from a subject named RUSSELL PEAKS (SCPEAKS''). He said that PEAKS had
recently pulled time for selling drugs and was back in business again. J. ROBINSON told
UC1 to check back with him on Friday morning and he would 1et UC1 know if the pills
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 he
would keep one or two for UCl to buy on UC1 's next visit. UCl thanked J. ROBW SON
and 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 residence
in Pound, VA. J. ROBINSON invited them in. During this visit, the CIs observed four long
guns 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 they
came 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 they
had an injured fighting cock that needed to be put down due to the eye injury that came
from a previous cock fsght in KY.
28. On 07/12/13, at approximately 12:20 pm, UCl and UC2 arrived at the ROBINSON
residence 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 in
his bedroom. J. ROBm SON took the UCs into his bedroom and showed them the guns
and explained the history on some of them. Also during this visit, R. CANTRELL
expressed interest in working for UC1's fictitious automobile repossession company and
later completed an application providing a1l of his personal information.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 15 of 32 Pageid#: 18
UC1 had a detailed conversation with R. CANTRELL about his involvem ent in
cockGghting. R. CANTRELL told UC1 that he was one of the best cockighting handlers
in the area and that he was connected to some M exican cartel gang members. Roger
advised that in the past, before he went to federal prison, his M exican conucts would tly
him from W ise County with ûghting cocks to M exico to handle and flght the gamecocks
R. CANTRELL explained that his M exican friends were preparing to set him up in
Alabama with a home and facility to raise, train and prepare gamecocks for derbies in
M exico and abroad.
R. CANTRELL explained that his federal probation would be over in November and that
he 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 on
the property. J. ROBm SON again suggested that the injured cock that the UCs had
purchased and that ROBINSON was training and maintaining, needed to be put down and
was taking up space and feed for no gain. J. ROBINSON suggested that the UCs Gght the
injured cock and another injured cock that they had. UC1 did attempt to get out of fighting
the cocks; however, J. ROBINSON and R. CANTRELL were putting pressure on UC1 and
UC2 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 and
placed gaffs on them in front of the UCs. UCl and UC2 later conducted this fight in a
shady spot on the ROBINSON property under the supervision of J. ROBINSON and R.
R. CANTRELL also was involved in handling one of the fighting cocks and J. ROBINSON
was 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 put
down anyway. The fighting cock UC1 was handling was severely injured and suffocating
on his own blood. J. ROBFNSON instructed UC1 to suck the blood out of the cock to keep
the cock alive to continue the fight.
At the end of the fight, J. ROBINSON took the gamecock that UC1 was fighting and
smashed the gamecock's head against a tree to kill it. At this time, the group saw some
older 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 make
it look still alive. UC1 later placed the dead fighting cock in a barrel near the building
where the ROBINSON'S m anufacmred the fighting gaffs. Before leaving the ROBINSON
residence, J. ROBINSON made several phone calls attempting to set up drug and untaxed
liquor 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 conversation
about the upkeep of the fighting cocks and untaxed liquor. UC1 asked J. ROBINSON
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 16 of 32 Pageid#: 19
whdher or not he had any pills for sale and ht advised that they could go down the road to
PEAKS' 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 the
vehicle, UC 1 observed several marijuana plants in 5 gallon buckets that were beside the
outbuilding on the PEAKS' property. They were approximately 4 feet tall and appeared in
UC1 observed J. ROBINSON go inside the residence of PEAKS and they both later came
out and walked behind the trailer. UC1 observed PEAKS and J. ROBm SON make hand to
hand contact that appeared to be a drug buy.
J. ROBINSON later walked back and got into UC1's vehicle. UC1 asked J. ROBINSON
whether or not he got the pills and J. ROBINSON advised that he purchased $100.00 worth
of Roxie pills from PEAKS.
J. ROBINSON then suggested that the UCs go back to his trailer. They arrived back at
the 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 in
getting 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 smaller
pills were $30.00 a pill. Before UC1 could respond, J. ROBINSON had crushed up the
large 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 down
and pinched as much powder as he/she could into his/her fingers and simulated snorting the
remaining powder. J. ROBm SON had prepared two lines of powder and after UC1
simulated snorting the one line, he/she allowed him the take the remaining powder UC1
had left over and add it to his line of powder. UC 1 then observed J. ROBW SON snort the
remaining Roxie powder.
J. ROBINSON told UC 1 that PEAKS could get as many pills as they wanted and that they
were aIl strong pills in the oxycodone family. J. ROBINSON also informed UC1 that
PEAKS 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 in
filling 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 located
and 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 him
and smoked some marijuana while they were down there. J. ROBINSON offered UC1
some hits of his marijuana; however, UC1 advised J. ROBINSON that due to recently
failing a drug test at work, he/she could not do any illegal drugs for a while.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 17 of 32 Pageid#: 20
J. ROBm SON advised that he recently purchased over one ounce of good, homegrown
local marijuana and that most people that were growing ''pot'' in their area had already
harvested the crop due to cold weather and a recent frost.
They walked around the property and checked the condition of the fighting cocks and they
appeared to be in good condition. J. ROBINSON advised that the cock fights in December
through February were not so good and that m any times there were not enough entries to
make going to Kentucky worth his while.
J. ROBINSON boasted on the fact there would be several nine-cock derbies and the W orld
Cup 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 he
could not wait until his business started up again.
Jonathan told UCl to come back in the morning and they would finish checking out the
fighting cocks due to dark time setting in. UCl left the ROBINSON residence at
approximately 7:41pm .
31 . On 1 0/1 1/13 at approximately 1 l :08 am, UC1 arrived at the ROBINSON residence and
met 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 of
marijuana from J. ROBINSON for $25.00. Before and after this drug buy UC1 observed
weapons 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 ROBINSON
fam ily. D. ROBm SON and J. ROBINSON were eating dinner at D. ROBINSON 'S house
and invited UC1 in. UC1 had a lengthy conversation with both of them about the welfare
of the purchased fighting cocks and inquired about the 2014 cockfighting season. UC1 also
provided 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 the
condition of the purchased fighting cocks.
They a11 talked about the upcoming cock fighting season and J. ROBINSON said it would
not be worth the UC's tim e fighting until mid-M arch 2014. J. ROBINSON advised that
du< 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.
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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 he
could 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 talked
about the large amount of money that would be there during this event and that the derby
winners would make a large amount of money. UC 1 then left the ROBW SON residence at
34. On 02/20/14 at approximately 5:30 pm, UC1 arrived at the ROBW SON residence. Here
UCl made contact with J. ROBINSON and D. ROBINSON in D. ROBINSON 'S work
shop where they were both manufacturing and working on fighting gaffs. UCl observed a
very 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. He
mentioned one customer from Kentucky that was on his way to pick up over $700.00 worth
of gaffs. Later in the day, UCl observed this customer come to pick up the order from D.
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 to
the 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 to
continue to operate his pit in KY. D. ROBm SON advised that after consulting legal
advice, 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 ROBINSONS
advised that fighting cocks were not labeled as ''anim als'' but as ''fowlf', therefore the new
law 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 UC2
would be back the next day to visit and check on the fighting cocks. UC1 left J.
ROBINSON'S residence at approximately 7:00pm .
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 19 of 32 Pageid#: 22
35. On 02/22/14 at approximately 1 :00 pm, UC1 and UC2 m et with J. ROBINSON at his
residence in Pound, VA. The UCs assisted J. ROBINSON in watering and feeding the
chickens on the property. There were approximately 400 chickens on the property
according to J. ROBINSON .According to UC1's observations, there were inadequate
living conditions for al1 the birds on the property. There was little water and bedding
available for all the birds that UC l observed. M any were restrained by a cord connected to
a plastic barrel. The barrels, which were supposed to act as shelter, were heavily saturated
by water on the ground.
J. ROBINSON suggested that they spar some of the fighting cocks to see what their
condition was. UC 1 put the plastic fighting muffs on the spurs of two selected Gghting
cocks. 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 fight
at the BIG BLUE pit in Kentucky, J. ROBINSON said the entry fee is expected to be
between $3,000.00 and $5,000.00 per entrant. J. ROBINSON advised that this would be the
biggest 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 the
keep to select and Ioad the fghting cocks that J. ROBINSON would fight at the derby in
the REDBUSH, Kentucky pit. (Note: J. ROBINSON was taking the UCs to a secondary
organized fighting pit in Kentucky because of D. STUM BO cancelling the weekend fight at
BIG BLUE. See 2/20/14).
W hile near the keep, UC1 observed R. CANTRELL arrive and he later assisted in selecting
and loading the fighting cocks into J. ROBINSON'S truck. After the fghting cocks were
loaded onto J. ROBINSON'S trtzck, J. ROBINSON placed the fighting gaffs in UC1 's truck
and told UCl to carry them to the pit. (J. ROBINSON did not want the gaffs and birds in
the same vehicle due to the criminality of animal fighting)
J. ROBINSON and R. CANTRELL rode together in J. ROBINSON'S truck, while UC1 and
UC2 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 attend
the cockGghting derby.
The group left R. CANTRELL'S residence in the Pound area of VA at approximately
3:00pm . They arrived at the pit in REDBUSH, Kentucky approximately 5:50pm . This pit
is off of Salyer Branch Rd in Flatgap, KY 4121 9. The GPS that the UCs were carrying put
them at a standing structure located approximately at longitude/latitude 37.937648,-
UC 1 describes the entry to the pit location in REDBUSH as a long dirt road that goes up a
very steep incline to a tlat location at the top where the pit is located. There are two gates
located on this road and they b0th are able to be secured by a lock. At the top of the hill
where the pit is located, there is a building used as a checkpoint. There was a w/m subject
standing near this location and he collected $20.00 a person for an admission fee to attend
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 20 of 32 Pageid#: 23
this cock fightinj derby. He provided them a ticket each and a piece of paper and told them
to 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 the
building as well as keeps inside the building. They entered this building and observed a
restaurant area in the front where cock fighting supplies were also being sold. There was
also an area in the rear of the building where an unknown w/m subject was selling and
sharpening 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 main
fighting 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 for
J. ROBm SON'S ûghting cocks. The person that appeared to be running and controlling this
pit operation was later identified as having the last name of SPENCER. SPENCER was
collecting the entry fees and announcing the rules and calling on the handlers during this
entire 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 in
the parking lot and attempttd to obtain video of important features of this fighting pit. UC1
also observed and attempted to get video of vehicle tags in the parking lot. There were
signs 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. UC1
observed 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. This
illegal gambling occurred in the main pit and the drag pits. UC1 later lost $70.00 ln bets in
the drag pits. He/she observed many subjeds winning very large amounts of cash during
these cock fights. UCl attempted to video as much illegal gambling as possible while
considering officer safety. There were video cameras set up all throughout the building.
UC1 observed the J. ROBINSON, R. CANTRELL, TIMM Y MULLINS (minor), and
PEAKS fighting cocks during this derby. They were a11 filmed lghting cocks during this
investigation 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 very
youthful appearing subjects in attendance durlng this fight. There were approximately three
hundrid subjects attendinj this cock fight. He/she observed a very large number of
suspected employees monltoring the inside and outside of the pit. They all seemed to be
concerned about 1aw enforcement raiding the event. UC l had several conversations with
subjects that were talking about the new federal laws that were passed making it illegal to
attend animal fighting events. Due to the large amount of entries at this fight, UC1 was told
the 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.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 21 of 32 Pageid#: 24
They waited there for a while and were later met by an employee of the pit who opened the
gate for them. He made the comment that the gate was secure to keep law enforcement out
and 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 located
in the Pound area of W ise County, Virginia. UC1 made contact with J. ROBINSON at this
location and found out that J. ROBINSON had been very sick over the past week and was
cancelling his trip to fight birds in Kentucky during the coming weekend. J. ROBINSON
advised UC1 that he was not able to properly train and take care of the fighting cocks in the
keep or have them ready for the weekend derby,
J. ROBINSON provided UC1 with additional information on the new protocol for the BIG
BLUE pit in Kentucky. J. ROBIN SON stated due to fear of law enforcem ent raids, the
STUM BOS were locking the front gate to the pit at 9:00nm, and then placing a bulldozer in
front of the gate to prevent any vehicles from coming in or going out without the pit's
control. J. ROBINSON said when they went back to the BIG BLUE pit, UC1 should be
prepared to stay until the fight was completely over. He advised UC1 that the STUMBOS
may not open their pit in 2015 due to fear of the new laws related to animal fighting. UC1
left the ROBINSON residence at approximately 8:00pm.
37. On 03/21/14, at approximately 4:30pm, UC1 and J. ROBINSON travelled to an animal
feed 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. ROBINSON
to 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 by
STANLEY'S father, who was recently deceased.
After feeding and watering these chickens, UC1 and J. ROBINSON went back to the
ROBINSON 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 (in
this 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 Kentucky
and was a very close business partner. During this conversation, J. ROBIN SON asked if
UC 1 could put up the entry fee for the Kentucky State Chnm pionship at BIG BLUE. UC1
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 22 of 32 Pageid#: 25
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 up
part or all of the entry fee money.
After the work was done, UC 1 had a conversation with M RS. ROBW SON, FIRST NAM E
UNKNOW 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 of
cockfighting 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 to
where they could continue to fight legally. D. ROBINSON m entioned that D. STUM BO
was 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 the
fights at the BlG BLUE pit in Kentucky. D. ROBW SON said that D. STUM BO was
Iocking the front gate at 9:00am on derby days and then parking a bulldozer in front of the
main 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 preparing
his work order of gaffs to take to the upcoming derby fight at the B1G BLUE pit in
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 ROBINSON
residence located in the Pound area of W ise County, Virginia.
The UCs found D . ROBINSON and J. ROBINSON in tht stand-alone workshop on the
property. D. ROBINSON and J. ROBINSON were both manufacturing and finished
fighting gaffs. UC2 asked D. ROBINSON how many sets of gaffs he would be taking to
BlG 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 fighting
cocks. UC1 watered over two hundred chickens and many did not have any water at all. lt
was very obvious that they had not been watered in a while, as they consumed a large
amount of water immediately as he/she filled up their containers.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 23 of 32 Pageid#: 26
UC2 was asked to assist J. ROBIN SON and D . ROBINSON with manufacturing the
fighting gaffs in the workshop. J. ROBINSON showed UC2 how to cut and sew the
leather 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 silver
nickel. He paid about $500.00 for 200 pounds of it and had already used about 100 pounds
of that this year. UC1 observed J. ROBINSON and D. ROBINSON manufacturing the
fighting gaffs in the workshop.
UC2 asked J. ROBINSON and D. ROBINSON about the change in the Federal Law about
cock fighting. J. ROBm SON stated he was aware of the change and that he had spoken
with D. STUM BO about the same. J. ROBINSON said D. STUM BO told him he was
closing the cock fighting pit this year if the 1aw didn't change back to make it legal in
Sometime after 6:42 pm , UCl and UC2 assisted J. ROBINSON to load the sghting cocks
on 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 gate
to the pit was locked and they were unable to get the Gghting cocks up to J. ROBINSON'S
cock house at B1G BLUE. UCl observed J. ROBINSON call his father's home phone. His
mother 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 to
set the thermostat. They left the pit at approximately 10:30 pm and traveled back to the
After they arrived back at the ROBINSON 'S, UC1 and UC2 helped put the fighting cocks
back in the keep. J. ROBINSON advised UC1 and UC2 to meet him Friday morning at
5:00am in Pound, VA across from STANLEY'S feed and hardware business. The UCs left
at approximately 12:10 am.
39. On 04/4/14 at approximately 5:45am, UCl and UC2 met w ith J. ROBINSON and W ILLIS
in a parking 1ot across from STANLEY'S feed and hardware business. UC1 verised that
the fighting cocks were in the back of J. ROBINSON'S truck and J. ROBINSON later went
across the road to pick up STANLEY. They a1l left the Pound area at approximately
5:57am , and traveled to M cDowell, Kentucky to the BlG BLUE pit. UC1 and UC2 drove
UC1 'S vehicle and followed J. ROBW SON, STANLEY, and W ILLIS to the BlG BLUE
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 24 of 32 Pageid#: 27
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 second
gate as described by J. ROBm SON as an extra security measure to block the gate once the
cockfights started. The man that collected the money advised that there were no new
mem bers being accepttd at this time. UC1 observed a metal m oney box in the shed at the
second gate where currency was being stored from the admission fee. UCs had to provide
their previously obtained club membership parking pass prior to entry to this event.
Once inside the BIG BLUE compound, UC1 observed a large number of vehicles
registered 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. There
were 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 BO
was supervising the restaurant area and D. STUM BO was preparing the main fighting pit
while J. STUM BO was collecting the money for entry fees and processing the handler's
information. UC1 observed J. ROBW SON unload his fighting cocks and place them in his
cock house that he rents.
UC 1 then went into the main pit and asked J. STUM BO what the entry fee for this derby
was 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 WILLIS
would pay the $50.00 insurance fee. STANLEY approached UC1 and asked for his/her
money. UCl did not have the proper change, so he/she handed STANLEY $900.00. UC1
later 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 1
observed numerous other handlers pay J. STUM BO their entry fee as well. D. STUM BO
was also there when the UCs paid their entry fee and he was helping J. STUM BO handle
the 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 they
won the derby they would split the winnings four ways. The Gghting cocks that fought on
this day were STANLEY'S cocks and J. ROBINSON was the handler .'l-here were 49 total
entries m ade for this Kentucky State Championship cocksghting event. UCl observed over
two hundred people attending this cock fighting derby, and by the end of the event there
were approximately one hundred vehicles in the parking lot. The fight record for
STANLEY'S ighting cocks on April 4th was 1-3. (UCI was advised by J. ROBINSON
after the derby concluded that STANLEY'S birds went 4-0 on the second day of the derby
that the UCs did not attend. J. ROBINSON was the handler for STANLEY'S birds on the
second day as well).
th 'a js UC1 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. UC1
also observed PEAKS handle fighting cocks in the pit on April 4th.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 25 of 32 Pageid#: 28
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 on
between the patrons attending the cockfights and the handlers as well. He/she observed one
white male subject lose $ l ,500.00 on one fight in the main pit. UC 1 attempted to get the
illejal gambling on audio/video.
UC1 also observed several bloody cock ights and attempted to get many of these fights on
video as well. On several occasions during these fights, the handlers had to ring the neck of
the birds to put the fighting cocks down. The restaurant stayed full all day and served
breakfast, lunch, and a $14.00 steak and potato special dinner.
UC1 also observed several subjects playing the gambling/poker slot machines in the
restaurant area. UC1 observed D. ROBIN SON und his wife operating D. ROBISON'S
fighting gaff table. UC1 observed both D. ROBINSON and his wife accept cash for
shap 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 been
to BIG BLUE.
D. STUM BO provided a lengthy speech to the audience prior to the opening fight asking
for 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 cock
fight and charged with a federal crime. He further stated that there were people in
Kentucky government that were changing the federal law but couldn't publicly come out
and say it. He mentioned Alison Grimes and Greg Stumbo by name. D. STUM BO handed
out copies of some recent articles in support for the cock fighters by some lawmakers in
Kentucky. UC1 obtained a copy of these articles. ln these handouts it clearly states that the
new 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. There
was a laptop computer on the registration table where J. STUM BO was collecting the
money, and UC1 observed him use this computer. The UCs left the derby at approximately
5:42pm, before the derby concluded for the day. The main gate and the second gate were
secured until the last fight was over and UC1 did observe the bulldozer blocking the second
entrance gate/check point where the admission fee is collected.
40. During the summer of 2013 UC2 received from J. ROBINSON a printed 2013/2014 fight
schedule for the BlG BLUE pit. This schedule shows the cock fighting derbies scheduled
for each Saturday from December 7, 2013 through July 26, 2014, as well as the 2-day
derbies that occur on Fridays and Saturdays.
tb d 21St f 2013 and January One 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 th 4
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 th 19
26 , M ay 17 , 24 , 31 , June 14 , 21 , 28 , and July 12 , 19 , and 26 of 2014.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 26 of 32 Pageid#: 29
There are three 2-day derbies in 2014 listed on this schedule. These derbies are outlined on
the schedule with a black box. The first day of the derby occurs on a Friday and the second
day 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 April
th d 5th ç 2014 the CSW ORL
D CHAM PION SHIP'' on M ay 2nd and 3rd of 2014 and the 4 an o
CSHAW AIIAN SHOW '' on June 6th and 7th of 2014
. SEE SCHEDULE BELOW :
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Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 28 of 32 Pageid#: 31
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 29 of 32 Pageid#: 32
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 aining
half of the cash pot to his house after the first day of fighting for safe keeping. The money
is then brought back to the pit at some point during the second day to pay out the second
The UC agents have observed D. STUM BO during a one day derby collecting money
throughout 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 it
and 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 large
amounts of cash. The UC agents have never seen the cash taken from the registration table
and put into a safe on prem ises. They have only seen that cash placed in a vehicle under
the 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 to
be highly accurate during this investigation.
Both ROBINSONS had informed the UCs of the new security measures being taken at BIG
BLUE after the passing of the 2014 Farm Bill. This new law made it a federal crime to
spectate an animal fight. They told the UCs that there would be a bulldozer parked in front
of the gate to keep 1aw enforcement from raiding the pit. They told the UCs that once
people arrived in the m orning and the registration period was closed they would not be
allowed 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 of
these facts were proven true during visits to the pit.
ln the experience of this affiant and the experience of other USDA agents and law
enforcement offkers who investigate organized animal fighting, the BlG BLUE pit in
Kentucky is one of the largest, most organized, and lucrative illegal cock fighting
enterprises in the United States.
The printed schedule for BIG BLUE lists 34 days of organized animal Gghts during the
2013/2014 season. Based on calculations done by this affiant using information gained
during this investigation, it can be estimated that those 34 days of fighting will generate
over 1 million dollars in cash. There are anywhere from 50 to 200 participants at any
given derby, with anywhere from 100 to 300 spectators.
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 30 of 32 Pageid#: 33
For this entire operation, D. ROBINSON has been identified as the only vendor authorized
by 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 running
his sales operation.
Unfortunately, there are many people in this country still engaged in the practice of make
sghting 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 biggest
organized cock fighting derbies in the United States. However, it is D. ROBW SON that
has the personal relationship with the STUM BO family that allows him to hold and
maintain 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 BO
had 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 to
gain admission to the B1G BLUE pit and obtain a covert ûçparking Pass''N embership photo
ID only because D. ROBIN SON had notified the security officer at the entrance gate to let
them in. D. ROBINSON 'S name alone was enough to get them access to a l million dollar
illegal 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 family
that gives D. ROBm SON 'S and J. ROBm SON'S information about the BlG BLUE pit a
credence that would not be normally afforded to a casual observer of fights at the this
41 . Based upon m y knowledge and experience and that of the other law-enforcement agents
with whom I have consulted and the facts that l have described, l believe that there is
probable cause that WALTER DALE STUM BO, JOSHUA STUM BO, SONYA STUM BO,
JONATHAN ROBm SON, and W ESLEY DEAN ROBINSON conspired, in violation of
Title 1 8, United States Code, Section 37l , to (1) knowingly sponsor or exhibit an animal in
an 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 of
l 8 U.S.C. j 1955(a).
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 31 of 32 Pageid#: 34
Respectfully su ' ed
Stanley Wo' onski
Special Agent, United States Department of Agriculture
Office of the Inspector General
Subscribed and sw rn to before me on this 39 day of , 2014.
Hon. es P. Jones
United States District udge
Case 1:14-mj-00122-JPJ Document 3-1 Filed 04/30/14 Page 32 of 32 Pageid#: 35
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