paculis complaint

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A091(Rcv ll 11)C minal Complaint

UNITED STATES I)ISTRICT COuRT S11for theSouthem District of Georgia 1313tiL-3

United States of AmericaThomas George Paculis Case No.


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AFFIDAVIT IN SUPPORT OF CRI IIINALCOMPLAINT AND ARREST ARRANT

I,Bradford T Snidcr,bcing ftrst duly sworn,hcrcby dcposc and statc as fo1lows:INTRODUCTION AND AGENT BACKGROUNI)

l. I am a law enforcement officer ol the United States within the meaning of Title18, United States Code, Section 2501(7), that is, an officer of the United States who isempowered by law to conduct investigations of, and to make arrests for offenses enumerated inTitles 3l and 18, United States Code. I make this aflidavit in support of a criminal complaintand arrest warrant for THOMAS GEORGE PACULIS.

2. I am a special agent with the Federal Bureau of lnvestigation ("FBI") and havebeen since August 2006. I am currently assigned to the Resident Agency ("R.,{") located insavannah, Georgia, which is a sub-office of the FBI's Atlanta Field office and have beenassigned here since November 2009. I have participated in numerous criminal investigationsinvolving violations of Title 18. Since 2006, I have received training and experience inconducting criminal investigations including interview and interrogation techniques, arrestprocedures, search and seizure procedures and search warrant applications'

3. The information provided in this affidavit is based on my personal knowledge,observations made during the course of this investigation, and information conveyed to me byother law enforcement oflicials. This affrdavit is intended to show only that there is sufficientprobable cause for the requested warrant and does not set forth all of my knowledge about thismatter. I have set forth only the facts and circumstances that I believe are necessary to establishprobable cause to believe that evidence, fruits and instrumentalities of violations regarding Title


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l8 U.S.C. Section 875 (d) : "Whoever, with intent to extort from any person, firm, association, orcorporation, any money or other thing ofvalue, transmits in interstate or foreign commerce anycommunication containing any threat to injure the proPerty or reputation ofthe addressee or ofanother or the reputation ofa deceased person or any threat to accuse the addressee or any otherperson of a crime, shall be fined under this title or imprisoned not more than two years, or both."

PROBABLE CAUSEYour Affiant describes the subject of this investigation as follows:

THOMAS GEORGE PACULIS, ,white male, 6'03', 190 lbs, brown hair, blue eyes, dateof birth: January xx, 1951, Social Security Account Number: XXX-XX-9686, FBI Number:83361oAC8.

l. On0612412013, at approximately I 1:30 AM, the Savarurah, Georgia office of theFBI received a telephone call and e-mail notification from Attomey GREG HODGES who isrepresenting PAULA DEEN in a lawsuit against her, filed in March 2012 by LISA JACKSON.The telephone call and follow on e-mail received from HoDGES showed that THoMASPACULIS was attempting to extort DEEN by requesting compensation in retum for notdisclosing "true and damning" statements made by DEEN, to the media. PACULIS indicated thathis information would bring hardship and financial ruin to DEEN-

2. DEEN is the founder of "The Lady and Sons" restaurant located in savannah,Georgia and',Paula Deen Enterprises." Through her restaurant and nationally broadcast cookingtelevision programs she is a nationally recogaized figure. JACKSON is the former general


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manager ofa restaurant owned by DEEN and her brother EARL aka BUBBAHIERS. JACKSON's lawsuit stems from alleged racial and sexual discrimination whileJACKSON was employed by Paula Deen Enterprises'

3. The initial e-mail received from HoDGES has been transcribed verbatim asfollows:

"From: Tom Paculis [mailto: [email protected]]Sent: Monday, June24,2013 10:40 AMTo : [email protected]: Paula Deen

Mr. G. Hodges...I am about to go public with statements refuting your clients statementsabout using the "N" word in her business practices at Lady and Son's... The statements are trueand damning enough that the case for Jackson will be won on it's merit alone...as always..there isa price for such information...You can contact me here if you feel it is necessary...or I can gopublic and we will see what happens then..."

4. At the direction of the FBI, HODGES replied to the initial e-mail from PACULISand exchanged several subsequent e-mails before HODGES requested to speak with PACULISby telephone. within the e-mails PACULIS provided HoDGES several examples ofinformation which PACULIS believed "would damage your client in so many ways that it wouldsink your ship before it left the dock." On06l26l20l3 at approximately I :00 PM PACULIS sentHODGES his telephone number via e-mail. on 06/26/2013 at approximately 3 :00 PM,HODGES completed a consensual telephone call with PACULIS. During the telephone call


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PACULIS told HoDGES that he wanted $250,000 in retum for not going to the media withinformation he stated was "true and damning" about DEEN. PACULIS stated that he did notwant a paper trail and that he wanted $250,000 "net", meaning that he wanted the taxes to havebeen already paid. HODGES ended the call by telling PACULIS that he would discuss thematter with DEEN and contact him the following day. Although HODGES provided PACULISwith the perception that DEEN was aware of his request. HODGES made it clear to the FBI thatDEEN had not been made aware of the extortion attempt by PACULIS.

5. On 0612712013, HODGES completed a second consensual telephone call toPACULIS. During the call and at the direction of the FBI, HODGES negotiated the amount ofmoney ro be paid to PACULIS from $250,000 to $200,000. PACULIS provided that he wascurrently "house sitting" in New York, did not have a vehicle and did not know how he wasgoing to collect the moneY.

6. DEEN was shown photographs ofPACULIS by FBI agents on06/2812013.DEEN did not recognize the photographs and did not recognize PACULIS's name.

7. on 0612812013 the FBI was made aware that PACULIS had been in contact withAttomey MATT BILLPS who is representing LISA JACKSON in her civil lawsuit againstDEEN. BILLIPS was conracted by the FBI and advised of the ongoing criminal investigationwith PACULIS as the main subject. BILLIPS provided that PACULIS contacted him by bothtelephone and e-mail on 06124/2013, in order to provide that he had received an e-mail fromHODGES asking the amount of money he wanted for his information. BILLIPS advised that hisstaff conducted their own investigation into the credence of PACULIS's statements. After a

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review of PACULIS's e-mails and information provided by telephone, BILLIPS contactedfederal authorities.

8. On O7loll2\l3, BILLPS provided the FBI with an e-mail he received fromPACULIS that has been transcribed verbatim as follows:"From: Tom Paculis [email protected]: July 1,2013,6:23:54 PM EDTTo: [email protected]: jackson vs deen

It seems like in every life ofa lawyer he will over step that line because he wants towin...but paying a potential witness not to testifr amounts to obstruction of justice, even if it's ina civil suit. I have pushed the opposing firm to that level of giving me an amount ofmoney, incash to never been heard ofagain and to never utter Paula Deen's name in public or private everagain.. .Now the buming question is...do you want in...I still have the chance to bring thistogether, but time is slowly running out...I have them hooked, but reeling this sucker in is gonnabe hard without help...give me a caII...607 564 6116..

TGP"


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CONCLUSION1. Based on the above facts and circumstances, I believe sufficient probable cause

exists to authorize a criminal complaint and arrest warrant for THOMAS GEORGE PACULISregarding violations of Title 1 8 United States Code, Section 875 (d)'

Special AgentFederal Bureau of Investigation

Subscribed and swom to before meon July 3,2013:

Respectfully submitted,

BRADFORD T SNIDER

STATESIvIAGISTRATE JUDGE

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