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Affidavit - Pilot Flying J

Affidavit - Pilot Flying J

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Published by Tom Gara
A Federal Bureau of Investigation raid brought the headquarters of Pilot Flying J, North America's largest truck-stop chain, to a standstill this week.
A Federal Bureau of Investigation raid brought the headquarters of Pilot Flying J, North America's largest truck-stop chain, to a standstill this week.

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Categories:Types, Business/Law
Published by: Tom Gara on Apr 18, 2013
Copyright:Attribution Non-commercial

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07/10/2013

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AFFIDAVIT
IN SUPPORT
OF
SEARCH
wARRANT
PPLICI;.I!~
E D
APR
1 8
2013
IN
THE MATTER OF THE
SEARCHES
OF:
the
office building located
at
5500 Lonas Drive, Knoxville, Tennessee;
the
office building located
at
5508
Lonas
Drive, Knoxville, Tennessee;
the
commercial building located
at
1339 E.
Weisgarber
Road, Knoxville, Tennessee;
the
residence located
at
4302
Dakota
Avenue, Nashville, Tennessee;
the
residence located
at
2211
Blair
Drive,
Hebron,
Kentucky;
and
the residence located
at
3317 Westminster Road, Bettendorf, Iowa.UNDER SEAL
Clerk,
U. S.
District CourtEastern District
of
TennesseeAt Knoxville
I,
Robert
H.
Root, being first duly sworn, hereby depose and state as follows:
1.
I am a Special Agent with the Federal Bureau
of
Investigation (FBI), UnitedStates Department
of
Justice, and have been since November 12, 1995. My primary duties are toconduct investigations
of
violations
of
federal criminal laws. From approximately 2008 through2011, I served as a Supervisory Special Agent for Complex Financial Crimes, Cyber Crime, andPublic Corruption. During that time I served as the Knoxville Field Office's CART (ComputerAnalysis Response Team) supervisor. I also have served in supervisory positions inCounterterrorism and Intelligence initiatives. Prior to serving in a supervisory capacity, I wasassigned to investigate Cyber Crimes against children. I have also received training from theNational Infrastructure Protection Center on computer networks, network security and intrusions.Currently, I am assigned to the Knoxville Field Office and am specifically assigned to workComplex Financial Crime and Public Corruption investigations. As part
of
my official duties, I
Page 1
of
120
Affidavit
of
Special Agent Robert H. Root, FBI, in support of search
warrant
applications for the following:the office building located
at
5500 Lonas Drive, Knoxville, Tennessee;the office building located
at
5508 Lonas Drive, Knoxville, Tennessee;the commercial building located
at
1339
E.
Weisgarber Road, Knoxville, Tennesseethe residence located
at
4302 Dakota Avenue, Nashville, Tennessee;the residence located
at
2211
Blair Drive, Hebron, Kentucky; andthe residence located
at
3317 Westminster Road, Bettendorf, Iowa.
Case 3:13-mj-02028 Document 4 Filed 04/18/13 Page 1 of 120 PageID #: 40
 
have participated in investigations wherein most traditional law enforcement techniques,including the drafting and execution
of
search warrants, have been utilized. I have also beeninvolved in investigations that required the drafting and execution
of
search warrants forcomputers. I have been assigned to an investigation
of
employees
of
Pilot Corporation, PilotTravel Centers, LLC, and PilotFlying
J
(hereinafter "Pilot," which is again defined below) fordevising and conspiring to devise a scheme to defraud by use
of
the mail and the transmission
of
wire communication in interstate commerce, in violation
of
18
U.S.C.
§§ 371
(conspiracy), 1341(mail fraud), 1343 (wire fraud), and 1349 (conspiracy).
2.
This affidavit is intended to show only that there is sufficient probable cause forthe requested warrant and does not set forth all
of
my knowledge about this matter. Thisaffidavit is based
on my
personal knowledge and observations made during the course
of
theinvestigation
of
possible violations
of
18
U.S.C.
§§
371, 1341, 1343, and 1349, arising from aconspiracy and scheme to defraud executed by various Pilot employees to deceptively withholddiesel fuel price rebates and discounts from Pilot customers (a term which is defined below),without the knowledge or approval
of
the customer, for the dual purposes
of
increasing theprofitability
of
Pilot and increasing the diesel sales commissions
of
the Pilot employeesparticipating in the fraud, information conveyed to me by other law enforcement and governmentofficials, including my review
of
interview and investigative memoranda prepared by myself andother law enforcement agents during the course
of
this investigation, information provided by aperson acting as a Confidential Human Source (referred to herein as CHS-1 ), informationprovided by former Pilot employee Cathy Giesick and a current Pilot employee who is referredto herein as CHS-2, and information obtained from consensually recorded conversations and the
Page 2
of
120
Affidavit
of
Special Agent Robert H. Root, FBI, in support
of
search
warrant
applications for the following:the office building located
at
5500 Lonas Drive, Knoxville, Tennessee;the office building located
at
5508 Lonas Drive, Knoxville, Tennessee;the commercial building located
at
1339
E.
Weisgarber Road, Knoxville, Tennesseethe residence located
at
4302 Dakota Avenue, Nashville, Tennessee;the residence located
at
2211
Blair Drive, Hebron, Kentucky; andthe residence located
at
3317 Westminster Road, Bettendorf, Iowa.
Case 3:13-mj-02028 Document 4 Filed 04/18/13 Page 2 of 120 PageID #: 41
 
transcriptions thereof. This affidavit does not recount all
of
the investigative activities that haveoccurred in conjunction with this investigation. Additionally, while this affidavit containsnumerous transcript excerpts from numerous consensually recorded conversations, this affidavitdoes not excerpt or summarize every conversation that has been consensually recorded duringthe course
of
this investigation.
I.
Purpose
of
Affidavit
3. This affidavit is made in support
of
applications under Rule
41
of
the FederalRules
of
Criminal Procedure for warrants to search the following:
a.
the office building located at 5500 Lonas Drive, Knoxville, Tennessee(hereinafter "the 5500 Lonas Drive Property") further described and depicted inAttachment A1, for the items described in Attachment A2. The 5500 Lonas DriveProperty is identified as Building
1,
5500 Lonas Road, on the Pilot Park officepark directory sign.
b.
the office building located at 5508 Lonas Drive, Knoxville, Tennessee(hereinafter "the 5508 Lonas Drive Property") further described and depicted inAttachment B
1,
for the items described in Attachment B2.
c.
the commercial building located at
13
3
9 E. W
eisgarber Road, Knoxville,Tennessee (hereinafter "the
13
3 9 E. W eisgarber Road Property") furtherdescribed and depicted in Attachment C
1,
for the items described in AttachmentC2.
Page 3
of
120
Affidavit
of
Special Agent Robert H. Root, FBI, in support of search
warrant
applications for the following:the office building located
at
5500 Lonas Drive, Knoxville, Tennessee;the office building located
at
5508 Lonas Drive, Knoxville, Tennessee;the commercial building located
at
1339
E.
Weisgarber Road, Knoxville, Tennesseethe residence located
at
4302 Dakota Avenue, Nashville, Tennessee;the residence located
at
2211
Blair Drive, Hebron, Kentucky; andthe residence located
at
3317 Westminster Road, Bettendorf, Iowa.
Case 3:13-mj-02028 Document 4 Filed 04/18/13 Page 3 of 120 PageID #: 42

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