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Complaint filed in Southern District of Georgia

Complaint filed in Southern District of Georgia

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Complaint filed in Southern District of Georgia
Complaint filed in Southern District of Georgia

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Published by: Time Warner Cable News on Jul 06, 2013
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09/17/2013

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AO 91 (Rev. Il/Il) Criminal Complaint
 
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UNITED STATES DISTRICT COURT
for the
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Southern District of Georgia
UIi JUL
United States of America
V.
Thomas George Paculis
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Case No.
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Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of
une 24, 2013
n the county of
hatham
n the
Southern
istrict of
eorgia
the defendant(s) violated:
Code Section
ffense Description
18 U.S.C.
875(d)
ee Attached Affidavit
This criminal complaint is based on these facts:
See Attached Affidavit
0
Continued on the attached sheet.
Complainant's signature
Bradford T. Snider
Printed name and title
Sworn to before me and signed in my presence.
Date:
7/03/2013
Judge's signature
City and state:
avannah, Georgia
on. G. R. Smith, U.S. Magistrate Judge
Printed name and title
Case 4:13-mj-00046-GRS Document 1 Filed 07/03/13 Page 1 of 7
 
AFFIDAVIT IN SUPPORT OF CRIMINALCOMPLAINT AND ARREST WARRANT
I, Bradford T Snider, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND
1.
I am a law enforcement officer of the United States within the meaning of Title
18, United States Code, Section 2501(7), that is, an officer of the United States who is
empowered by law to conduct investigations of, and to make arrests for offenses enumerated in
Titles 31 and 18, United States Code. I make this affidavit in support of a criminal complaint
and arrest warrant for THOMAS GEORGE PACULIS.2.
I am a special agent with the Federal Bureau of Investigation ("FBI") and have
been since August 2006. I am currently assigned to the Resident Agency ("RA") located inSavannah, Georgia, which is a sub-office of the FBI's Atlanta Field Office and have been
assigned here since November 2009. I have participated in numerous criminal investigations
involving violations of Title 18. Since 2006, I have received training and experience in
conducting criminal investigations including interview and interrogation techniques, arrest
procedures, 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 by
other law enforcement officials. This affidavit is intended to show only that there is sufficient
probable cause for the requested warrant and does not set forth all of my knowledge about this
matter. 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
Case 4:13-mj-00046-GRS Document 1 Filed 07/03/13 Page 2 of 7
 
18 U.S.C. Section
875
(d) : "Whoever, with intent to extort from any person, firm, association, orcorporation, any money or other thing of value, transmits in interstate or foreign commerce anycommunication containing any threat to injure the property or reputation of the addressee or ofanother or the reputation of a 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 CAUSE
Your Affiant describes the subject of this investigation as follows:
THOMAS GEORGE PACULIS, ,white male, 603", 190 lbs, brown hair, blue eyes, date
of birth: January xx, 1951, Social Security Account Number: XXX-XX-9686, FBI Number:
8336 1OAC8.
On 06/24/2013, at approximately 11:30 AM, the Savannah, Georgia office of theFBI received a telephone call and e-mail notification from Attorney 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 return 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.
EEN is the founder of "The Lady and Sons" restaurant located in Savannah,Georgia and "Paula Deen Enterprises." Through her restaurant and nationally broadcast cooking
television programs she is a nationally recognized figure. JACKSON is the former general
2
Case 4:13-mj-00046-GRS Document 1 Filed 07/03/13 Page 3 of 7

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