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Paculis Complaint

Paculis Complaint

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A091(Rcv ll′ 11)C■ minal Complaint

UNITED STATES I)ISTRICT COuRT S11
for the
Southem District of Georgia 1313」 tiL-3

United States of America Thomas George Paculis
Case

No. <f,

6

″ υ 〃υ `θ “

CRIPIINAL CODIIPLAINT
ving is true to the besl of my kno、 vledge and belie■

I,the complainant in this case,state that the folloヽ

On or about the date(s)

of

」 une

24,2013

in the county

of

Chatham

ln the

Southem
18U S C 875(d)

District

of

Georgia

, the defendant(s) violated:

′′ aS′ ο Cο グ
'ο

Offense Description See Attached AfrdavL

This criminal complaint is based on these facts:
See Attached Affidavit

D

Continued on the attached sheet.

た,″α ″ Cο ″ ′

=sig“

″ ″

Bradford T Snider
P′

"セ

ど″ α ″ θα ″ ′′ θ
'″

Swom to before me anu signed in my presence.

Date:

07/03/2013

City and state:

Savannah, Georgia

Hon G R Smth,U S Maglstrate」 udge
Prinled name and tille

AFFIDAVIT IN SUPPORT OF CRI■ IIINAL

COMPLAINT AND ARRESTヽ

″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 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

3l

and 18, United States Code.

I

make this aflidavit in support of a criminal complaint

and arrest warrant for THOMAS GEORGE PACULIS.

2.

I

am a special agent with the Federal Bureau of lnvestigation ("FBI") and have

been since August 2006.

I

am currently assigned to the Resident Agency ("R.,{") located in

savannah, Georgia, which is a sub-office
assigned here since November

of the FBI's Atlanta Field office and have

been

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 oflicials. This affrdavit is intended to show only that there is sufficient this probable cause for the requested warrant and does not set forth all of my knowledge about

matter. I have set forth only the facts and circumstances that I believe are necessary to establish
probable cause to believe that evidence, fruits and instrumentalities

of

violations regarding Title

l8 U.S.C. Section

875 (d) : "Whoever, with intent to extort from any person, firm, association, or

corporation, any money or other thing ofvalue, transmits in interstate or foreign commerce any communication containing any threat to injure the proPerty or reputation ofthe addressee or of
another or the reputation

ofa

deceased person or any threat to accuse the addressee or any other

person 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, 6'03', 190 lbs, brown hair, blue eyes, date

of birth: January xx, 1951, Social Security Account Number: XXX-XX-9686, FBI Number:
83361oAC8.

l.
FBI received

On0612412013, at approximately I 1:30
a telephone

AM, the Savarurah, Georgia office of the

call and e-mail notification from Attomey GREG HODGES who is

representing 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 THoMAS

PACULIS was attempting to extort DEEN by requesting compensation in retum for not
disclosing "true and damning" statements made by DEEN, to the media. PACULIS indicated that his 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 cooking

television programs she is a nationally recogaized figure. JACKSON is the former general

つ4

manager

ofa restaurant owned by DEEN

and her brother

EARL aka BUBBA

HIERS. JACKSON's lawsuit stems from alleged racial and sexual discrimination while
JACKSON was employed by Paula Deen Enterprises'

3.
follows:

The initial e-mail received from HoDGES has been transcribed verbatim as

"From: Tom Paculis [mailto: skipper-863@yahoo.com]
Sent: Monday, June24,2013 10:40
To : ghodges@olivermaner.com

AM

Subject: Paula Deen

Mr. G. Hodges...I am about to go public with statements refuting your clients statements
about using the "N" word in her business practices at Lady and Son's... The statements are true
and damning enough that the case for Jackson
a price

will

be won on it's merit alone...as always..there is

for such information...You can contact me here if you feel it is necessary...or I can go

public and we will see what happens then..."

4.

At the direction of the FBI, HODGES replied to the initial e-mail from PACULIS

and exchanged several subsequent e-mails before HODGES requested to speak with PACULIS

by telephone. within the e-mails PACULIS provided HoDGES several examples

of

information which PACULIS believed "would damage your client in so many ways that it would
:00 PM PACULIS sent sink your ship before it left the dock." On06l26l20l3 at approximately I

HODGES his telephone number via e-mail. on 06/26/2013 at approximately 3 :00 PM,
the telephone call HODGES completed a consensual telephone call with PACULIS. During

PACULIS told HoDGES that he wanted $250,000 in retum for not going to the media with information he stated was "true and damning" about DEEN. PACULIS stated that he did not
want a paper trail and that he wanted $250,000 "net", meaning that he wanted the taxes to have
been already

paid. HODGES ended the call by telling PACULIS that he would discuss the

matter with DEEN and contact him the following

day. Although HODGES provided PACULIS

with the perception that DEEN was aware of his request. HODGES made it clear to the FBI that DEEN had not been made aware of the extortion attempt by PACULIS.

5.

On 0612712013, HODGES completed a second consensual telephone call to

PACULIS. During the call and at the direction of the FBI, HODGES negotiated the amount of
money ro be paid to PACULIS from $250,000 to $200,000. PACULIS provided that he was

currently "house sitting" in New York, did not have a vehicle and did not know how he was
going 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 with

Attomey MATT BILLPS who is representing LISA JACKSON in her civil lawsuit against

DEEN. BILLIPS was conracted by the FBI and advised of the ongoing criminal investigation
with PACULIS
as the

main subject. BILLIPS provided that PACULIS contacted him by both

telephone and e-mail on 06124/2013, in order to provide that he had received an e-mail from

HODGES asking the amount of money he wanted for his information. BILLIPS advised that his
staff conducted their own investigation into the credence of PACULIS's statements. After a

4

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

8.

On O7loll2\l3, BILLPS provided the FBI with an e-mail he received from

PACULIS that has been transcribed verbatim as follows:

"From: Tom Paculis skipper-863@yahoo.com
Date: July 1,2013,6:23:54 PM EDT

To: billips@bandlawyers.com
Subject: jackson vs deen

It seems like in every life ofa lawyer he will over
win...but paying
a a

step that line because he wants to

potential witness not to testifr amounts to obstruction of justice, even if it's in

civil suit. I have

pushed the opposing firm to that level of giving me an amount ofmoney,

in

cash to never been heard

ofagain and to never utter Paula Deen's name in public or private ever

again.. .Now the buming question is...do you want in...I still have the chance to bring this together, but time is slowly running out...I have them hooked, but reeling this sucker in is gonna
be hard without

help...give me a caII...607 564 6116..

TGP"

¨    一   ,

CONCLUSION

1.

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

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

Respectfully submitted,

BRADFORD T SNIDER
Special Agent Federal Bureau of Investigation

Subscribed and swom to before me on July 3,2013:

STATESIvIAGISTRATE JUDGE

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