Case 4:13-mj-00046-GRS Document 1 Filed 07/03/13 Page 1 of 7

AO 91 (Rev. Il/Il) Criminal Complaint

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UNITED STATES DISTRICT COURT

.,., LUIi JUL 3 Southern District of Georgia United States of America
V.
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for the

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SO. OI1.I Case No.

Thomas George Paculis

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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 Southern District of June 24, 2013
Georgia

in the county of , the defendant(s) violated:

Chatham

in the

Code Section
18 U.S.C. 875(d)

Offense Description
See 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: City and state:

07/03/2013 Judge's signature

Savannah, Georgia

Hon. G. R. Smith, U.S. Magistrate Judge

Printed name and title

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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 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 in Savannah, 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 establish probable cause to believe that evidence, fruits and instrumentalities of violations regarding Title

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18 U.S.C. Section 875 (d) : "Whoever, with intent to extort from any person, firm, association, or corporation, any money or other thing of value, transmits in interstate or foreign commerce any communication containing any threat to injure the property or reputation of the addressee or of another or the reputation of a 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, 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 the FBI received a telephone call and e-mail notification from Attorney 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 return 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 recognized figure. JACKSON is the former general

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manager of a 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: "From: Tom Paculis [mailto: skipper_863yahoo.com] Sent: Monday, June 24, 2013 10:40 AM To: ghodgesolivermaner.com Subject: Paula Deen Mr. G. Hodges...1 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 will be won on it's merit alone. ..as always..there is a price 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 The initial e-mail received from HODGES has been transcribed verbatim as

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 sink your ship before it left the dock." On 06/26/2013 at approximately 1:00 PM PACULIS sent HODGES 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 return 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 06/27/2013, 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 to 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 of PACULIS by FBI agents on 06/28/2013.

DEEN did not recognize the photographs and did not recognize PACULIS's name.

7.

On 06/28/2013 the FBI was made aware that PACULIS had been in contact with

Attorney MATT BILLIPS who is representing LISA JACKSON in her civil lawsuit against DEEN. BILLIPS was contacted 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 06/24/2013, 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

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review of PACULIS's c-mails and information provided by telephone, BILLIPS contacted federal authorities. 8. On 07/01/2013, BILLIPS 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 of a lawyer he will over step that line because he wants to win.. .but paying a potential witness not to testify amounts to obstruction of justice, even if it's in a civil suit. I have pushed the opposing firm to that level of giving me an amount of money, in cash to never been heard of again and to never utter Paula Deen's name in public or private ever again. . .Now the burning question is. . .do you want in. . .1 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 call.. .607 564 6116.. TGP"

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CONCLUSION 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 18 United States Code, Section 875 (d). Respectfully submitted,

BRADFOR T SNIDER Special Agent Federal Bureau of Investigation

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

HONOABLE G.R. SMITH UNITED STATES MAGISTRATE JUDGE