Case 5:11-cr-00002-JPJ Document 188

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRlCT OF VIRGINIA HARRlSONBURG DIVISION UNITED STATES OF AMERICA
v.

Case No.5: II-cr-00002

PAUL H. THOMSON

STATEMENT OF FACTS
The offenses described below occurred within the Western District of Virginia. This Statement of Facts briefly summarizes the facts and circumstances surrounding the defendant's criminal conduct. It does not necessarily contain all of the information obtained during this investigation and applicable to an accurate Presentence Report and Sentencing Guidelines calculation. In May of20 10, Paul Thomson ("Thomson") possessed cocaine at the Red Lion Tavern, in Winchester, Virginia. On August 25,2010, Thomson and Nannette Boden ("Boden"), Thomson's trial assistant, visited Oscar Salvatierra-Jove I ("Jove I") in the Northwest Regional Adult Detention Center in Winchester, Virginia. Jovel was Thomson's cocaine supplier, and had been arrested by the DEA on August 24, 2010. During the meeting with Jovel, Thomson asked Jovel if Boden's telephone number was in Jovel's cell phone. Jovel told Thomson yes, Boden's telephone number was in Jovel's cell phone, and that Jovel's cell phone had been seized by the police when they arrested him. Thomson then directed Boden to change her cell phone number. On August 28, 2010, Boden agreed to change her cell phone number after Thomson again instructed Boden to change her cell phone number. Thomson also directed Boden to get rid of her cell phone entirely, but she did not. Thomson was in the room when Boden called the phone company to change the phone number. Boden made the call using a telephone at the Red Lion Tavern in Winchester, Virginia; she used the speakerphone function so Thomson could listen to her conversation with the phone company. During the telephone conversation with the phone company. Boden instructed the phone company to change her phone number. The phone company agreed to change Boden's phone number, and asked her why she was changing the number. Boden looked at Thomson, and he quietly instructed Boden to tell the phone company she was changing her number because she was receiving harassing phone calls. Accordingly,

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Boden told the phone company she had been receiving harassing phone calls. The phone company then changed her number. In October of 20 I0, Thomson caused to be deleted over 200 text messages from a cellular telephone belonging to Lemuel Roberts, who was one of Thomson's cocaine suppliers and a legal client of Thomson 's at the time. Thomson deleted the text messages because the messages were exchanged between Roberts and Thomson, and pertained to Thomson's cocaine possession and use. In or about October 01'201 0, Jovel was transferred to the Rockingham County Jail in Harrisonburg, Virginia. Thomson visited Jovel at the Rockingham County Jail on two separate occasions. Thomson's first visit to meet with Jovel at the Rockingham County Jail occurred on November 24, 2010. During this meeting, Thomson twice instructed Oscar to lie to federal government agents about why Boden's phone number was in Jovel's cell phone. Before Thomson's second trip to meet with Jovel at the Rockingham County Jail, Thomson instructed Boden to help him prepare a document, a script, that Thomson would use during his meeting with Jovel. During Boden's meeting with Thomson, he dictated to Boden a list of questions and statements, which Boden typed using a computer. After Boden had typed the questions and statements, Thomson directed Boden to create a Spanish version of the same document, which she did, using an online language translation program. Thomson told Boden that he intended to use the typed questions and statements during his meeting with Jovel in case the meeting was being recorded. One of the questions on the list Boden typed for Thomson asked Jovel whether Sebastian or his wife Allisia's phone numbers were in Jovel's cell phone. Boden asked Thomson Abalo why he had included this question; Thomson later explained to Boden that Sebastian and Allisia could become grand jury witnesses against Thomson, so Thomson needed to know whether their names and phone numbers were in Jovel's cell phone. One ofthe statements Thomson dictated for Boden to type explained to Jovel that Boden's cell phone number was in Jovel's cell phone because Boden had been trying to help Jovel's daughter immigrate to the United States. Boden asked Thomson why he was including this statement in the document, and he explained to Boden that Jovel needed a ditferent story to tell the police about why Boden's cell phone number was in his cell phone. Boden told Thomson that the statement about Jovel's daughter did not accurately describe the real basis of her relationship with Jovel, which was based upon getting cocaine for Thomson from Jovel. In the evening of January 9, 2011, Lanelle Hockman and Boden drove with Thomson to the Rockingham County Jail in Harrisonburg, Virginia. Hockman and Thomson went inside the jail to meet with Jovel, while Boden remained in the veh icle. During the meeting with Jovel, Thomson again instructed Jovel to lie to federal government agents about why Boden's cell phone number was in Jovel's cell phone. Thomson also gave Jovel the script he and Boden had prepared. Hockman was present during the meeting. 2

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Thomson engaged in the above acts in an effort to conceal his criminal conduct, hinder state and federal investigations into his conduct, and hinder federal proceedings, including federal trials and grand jury investigations.

I have reviewed the above Statement of Facts with my attorney. I agree that these facts are true and accurate, and form the factual basis for my guilty plea to the charged offenses.

G/~

PAULd.SON

(
P. FLANNERY
orney for Defendant