?Jx What property was taken: Total value of preperty taken: What. if any, property have you recovered: What is the business audior personal relationship between you and the party or ?rm complained of: Have you discussed this matter with the person or ?mi: Their reply: Did you sign a contract: if so, enclose a copy. What other agencies have you reported this matter to: 0R IV. ACT DESCRIPTION: (attach additional pages as needed) Describe the exact nature of your complaint below and on additional sheets. if necessary. Please be complete. Include the name of the individual that you deal: with and dates. If possible. recite facts in the order in which they occurred. You must provide copies ol?all relevant documents (see attached list). Keep all originals in a safe place in theevent they are needed {or court purposes. See attached. 11? I certify that the information that I have furnished the District Attorney in this complaint is true and correct to the best of my knowledge and belief, and is furnished for the sole purpose of instituting a criminal prosecution where the investigation indicates criminal activity and not for the purpose of recovering personal property or any other thing of value. I authorize the District Attorney to use the information given in any manner that he deems necessary and proper. I further certify that I understand that the District Attorney's Of?ce cannot give me legal advice or act as my attorney. I also understand that the completion of this form will not constitute the ?ling of criminal charges. I have not withheld any information pertinent to this complaint. Natin P3111 PRINTED OF COMPLAINTANT SUBSCRIBED AND SWORN TO before me this the day of A.D., 20 . Notary Public in and for the State of Texas (Seal) My Commission Expires: L, 4) U: 6} 8) 9) Information needed from you to begin an investigation may include the following, please send as manv of these documents as vou have available: In the fact description, be very detailed about what speci?cally you are alleging (attach additional sheets as necessary.) if checks, drafts or other bank items were used in the commission of the alleged offense include: a) b) C) d) 6) Copies of bank statements Copies ol'the front and back of checks Copies of wire orders Checkbook registers, check stubs, accounting ledgers, and/or complete backup c0pies of QuickBooks or Peachtree accounting software (include version number). If you use another type of software, check with the assigned investigator prior to sending a backup ?le. identi?cation of all of the victim?s bank accounts. if the victim is a business or association: a) b) C) Copies of documents used for the legal formation of the business (partnership agreements, articles of incorporation. etc.) Description of business. including type of Operation. names of owners or partners. names ofo'irectors and contact information (include on a separate sheet The af?ant?s position within the business Ifthe party about which you are complaining is/was an employee: a) Complete personnel file, including application, resume, Forms W2 and W4, direct deposit information, copies of paychecks. list of all direct deposits, copies of reimbursements, time sheets, and relevant correspondence. Promissory notes, security agreements, or loan agreements All civil pleadings and orders related to the actions about which you are complaining. Copies of any receipts or invoices involved Copies of all contracts or written agreements between involved parties Copies of any pertinent written or email correspondence between parties l0) A forensic audit li' 1, INFORMATION Anon Tm: PA RTV 0R FIRM COMPLAIVED 0F: Kalli Sabhan ancial Examiner Ihe Texas Slam Scouriues Board Almm. Tums Thomas Preslon Joy FBI Agem Ausnn. Texas Ems! Texas Department ofPubllc Safely ustm Texas Alan Buie Asslsianl Ummd Smles Auomcy Office oflhe S. Anomey forihc Weswm Dchxas. Ausun leiion. Ausnn. Texas Nueraj Gupta Unncd smes Aunmey Office of|hc Anomey for the Weslel'n of l'exnsv Ausun Ausun, Texas Mark I'mrick Lane 3' Maglsumc Judge, AUSKIH vamnn Ausxin Texas Veronica Sobrevilla~Dcnt Counmom Depmy Maglsu'atc Judge Mark Lane Ausun, Texas 11. PARTY AND WITNESS: Nalin "Nile" Paul exas flimsy INFORMATIO) ABOUT ALLEGED OFFENSE: Dale cfAllcged Offense August Sepremher 2019 Where did The offense occur Auslln. Travis Coumy, Texas lv. FACT DESCRIPTION: {dune/i arh/rrmualrrages as flu/drill Describe rhe cxacl unmre belaw ml additional rrnecessary please be lrrellnle llu: name oflhe rhar deall with and dares recue inch in lhe order which lhey eccuned You must panldc Copies ufall releyaul documents (see anathed llsl) Kong all uriginnls in sale mace the mm "12' are needed lor raurl This cumplarnt is search \vdrranh' that wele executed in Angusl or 2019 in Allsun, Trayrs County) Texas, and mllducl of lhe officers and agems and cxecullng lhe search warranls. These Search - \vcle of properties hy Nauu "Nam" Paul nnd/m my company World Class Crlpilal Group ur rhe scarch ruehnle Raul At Thomas Presluu lay. and Jasuu Ernsr These 3 agenls were parl Mu group el'appruxuuarely 7s agcms llral were presenl al the searches ar 3 separale rm Augusl 14, ml>> The Auszls overseeing lhe mauer ere Alan Bule and Neale] of the Depuuruenr of Jnsuee lor the s. Allomev oflhc Wesreru ofTexas The search warrants were supposedly nurhorrzed and Slgned by us Judge Mark Palrick Laue Judge Lanc's Courlroom Clerk is Veronica Senrch \varrams were no| presenred lo the individuals pl esenr at any ol'rhe 3 locauuns him were searched on Au usl 14,2019 These locatlons include (1) World Class Office,-- Ausuu, Texas- (2) World class Heldrnis Server Room.-- (3) Paul's residence, Austru, Texas- was personally present at lceaucu (3) my residence. --Allsun, Texas - The agems raided my resrdeuce at approxrrualely 9 00am en Angus! 14,2019. Despue uver teu requests to see rhe search warranr, Ageul Ram Suhhan repealedly denied my access \0 seeing rhe search wnrram Addmeually, Agem Rani Sahhnn and the olher agent: cul lhe wl>>fi hues lo my home and deslmyed my security camera system afler my home The security camera system was desuoycd at approxrmarely 9 172m Desprre my requests, I was detained in my home and was nm alluwed use the resrroonr for approxlmalcly 2 hours ancr the ng=nls armed Addmunally, Agent Sabban relused to let me call an auomey umll apprexuualely ll 00am. two hours ahcr lhey arrived Agenl Sahhan confiscated my phone from my pecker when lhey enrered my residence. When i was finally allowcd lo call my auumey, had to make the call Agem Sabban's cell phone My aucmey rue xha! Ihey were allowed to detain me and that it was against my rights for them to have detained me and not allowed me to call counsel for the two hours they had been inside my residence. I asked my counsel to tell Agent Sabban that I was free to leave, and they were not to detain me any longer. Agent Sabban acknowledged this on the call with my counsel. After he hung up the phone call, I attempted to stand up since I was told I was free to leave. Agent Sabban ordered me to sit back down and I wasn?t free to leave ?until he said so.? They proceeded to keep me detained for another 1.5 hours until 12:30pm. Individuals requesting copies of the search warrant at the of?ce and server room were similarly denied access to the search warrants when requested before, during, and after the searches took place. Copies of the purported search warrants were received by my counsel via email from AUSA Alan Buie. The ?rst relating to my residence was received by my counsel in an email from Alan Buie at 5:59pm on August 14, 2019. The search warrants relating to the office and the server room were sent on August 15, 2019 and August 16, 2019. AUSA Alan Buie assured my counsel that there were only 3 search warrants. We later learned an additional search and seizure took place at an off-site, third-party ?le storage facility that held documents belonging to my company. On a September 5, 2019 phone call, Chuck Meadows and Gerry Morris, as co- counsels for myself and World Class, asked AUSAs Alan Buie and Neeraj Gupta to con?rm that there were only 3 search warrants issued for the 3 respective locations. Mr. Buie and Mr. Gupta maintained their story that these were the only search warrants. When Mr. Meadows and Mr. Morris told Mr. Buie they were aware of the search and seizure of World Class? records from Contego, a third-party ?le storage vendor?s of?ces, Mr. Buie simply responded, ?Okay. You got me." Mr. Buie then claimed that he did have a search warrant for the ?le?storage location but felt he didn?t need to disclose it to Mr. Paul or his counsel. On September 6, 2019, Mr. Buie emailed a search warrant for this location that he claims was authorized by Judge Mark Lane for the search of this location. In February 2020, my counsel, Michael Wynne, and I learned of at least 3 additional search warrants that Mr. Buie and Mr. Gupta obtained, that were signed and authorized by Judge Mark Lane, that were never previously disclosed. Mr. Buie stated that these search warrants were obtained ?just in case we needed them.? In October 2019, the court signed an order allowing access to judicial records to provide my counsel and I copies of the actual records that were ?led in the case. The documents we were given do not match the documents we subsequently learned about in the case. These other ?new? search warrants were never provided to us. This complaint is being ?led because of a strong belief that the named parties have tampered with the government records relating to these search warrants, they obtained these search warrants based on false information and inaccurate af?davits, and intentionally mistreated, detained, and violated my constitutional rights of Mr. Paul, and illegally searched and seized property belonging to myself, my family, and World Class. Many items seized from my home were not within the scope of what the search warrant they later provided would have allowed. They took pictures of my children, childbirth videos of my two daughters, health records, attomey-client privileged ?les, and more. The metadata of the documents provided as government records authorizing the search warrants show that they were edited after the searches started on August 14, 2019. The bases for asserting claims include, but are not limited to, Tampering with Government Records under Texas Penal Code 37.10, and (ii) Of?cial Oppression under Texas Penal Code 39.03.