Affidavit

JONES: Yeah.CHS-2: Perfect. Okay.JONES: So, so look, I've got the history back to 2008. And I've actually got, I used tokeep track of, you know, the discount that was used-- you know he was saying some of'em do an off-invoice discount and then they do a cost-plus cleanup? So I have to makesure, if that's the case, that I set up the price fetch that should run to where it backs outthat that we've already given 'em.71. On November 20, 2012, CHS-2 attended a diesel sales meeting in which all directsales personnel were present, including all regional directors, regional sales managers andregional account representatives. Also present were Jimmy Haslam, Mark Hazelwood, andMitch Steenrod. During Hazelwood's presentation to the entire group, a male voice interruptedHazelwood to make reference to Freeman's previous deceptive conduct in connection withCustomer Western Express, which was the same deceptive conduct that Freeman recounted tothe regional sales directors who met at Freeman's lake house on October 25, 2012:HAZEL WOOD: ... because what David Owens really tells them is its cost plus five.That's what he tells them with no idea what cost plus five is. We're going to go into themarketplace at four with a zero fee and we are going to give you credit. You're going topay three times a week. That's going to ...Male Voice #1: -like Stick's old deal with Western ...HAZELWOOD: Yeah, [laughter] Well, we're gonna, we're gonna intro, going tointroduce him to a guy by the name of Manuel.Male Voice #2: No planes in this deal.FREEMAN: Yeah, ah, some of us, rich and famous, we have our own, own planes.HAZEL WOOD: ... [continues presentation to assembled group]72. On November 28, 2012, CHS-2 engaged in a consensually recorded conversationwith Pilot Regional Sales Manager Kevin Clark regarding Rebate Fraud and Discount Fraud:CLARK: And here's another one that's-- and I don't know what to do 'bout this-- butfuckin' this, W .M. Moorehouse is still, this is the one that Brian was screwin'. He caughtPage 66 of 120Affidavit of Special Agent Robert H. Root, FBI, in support of search warrant applications for the following:the office building located at 5500 Lonas Drive, Knoxville, Tennessee;the office building located at 5508 Lonas Drive, Knoxville, Tennessee;the commercial building located at 1339 E. Weisgarber Road, Knoxville, Tennesseethe residence located at 4302 Dakota Avenue, Nashville, Tennessee;the residence located at 2211 Blair Drive, Hebron, Kentucky; andthe residence located at 3317 Westminster Road, Bettendorf, Iowa.Case 3:13-mj-02028 Document 4 Filed 04/18/13 Page 66 of 120 PageID #: 105