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Case 1:17-mj-00283-CMS Document 1 Filed 04/14/17 Page 1 of 5

FILED IN CHAMBERS
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ORIGINAL United States District Court
NORTHERN DISTRICT OF GEORGIA
APR 14 2017
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By. ~~Clerk
UNITED STATES OF AMERICA
v. CRIMINAL COMPLAINT
Case Number: 1:17-MJ-283
KELLY BASS and DELDRICK D. JACKSON

I, the undersigned complainant being duly sworn, state the following is true and correct to the best of
my knowledge and belief.

COUNT 1 - On or about April 13, 2017, in Fulton County, in the Northern District of Georgia,
defendant DELDRICK D. JACKSON knowingly escaped from the custody of the United States Penitentiary
in Atlanta, Georgia, an institution and facility in which the defendant was lawfully confined at the direction
of the Attorney General by virtue of a judgment and commitment of the United States District Court upon
convictions for Conspiracy to Distribute Cocaine, in violation of 21 U.S.C. 846, and Money Laundering
Conspiracy, in violation of 18U.S.C.1956(h); all in violation of Title 18, United States Code, Section 751(a).

COUNT 2- On or about April 13, 2017, in Fulton County, in the Northern District of Georgia, defendant
KELLY BASS knowingly rescued, instigated, aided and assisted the escape of Deidrick D. Jackson, a person
committed to custody of the United States Penitentiary in Atlanta, Georgia, an institution and facility in
which Jackson was lawfully confined at the direction of the Attorney General by virtue of a judgment and
commitment of the United States District Court upon convictions for Conspiracy to Distribute Cocaine, in
violation of 21 U.S.C. 841, and Money Laundering Conspiracy, in violation of 18 U.S.C. 1956(h); all in
violation of Title 18, United States Code, Section 752(a) '

I further state that I am a(n) FBI Special Agent and that this complaint is based on the following facts:
SEE ATTACHED .AFFIDAVIT
Continued on the attached sheet and made a part hereof. Yes

Based upon this complaint, this Court finds that there is probable cause to believe that an offense has been
committed and that the defendant has committed it. Sworn to before me, and subscribed in my presence:

April 14, 2017


Date

CATHERINE M. SALINAS
UNITED STATES MAGISTRATE JUDGE
Name and Title of Judicial Officer

AUSAs Jeffrey W. Davis and Timothy H. Lee/ 404-581-6000


Case 1:17-mj-00283-CMS Document 1 Filed 04/14/17 Page 2 of 5

AFFIDAVIT IN SUPPORT OF COMPLAINT

I, James P. Hosty, IV, being first duly sworn, state as follows:

A. Agent Background
1. I, James P. Hosty IV, am a Federal Bureau of Investigation ("FBI") Special
Agent assigned to the Atlanta Field Office's Public Corruption squad. As a Special
Agent of the FBI, I am an "investigative or law enforcement officer of the United
States" within the meaning of 18 U.S.C. 2510(7). As such, I am empowered to
conduct investigations of and to make arrests for offenses enumerated in 18 U.S.C.
2516

2. I am currently employed as a Special Agent with the Federal Bureau of

Investigation, and have been so employed since 2005. Prior to being employed by
the FBI, I was employed by the Wichita Police Department in Wichita, Kansas for
approximately eight years. During that time, I was a Police Officer for
approximately four years and a Detective for approximately four years. While
employed as a Detective I worked various assignments including Undercover
Narcotics and in the Gang Unit. Upon being hired as a Special Agent with the FBI, I
attended the FBI Academy in Quantico, Virginia where I received extensive training
on investigating various violations of federal law. Currently, I am assigned to the
Atlanta Division, Public Corruption Squad, and have been so assigned since
November 2009.
B. Sources of Information

3. The facts set forth in this affidavit are based on my personal observations and
knowledge, and may also be based on: (a) my training and experience, (b)
information obtained from other individuals participating in the investigation, (c)
Case 1:17-mj-00283-CMS Document 1 Filed 04/14/17 Page 3 of 5

reports and/ or business records, (d) recorded conversations and videos, and (e)
communications with other individuals who have personal knowledge of the events
and circumstances described herein. Since this affidavit is being submitted for the
limited purpose of establishing probable cause, I have not included in this affidavit
every detail of the investigation. Rather, I have set forth facts that I believe are
sufficient to establish probable cause for the issuance of the requested search
warrant. Unless specifically indicated otherwise, any conversations and statements
described in this affidavit are related in substance and in part only.
C. Probable Cause Basis

4. The United States Penitentiary in Atlanta, Georgia ("USP Atlanta") is a


medium-security federal prison for male inmates operated by the Federal Bureau of
Prisons ("BOP"). USP Atlanta also has a detention center for pre-trial inmates and a

satellite prison camp for minimum-security male inmates.


5. The FBI and the Atlanta Police Department (" APD") are investigating
instances of inmates temporarily escaping from the prison camp at USP Atlanta and
frequently returning to the camp with contraband. For example, on February 3,
2017, inmate Justin B. Stinson escaped from USP Atlanta and was caught by the FBI.
At the time of his arrest, Stinson possessed a cell phone, scissors, nail clippers, two
bottles of tequila, two cartons of cigarettes, four boxes of cigars, and various food
items. Stinson admitted to the FBI that he planned to smuggle the above items into
USP Atlanta. On February 14, 2017, a Grand Jury returned an Indictment against
Stinson for escape and contraband smuggling charges. See United States v. Stinson,
1 :17-CR-048.

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6. Deidrick D. Jackson is an inmate at USP Atlanta with a scheduled release date


of January 14, 2022. In May 2010, Jackson was convicted of conspiring to distribute
cocaine (in violation 21 U.S.C. 846) and conspiring to launder money (in violation
18 U.S.C. 1956h). Jackson is currently assigned to USP Atlanta at the direction of
the Attorney General by virtue of a judgment and commitment of a United States
District Court from the Middle District of Georgia based on a conviction for the
above-listed crimes.
7. BOP visitation records show that Jackson has listed Kelly Bass as his fiancee.
According to Georgia driver registration records, Bass is the owner of a silver Acura
SUV bearing Georgia license plate number PRZ1697.
8. Based on the investigation, I believe that Bass and/ or Jackson provide
inmates who have escaped with transportation to restaurants, hotels, or residences
for a fee (often paid via the Square Cash app).
9. For example, video surveillance footage shows that: (a) on January 28, 2017,
at approximately 10:32 p.m., several individuals ran from the prison camp area
towards USP Atlanta's perimeter fence; (b) at approximately 10:42 p.m., a silver SUV
arrived in the area and three individuals entered the SUV and departed; and (c) at
approximately 2:10 a.m. on January 29, 2017, three individuals got out of the silver
SUV and ran towards the USP Atlanta perimeter fence. Additionally, video
surveillance footage from a hotel near USP Atlanta showed that at approximately

10:52 p.m., on January 28, 2017, a silver SUV bearing license plate number PRZ1697
(a vehicle registered to Bass) arrived in the hotel's parking lot and left at
approximately 2:04 a.m. on January 29, 2017.

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10. Moreover, Square Cash records show that from November 2016 to March

2017, an account associated with Bass's debit card has received approximately
$4,000 in money transfers from accounts associated with USP Atlanta inmates.
11. On April 13, 2017, law enforcement officers stopped a silver SUV driven by
Bass and occupied by escaped inmate Jackson. Upon searching Bass's SUV, officers
recovered two cell phones, a large box filled with packs of cigarettes, and several

bottles of alcohol. USP Atlanta Special Investigative Agent Gerson Rivera confirmed
that Jackson did not had permission to leave USP Atlanta on April 13, 2017.
12. After being advised of and waiving his Constitutional rights, Jackson
admitted to the FBI in substance that: (a) he was an inmate of USP Atlanta, (b) he
escaped by walking out of the front gate of USP Atlanta, (c) that he escaped to have
sex, (d) that he has escaped from USP Atlanta on multiple other occasions.
D. Conclusion

13. Based on the information contained in this Affidavit, probable cause exists to
believe that Jackson violated Title 18, United States Code, Section 751(a) (Escape
from Custody); and Bass violated Title 18, United States Code, Section 752 (Assisting

Escape of Person Committed to Custody).