Beasley v. Birdsong Alleges RICO Scheme to Oust Heritage Foundation CEO
Confidential Documents Compiled Into 128-Page Dossier, Disseminated to Officials and Media
Bari Beasley, CEO of the Heritage Foundation of Williamson County, has sued six former employees and associates in the U.S. District Court for the Middle District of Tennessee, alleging they orchestrated a racketeering scheme to force her out by compiling and disseminating a 128-page dossier containing false and confidential information about her professional and personal life. The complaint, filed July 13, 2026, names Shelly Birdsong, Pamela Chandler, Mary Lankford, Miriam Wiggins, Cynthia Stielow, and Walter Green as defendants, along with 20 unnamed John and Jane Does.
The complaint alleges that the defendants, operating as part of the Citizens for a Cleaner Watershed Coalition (CCWC), obtained confidential Foundation documents without authorization and compiled them into a document titled "Save the Heritage Foundation." The dossier was then disseminated via email, mail, and digital platforms to community members, government officials, donors, and media outlets, including the Williamson Herald and the Williamson Wrong Facebook and Substack pages. The complaint asserts that this campaign led to a loss of over 500 donors, a $400,000 decrease in donations, a Tennessee Attorney General investigation, and a $50,000 annual reduction in Beasley’s compensation (Compl. ¶207). The Foundation’s internal investigation, conducted post-July 2025, cost over $100,000 and further strained the organization’s resources (Foundation’s Internal Investigation). The complaint alleges that the internal investigation confirmed the financial statements accurately presented the Foundation’s financial position and that the Foundation received a clean audit following the publication of the dossier (Compl. ¶112).
Defendants Allegedly Accessed Confidential Records Without Authorization
The complaint details a pattern of unauthorized access to Beasley’s and the Foundation’s confidential records, beginning in 2024. On August 23, 2024, Stielow, then the Foundation’s Chief Advancement Officer, transmitted confidential cash flow projections via wire communication, which were later included in the dossier (Compl. ¶163). The complaint alleges that Stielow transmitted Foundation emails to herself and others using an internet-connected scanner, and that these documents were circulated via interstate mails and wires among defendants and coalition members (Compl. ¶33). The Foundation’s cash position at the beginning of 2024 was $2,425,569, but by the beginning of 2025, it had declined to $1,218,334, a reduction the complaint attributes in part to the defendants’ actions (Compl. ¶¶ amounts section). The complaint further alleges that "Defendants Wiggins and Stielow collected and shared unauthorized documents, committing mail and wire fraud" as part of the scheme (Compl. ¶201).
In May 2025, the Foundation received a new pledge of $1,000,000 for the Franklin Grove project, contributing to a $1.1 million rise in Franklin Grove pledge receivables (Compl. ¶¶ amounts section). However, the complaint alleges that the defendants’ actions undermined the Foundation’s financial stability, including the misrepresentation of its financial health in the dossier. The complaint states that the defendants’ Financial ChatGPT Analysis "intentionally omitted facts that would have contextualized the financial figures," leading to inaccurate conclusions about the Foundation’s finances (Compl. ¶47). In 2024, the Foundation and the Franklin Theatre received a one-time grant of $750,000, split evenly between the two accounts (Compl. ¶¶ amounts section). The complaint alleges that the defendants’ use of the Financial ChatGPT Analysis was part of a broader effort to "cause reasonable readers to believe that Plaintiff had actually engaged in dishonest... conduct" (Compl. ¶76).
The complaint further alleges that on March 31, 2025, an anonymous email titled "Heritage Foundation Workplace Concerns with CEO" was sent to Foundation Board Chair William Scales and Nashville HR representative Laura Camp from the address CarrieMcGavock@protonmail.com. The email threatened media exposure if no action was taken against Beasley, stating, "If no action is taken, we will be forced to go to the media with our concerns" (Compl. ¶25). The Foundation’s Board investigated the allegations in April 2025 and subsequently gave Beasley a vote of confidence, but the complaint alleges that the defendants continued their campaign to undermine her (Compl. ¶ timeline section). The complaint also alleges that months before the dossier’s publication, Defendant Birdsong transmitted an email soliciting assistance to "expose" Plaintiff and the alleged "financial scandal" at the Foundation (Compl. ¶167).
The complaint describes how Defendant Stielow, whose last day at the Foundation coincided with the dossier’s publication on July 18, 2025, transmitted or caused to be transmitted Foundation emails to herself, other defendants, and CCWC members using an internet-connected scanner (Compl. ¶33, ¶122). The complaint further alleges that Plaintiff-related and Foundation-related documents were circulated via interstate mails and wires among defendants and CCWC members, including the transmission of confidential documents to create a false ChatGPT analysis (Compl. ¶34, ¶35). The complaint states that "Defendants transmitted confidential documents over the Internet to create a false Financial ChatGPT Analysis, which was then transmitted back to Document preparers" (Compl. ¶35).
Dossier Contained False Allegations of Financial Misconduct, Conflicts of Interest
The "Save the Heritage Foundation" document, which the complaint describes as a 128- or 135-page dossier, contained numerous false and misleading allegations about Beasley’s conduct as CEO, according to the complaint. The complaint alleges that the dossier falsely implied that Beasley misappropriated Foundation funds for personal benefit, including for the maintenance of a historic property owned by a board member. The complaint clarifies that no Foundation funds were involved in this transaction, and that the board member personally paid $10,000 for work on their property (Compl. ¶43). The dossier also falsely alleged that Foundation funds were used to pay approximately $42,000 for Plaintiff’s personal expenses, a claim the complaint disputes (Compl. ¶61). The complaint states that the $42,000 figure was a mischaracterization of a board-approved $15,000 preservation video project, which the dossier falsely described as a "promotional video about [Beasley]" (Compl. ¶42(D)).
The complaint further alleges that the defendants "selectively quoted documents and emails while omitting context altering their meaning," and that they "assembled a one-sided compilation of materials to portray Plaintiff as dishonest and unethical" (Compl. ¶84, ¶86). The dossier mischaracterized the board-approved $15,000 preservation video project as a "$42,000...promotional video about [Beasley]," a claim the complaint describes as "patently false" (Compl. ¶42(D), ¶4). The complaint also alleges that the dossier falsely characterized private-school tuition assistance for Beasley’s minor daughter as an undisclosed conflict of interest, and that it included private information about her minor child without consent (Compl. ¶58, ¶259). The complaint states that the defendants "either knew the challenged factual assertions were false or acted with reckless disregard" for their truth or falsity (Compl. ¶89).
The complaint quotes the defendants’ Financial ChatGPT Analysis, stating, "Defendants’ use of the Financial ChatGPT Analysis intentionally omitted facts that would have contextualized the financial figures," which the complaint alleges was done to misrepresent the Foundation’s financial position (Compl. ¶47). The analysis intentionally omitted material facts, such as the Foundation’s clean independent audits and the lack of material weaknesses in internal controls, to create a misleading narrative (Compl. ¶80). The complaint also alleges that the dossier falsely stated that Beasley received annual bonuses, a claim contradicted by the Foundation’s financial records (Compl. ¶49). Additionally, the dossier misrepresented internal cash-flow projections as evidence of poor financial performance, despite the Foundation’s overall growth under Beasley’s leadership (Compl. ¶48). Auditors confirmed that Franklin Theatre funds, totaling $375,000 from the one-time grant, were fully owned by the Foundation and returned after operational use (Compl. ¶50). The complaint further alleges that the dossier falsely implied Plaintiff altered financial records before presenting them to the Board, stating, "The Document falsely implied Plaintiff misappropriated Foundation funds for personal benefit" (Compl. ¶53).
The complaint alleges that the dossier falsely characterized construction services provided by Plaintiff’s husband as an improper conflicted transaction. The complaint clarifies that the services were negotiated by Board Chair William Scales and provided below market rates (Compl. ¶54, ¶59). The complaint also asserts that the defendants deliberately omitted material facts necessary to prevent the dossier’s statements from being misleading, including the Foundation’s clean audits and the lack of material weaknesses in internal controls (Compl. ¶68, ¶80). The complaint states that the defendants "possessed or avoided information demonstrating that the accusations were false or misleading" (Compl. ¶78).
Defendants Admit to Creating and Disseminating the Dossier
The complaint cites several admissions by the defendants regarding their roles in creating and disseminating the dossier. On July 23, 2025, Chandler emailed Mayor Ken Moore, admitting that she, Birdsong, and Lankford "created the Document with help of documents and meetings from staff current and past," and that "copies have been distributed to various media outlets and various appropriate state agencies" (Compl. ¶97, ¶118). The complaint alleges that Chandler’s email is a direct admission of the conspiracy and defamation claims. The email further stated, "The packet came to the Williamson Herald after receiving several anonymous letters to the editor," indicating the defendants’ involvement in disseminating the dossier to the media (Compl. ¶109). The complaint also quotes Chandler’s email, which stated, "Copies have been distributed to various media outlets and various appropriate state agencies" (Compl. ¶118).
Birdsong, the owner of Your Williamson magazine, allegedly transmitted the dossier via email using the address savetheheritagefoundation@gmail.com, and solicited help from a former Foundation CFO, David Runyan, to gather information about Beasley and the Foundation (Compl. ¶96, ¶168). On June 25, 2025, Birdsong transmitted an email to Runyan soliciting assistance to "expose" Beasley and the alleged "financial scandal" at the Foundation (Compl. ¶168). The complaint alleges that Birdsong also transmitted "anonymous" letters via email to multiple recipients on June 25, 2025, furthering the campaign against Beasley (Compl. ¶169). The complaint states that Birdsong admitted in an email to receiving and soliciting information about Plaintiff and the Foundation, including the transmission of materials that would later appear in the dossier (Compl. ¶36).
Green, a local historian and author, allegedly created a Google Drive link to disseminate the dossier to donors and officials, and transmitted materials to Alderman Patrick Baggett with instructions to "Please use discretely!" (Compl. ¶123, ¶37). The complaint alleges that Green transmitted the dossier via a Google Drive link to Ralene Debord on or about July 22 or 24, 2025, and that he advised recipients to "remain discreet, in advance of the publication of the Document" (Compl. ¶123, ¶181). The complaint further alleges that Green uploaded the dossier to Google Drive and disseminated it to donors and officials, including the transmission of the dossier to Ralene Debord via a Google Drive link (Compl. ¶105-106, ¶123).
The dossier was disseminated to a wide range of recipients, including government officials, donors, and media outlets. The Williamson Herald published excerpts from the dossier on July 31, 2025, after receiving "several anonymous letters to the editor," according to the complaint (Compl. ¶109). The complaint quotes the Williamson Herald’s statement that "The packet came to the Williamson Herald after receiving several anonymous letters to the editor..." (Compl. ¶109). The complaint alleges that the dissemination of the dossier led to a state attorney general investigation into the Foundation, which began in September 2025, as well as a costly internal investigation by the Foundation that exceeded $100,000 (Compl. ¶111, Foundation’s Internal Investigation). The Foundation’s internal investigation found that the financial statements accurately presented the Foundation’s financial position, and the Foundation received a clean audit following the publication of the dossier (Compl. ¶112).
The complaint details the extensive dissemination of the dossier, including its transmission to Rick Warwick on July 23, 2025, Greg Gamble and Ralene Debord on July 24, 2025, and Alderman Bev Berger on July 27, 2025 (Compl. ¶182, ¶183, ¶184). The dossier was also transmitted to Steve and Kay George, Marty Ligon, and Hunter Jones between July 18 and July 29, 2025 (Compl. ¶186). The complaint alleges that the CCWC, including defendants Birdsong, Lankford, and Chandler, created the 128-page (or 135-page) dossier entitled "Save the Heritage Foundation" with the intent to disseminate it via interstate mails and wires (Compl. ¶39). The complaint further alleges that the dossier was transmitted to the Tennessee Attorney General’s Office on or about July 17 or 25, 2025, and that it was disseminated to community members, officials, and donors between July 18 and July 29, 2025 (Compl. ¶177, ¶178).
Foundation’s Financial Health Allegedly Damaged by Dossier
Under Beasley’s leadership, the Foundation’s total assets grew from $12.5 million to $35 million, and its net assets increased from $9.4 million to $18.4 million, according to the complaint. The Foundation also raised $20 million in corporate and major gifts, and generated $60 million in total revenue during her tenure. The Franklin Grove Construction Work-in-Progress account saw growth of $1.35 million, reflecting the Foundation’s expanding preservation efforts (Compl. ¶¶ amounts section). Despite these achievements, the complaint alleges that the Foundation’s revenue declined by $420,000 in 2025 compared to 2024, a reduction attributed to the loss of 511 donors following the dissemination of the dossier (Compl. ¶¶ amounts section). The complaint states that the Foundation’s internal investigation, which cost over $100,000, was necessitated by the defendants’ actions and further strained the organization’s resources (Foundation’s Internal Investigation).
The complaint alleges that the Foundation’s internal investigation found that the financial statements accurately presented the Foundation’s financial position, and that the Foundation received a clean audit following the publication of the dossier (Compl. ¶112). The complaint further alleges that the Foundation faces potential total losses of approximately $1 million due to reduced donations and expenses. Beasley’s compensation was reduced by $50,000 annually as a direct result of the defendants’ actions, and she also lost her 2025 bonus (Compl. ¶130, ¶207). The complaint further alleges that the Foundation’s cash position declined from $2,425,569 at the beginning of 2024 to $1,218,334 at the beginning of 2025, a reduction that the complaint links to the defendants’ campaign (Compl. ¶¶ amounts section). The complaint states that the Foundation’s internal investigation, which cost over $100,000, was one of several financial burdens imposed by the defendants’ actions (Foundation’s Internal Investigation).
RICO Claims Allege Pattern of Racketeering Activity Through Mail and Wire Fraud
The complaint brings multiple claims under the Racketeer Influenced and Corrupt Organizations Act (RICO), including Count I: RICO Violation (18 U.S.C. § 1962(c)) against all defendants for conducting the affairs of an enterprise (CCWC) through a pattern of racketeering activity, and Count II: RICO Conspiracy (18 U.S.C. § 1962(d)) against all defendants for conspiring to violate § 1962(c) (Compl. ¶¶ Counts section). The complaint alleges that the enterprise’s purpose was "spreading misinformation about the Foundation and the Plaintiff in order to injure Plaintiff’s reputation, her business, damage her financially, and remove her from her position" (Compl. ¶153). The complaint describes CCWC as an "association-in-fact" enterprise with the goal of unseating Beasley and installing a pliable CEO (Compl. ¶152, ¶223). The complaint states that each defendant is a "person" associated with the enterprise under 18 U.S.C. § 1961(3), and that each defendant conducted the enterprise’s affairs through a pattern of racketeering activity (Compl. ¶199, ¶200).
The complaint identifies several predicate acts of mail and wire fraud, including the transmission of confidential documents via wire communication and the dissemination of the dossier via email and mail. For example, the complaint alleges that on May 20, 2025, Stielow transmitted confidential Foundation financial documents to Wiggins via wire communication (Compl. ¶166). The complaint also alleges that the defendants transmitted the dossier to the Tennessee Attorney General’s Office on or about July 17 or 25, 2025, and that the dossier was disseminated to community members, officials, and donors between July 18 and July 29, 2025 (Compl. ¶177, ¶178). The complaint further alleges that Defendant Wiggins transmitted Plaintiff’s confidential Foundation correspondence to other CCWC members months before the dossier’s publication, and that she transmitted Foundation documents via wire communication, including scanning (Compl. ¶171, ¶172). The complaint states that Wiggins also transmitted her retirement investment account statement via wire communication to CCWC members (Compl. ¶173).
The complaint alleges that the defendants devised a scheme to use interstate mails and wires to harm Beasley and the Foundation through false representations and omissions. The complaint states that the defendants "published and disseminated the Document throughout the community via their email accounts, including anonymous accounts," such as the savetheheritagefoundation@gmail.com address used by Birdsong (Compl. ¶157). The complaint details numerous transmissions of the dossier, including to Rick Warwick on July 23, 2025, Greg Gamble on July 24, 2025, and Alderman Bev Berger on July 27, 2025 (Compl. ¶182, ¶183, ¶184). The dossier was also transmitted to Steve and Kay George, Marty Ligon, and Hunter Jones between July 18 and July 29, 2025 (Compl. ¶186). The complaint alleges that the defendants’ actions were part of a coordinated effort to "expose" Beasley and the alleged "financial scandal" at the Foundation, including the transmission of "anonymous" letters to multiple recipients on June 25, 2025 (Compl. ¶169).
In addition to the RICO claims, the complaint includes Count III: Violation of the Stored Communications Act (18 U.S.C. § 2701 et seq.) against all defendants for unlawfully obtaining and disseminating Beasley’s and the Foundation’s confidential electronic communications (Compl. ¶¶ Counts section). The complaint alleges that Wiggins and Stielow accessed Beasley’s private emails and financial records without authorization, including information concerning her minor daughter (Compl. ¶259). The complaint states that Wiggins transmitted her retirement investment account statement to CCWC members via wire communication, and that Stielow transmitted Foundation emails to herself and others using an internet-connected scanner (Compl. ¶173, ¶33). The complaint further alleges that the defendants "collected documents and information from Plaintiff and the Foundation, without authorization and/or exceeding the scope of their authorization" (Compl. ¶201). The complaint states that Defendants Wiggins, Stielow, and Jane/John Does accessed Plaintiff’s and the Foundation’s email systems and servers without authorization (Compl. ¶137).
The complaint also brings Count IV: Violation of the Computer Fraud and Abuse Act (18 U.S.C. § 1030) against all defendants for accessing protected computers without authorization to obtain confidential information (Compl. ¶¶ Counts section). The complaint alleges that Wiggins, Stielow, and unnamed defendants accessed the Foundation’s email systems and servers without authorization, obtaining confidential information that was later included in the dossier (Compl. ¶137, ¶145). The complaint asserts that the defendants’ actions caused a minimum loss of $5,000 to Beasley, satisfying the damage requirement under the CFAA (Compl. ¶¶ amounts section). The complaint further alleges that Defendants Birdsong, Lankford, Chandler, Green, and Jane/John Does acted in concert to obtain stored communications without authorization (Compl. ¶139).
The complaint seeks treble damages for the injuries sustained by Beasley under 18 U.S.C. § 1964(c), as well as costs and reasonable attorneys’ fees (Compl. ¶210, ¶214). The complaint also brings claims for invasion of privacy, defamation, false light invasion of privacy, intentional infliction of emotional distress, intentional interference with business relationships, civil conspiracy, and intrusion upon seclusion. The complaint alleges that the defendants’ conduct was "so outrageous in character and so extreme in degree as to go beyond all possible bounds of decency," entitling Beasley to damages for intentional infliction of emotional distress (Compl. ¶239). The complaint further alleges that the defendants’ actions constituted a "substantial and intentional invasion of Plaintiff’s privacy," warranting damages under the intrusion upon seclusion claim (Compl. ¶263). The complaint states that the defendants obtained private emails, financial records, and information concerning Plaintiff’s minor daughter, and that they compiled a dossier on Plaintiff’s professional and personal life unrelated to Foundation business (Compl. ¶259, ¶260).
Defendants’ Actions Allegedly Caused Emotional and Professional Harm
The complaint alleges that the defendants’ actions caused Beasley significant emotional harm, including anxiety, distress, and humiliation, and that she sought medical treatment as a result (Compl. ¶132). The complaint further alleges that the defendants’ campaign was designed to undermine Beasley’s professional relationships with donors, officials, and community leaders, which were critical to her employment and reputation (Compl. ¶244). The complaint quotes the dossier’s dissemination instructions, with Green advising a recipient to "remain discreet, in advance of the publication of the Document" (Compl. ¶123). The complaint alleges that the defendants targeted Beasley’s relationships with individuals such as Mayor Ken Moore, Alderman Patrick Baggett, and Foundation board members Tyler Borders and John Bond, among others (Compl. ¶244). The complaint states that the defendants’ conduct was motivated by a desire to remove Beasley as CEO and impair her professional standing, and that their actions were part of a coordinated effort to "expose" her and the alleged "financial scandal" at the Foundation (Compl. ¶247, ¶168).
The complaint alleges that the defendants’ actions disrupted or impaired Beasley’s relationships with key stakeholders, resulting in a loss of compensation, reputation, future earning capacity, and business opportunities (Compl. ¶248-249). The complaint states that Beasley suffered a 20% reduction in her salary and the loss of her 2025 bonus due to the Foundation’s financial decline, which the complaint attributes to the defendants’ actions (Compl. ¶130). The complaint also alleges that the defendants acted intentionally and maliciously, entitling Beasley to compensatory and punitive damages (Compl. ¶250). The complaint describes how the defendants conspired to unlawfully obtain and disseminate Plaintiff’s confidential information, including drafting false statements with ChatGPT and disseminating the dossier via email accounts created for this purpose (Compl. ¶253, ¶157).
The complaint further alleges that the defendants’ dissemination of the dossier led to calls from Franklin residents for Beasley’s termination, and that the defendants coordinated to obtain Plaintiff’s private communications and distribute the dossier (Compl. ¶115, ¶114). The complaint states that Defendant Birdsong solicited confidential information, recruited participants, and coordinated CCWC communications, while Defendant Chandler admitted to Mayor Moore about the distribution of the dossier to media and state agencies (Compl. ¶117, ¶118). The complaint also alleges that Defendant Lankford participated in the creation and dissemination of the dossier, and that Defendant Wiggins improperly acquired and transmitted confidential Foundation documents (Compl. ¶120, ¶121). The complaint states that Mary Catherine Mousourakis, a former Foundation employee, participated in the creation and distribution of the dossier, and that Brian Laster and Alderman Baggett possess knowledge of document-related communications (Compl. ¶126, ¶127).
The allegations in the complaint are unproven, and no defendant has yet responded to the claims. The complaint seeks damages for the harm caused to Beasley’s reputation, emotional well-being, and financial stability, as well as injunctive relief to prevent further dissemination of the dossier and unauthorized access to confidential information.