Nothing To See Here
[Update as of 1/24/23*— Well well well…It looks like the investigation IS still currently ongoing for TM “Dumbass.”] (See added receipt)
Despite the claims of Salem Board of Selectmen Chairperson, Cathy "Puppet" Stacey, Salem Town Manager Chris Dillon is indeed being criminally investigated by the Strafford County Attorney. Unlike other LEAKS, this Leak will not contain all of the #receipts attached, in order to protect the integrity of the investigation. You will see from the below, actual complaint filed, the #receipts do exist and were attached to this complaint. RobbiLeaks will attach the two media articles that were published, which confirm the existence of the investigation, yet Chris "TM Dumbass” Dillon remains on the job. Methinks........not for much longer.
July 8, 2022
RE: Perjury Complaint - Town Manager Christopher A. Dillon
I suspect you have read or heard about RobbiLeaks. You may have seen or heard about the many #receipts that I have been posting, through 77 Episodes of RobbiLeaks, which commenced on January 19, 2022.
I'm certain Christopher Dillon, Salem Town Manager, claims my settlement of $100,000 was a victory for the Town of Salem, explaining that my attorney requested the maximum of $325K that Primex would cover for each lawsuit (1. Town, Dillon, and Fogarty 2. McKean), plus roughly $300K for lost wages. That is all true, but money was never my goal. My goal was to restore my name and reputation and, quite frankly, there is no sum of money that makes me whole for what was done. My 24-year career was literally destroyed overnight. I did not care how many zeros were on the check. I refused to settle for any amount that had a Non- Disclosure Agreement (NDA) attached. Mr. Dillon gambled that no one would care, nor listen to what I had to say. I hope we can all agree that was a bad wager.
I am not going to ask you to take my word for anything. I will provide proof of each allegation/claim that I make. Each #receipt will be labeled as an Exhibit (ie. See Exhibit 1) and each Exhibit will be attached to this writing.
It is my belief, as well as many others, some political wrangling, orchestrated by Selectman Jim Keller, Selectman Michael Lyons, and former Selectman Everett McBride, occurred when Mr. Dillon was afforded a 2-year extension to his contract in September 2021. This vote was taken despite the Salem Police Union's Vote of No Confidence and the BOS voting against a 1-year extension just months prior, I hope that no one has been fooled to believe that vote was not a big part of the reason for Mr. McBride's failed re-election bid.
I, and many others, do not believe the decision to take a vote to extend Mr. Dillon's contract for a 2-year period was a coincidence. Many believe Selectmen Keller and Lyons knew that Mr. McBride was vulnerable, and if Mr. McBride was defeated, Mr. Dillon's contract would likely not have been extended. Though I believe Mr. McBride would have been defeated even if he would have voted against the 2-year extension, his poor decision to vote for the contract extension, sealed his fate. And for the record, Selectman Keith Stramaglia has proven to be a breath of fresh air.
To rid the Town of Salem of Mr. Dillon, and avoid paying him over $300K to leave, there must be CAUSE to remove/terminate him. RobbiLeaks has been outlining the CAUSE for months, but now I am filing a formal complaint.
I believe Mr. Dillon lied, under oath, on at least two occasions (December 2020 and April 2022). I suspect another complaint addressing the April 2022 incident in greater detail is forthcoming. My complaint will address the December 2020 incident, and a few other issues.
I will also be sharing information from Mr. Dillon's deposition in December of 2020. The deposition transcript is 277 pages and had 25 exhibits that were used. The deposition was conducted by my attorney, Andrea Amodeo-Vickery. I paid for the deposition. The deposition is my property, and I can share with whomever I like. That said, I will only share the pertinent parts of the deposition. I have been prevented from sharing documents due to a protective order. However, the same documents that are under protective order in my case are part of the public record in another case (Exhibit 11– Case: 1:20-cr-00105-PB). Therefore, I will provide those documents as well.
In December of 2020, Atty. Amodeo-Vickery deposed Mr. Dillon for nearly eight (8) hours. There were several areas Mr. Dillon was questioned about. Mr. Dillon was sworn-in and therefore was under oath. Perhaps Mr. Dillon was unaware that lying under oath, outside of a courtroom, is also a crime. As you are aware, it is a Class B Felony (See Exhibit 1-NH RSA 641:1 Perjury).
Atty, Amodeo-Vickery questioned Mr. Dillon about a meeting he had at the Office of the Attorney General on January 14, 2019. Mr. Dillon emphatically claimed he did not bring any items to that meeting, other than the material the AG requested (all IA files from 2013 to 2018 and all time and attendance slips for time off from 2016-2018). Mr. Dillon stated he did nothing to prepare for the meeting, stating, "what was I going to prepare for, they were going to ask me questions," (See Exhibit 2 -- Transcript of Mr. Dillon's deposition, pgs. 248 -277).
On January 9, 2019, at the behest of former PD employee, Sgt. Chad Clark, Mr. Dillon, and Ms. Fogarty entertained a meeting with all SPD supervisors below the rank of Captain (all Sergeants and Lieutenants). The following individuals attended the meeting: Lt. Shane Smith (now Deputy Chief), Lt. Joe Keating (now Captain), Lt. Jason Smith (now Captain), Lt. Tom Kench, Lt. Kevin Fitzgerald (promoted to Captain, now retired), Sgt. Brendon Gleason (now Lieutenant), Sgt. Steve Wydoila (now retired), Sgt. Eric O'Brien, Sgt. Mike Bernard, Sgt. Chad Clark (promoted to Lt., then demoted back to Sgt. when he was approved for an accidental disability retirement), and Sgt. Mike Verrocchi, who oddly, was not invited to the meeting by Sgt. Clark. Fortunately, Sgt. Verrocchi was made aware of the meeting, by Mr. Pattullo, and though late, due to not knowing about the meeting, did show up. Sgt. Bob Genest (now Lieutenant) and Sgt. Justin Bagley (now Lieutenant) did not attend the meeting, as one was on vacation and the other was at training.
The following people spoke at the meeting: Shane Smith, Kevin Fitzgerald, Steve Wydoila, and Chad Clark, while Mr. Dillon and Ms. Fogarty feverishly took notes. (See Exhibit 11). Those who spoke told stories for which they not only didn't have the facts but had no firsthand knowledge about. Sgt. Verrocchi was the only person to speak up and point out the stories being told had no basis in fact. In fact, Sgt. Clark took exception to Sgt. Verrocchi's comments and the two nearly came to blows. You don't have to take my word for it, I wasn't there, but I suspect Sgt. Verrocchi, who was there, will have no issue answering any questions you may have.
On January 14, 2019, Mr. Dillon and Mr. Pattullo drove to the Office of the Attorney General and met with Sr. AAG Geoffrey Ward, AG Investigator Scott Gilbert, and AG Investigator Jim Kinney. Sr. AAG Ward took notes (See Exhibit 3 – Sr. AAG Ward's handwritten notes from 01-14-19). It is quite clear that Sr. AAG Ward was writing notes about what Mr. Dillon was reporting, which was information that he did not corroborate, verify, investigate, or ask anyone else to investigate. The information Mr. Dillon reported to the Office of the Attorney General came from the 1-9-19 meeting with the sergeants and lieutenants.
In the deposition, from December of 2020 (Exhibit 2), Mr. Dillon states several times, "I don't recall", I don't remember", "I don't know if they told me or 1 told them", "I didn't verify", "What was I going to prepare for, they were going to ask me questions." He also stated he did not bring anything other than what the AG asked him to bring. That is a lie, he brought his handwritten notes, as well as the memo Ms. Fogarty sent to him on 1-10-19 (See Exhibit 11). Mr. Dillon and Ms. Fogarty recently testified in Federal Court, and both had to admit to the above. The court transcript is a public record (Case: 1:20-cr-00105 – PB). Mr. Dillon lied about a material fact. That material fact being that he didn't report it to the AG. Mr. Dillon claims many times in the deposition, he didn't know how the AG became aware.
Many of the topics in Mr. Dillon's handwritten notes and Ms. Fogarty's memo were not in the audit. (See Exhibit 11). Before you go believing Mr. Dillon's memory failed him, as he tried to claim, I direct your attention to pages 94 -100 of Exhibit 2. Mr. Dillon tells quite a story from 10-15 years ago with amazing clarity. Though this story is also not accurate, Mr. Dillon asserts he remembers this incident clearly, but does not "recall or remember" an incident from 2 years prior. In those same pages, Mr. Dillon talks about (Redacted) complaint and how it was not investigated. Please review the letter dated 1-19-18 from the Office of the Attorney General. You will note the "We are referring the complaint back to you for whatever internal action you deem appropriate." Chief Donovan did indeed review the complaint and did not deem any further internal action was necessary. The fact is, Mr. Dillon and Ms. Fogarty were not happy with the Chief's decision, but that is a far cry from the assertion "the Chief didn't do anything.”
In pages 94-100, Mr. Dillon also states he didn't trust me because he thinks I lied to him about members of the Bud Com contacting me. I told Mr. Dillon, "They called me, I didn't call them." I never stated I didn't talk to any member from the Bud Com. I also sent him the presentation I'd be presenting to the Bud Com, for his review and changes, if requested.
It is not necessary to remember the truth, it is only necessary to remember lies. The truth should be told the same way, every time. The truth and facts don't change. Simply stated, I believe Mr. Dillon perjured himself under oath.
On January 17, 2019, I was placed on Administrative Leave with pay (See Exhibit 4- Sr. AAG Ward letter to Dillon and Pattullo, and Dillon's letter to me placing me on Admin Leave with pay). You will note, Sr. AAG Ward makes no mention of the potential crimes being investigated. In fact, the Office of the Attorney General never announced publicly what crimes were being investigated.
I was investigated by the AG for twenty-nine (29) months (Jan. 2019 to June 2021). I volunteered to testify at Grand Jury, where I would not have the benefit of counsel. There were six (6) Grand Jury sessions (March 2019, April 2019, May 2019, June 2019, July 2019, and August 2019). The AG declined my offer to testify. I volunteered to report to the Office of the Attorney General to answer all questions, without a grant of immunity. The AG declined that offer as well. No one from the Office of the Attorney General spoke to me, informally or formally, and that remains true to this day. I was not indicted, I was not charged, and I surely was not convicted of so much as a parking ticket.
Mr. Dillon has stated, many times, this does not mean I am Exonerated. First, I would like to point out Exonerated is not a legal term. The legal term would be Not Guilty. To be found Not Guilty I would have been charged with a crime and gone to trial and received a Not Guilty verdict from a Judge or Jury. I was not charged with a crime. To be charged with a crime there would need to be Probable Cause. The Office of the Attorney General stated, "the State could not sustain its burden to prove beyond a reasonable doubt that Mr. Morin committed ANY of the above-referenced crimes." (See Exhibit 5- Sr. AAG Ward letter to Dillon June 1, 2021). It should be noted, the first time I became aware of what I was being investigated for was when I received this letter. You will note, there is no context to any of those crimes.
On December 26, 2019, Mr. Dillon sent an email to the BOS. In that email, Mr. Dillon listed several crimes he claimed the AG was investigating (See Exhibit 6 - Dillon email to BOS). In the deposition in December of 2020, Mr. Dillon stated he guessed what the AG was investigating (See Exhibit 2, pgs. 259- 261). Not only is Mr. Dillon's answer a complete fabrication, but Mr. Dillon has no experience or knowledge to support that statement. Mr. Dillon wrote that email to continue to place me and others in a false and negative light. You will also note that some of that same verbiage in that 12-29-19 email (See Exhibit 6) is identical to the 1-10-19 email that Ms. Fogarty sent to Mr. Dillon (See Exhibit 11).
Mr. Dillon is the person who told the AG that I, Sgt. Verrocchi and Captain Wagner should be investigated and relayed the information given to him by four individuals, Shane Smith, Kevin Fitzgerald, Steve Wydoila, and Chad Clark. Mr. Dillon made no effort to determine if any of that information had merit and admitted that in the deposition in December 2020. And further, much of his testimony, under oath, in December of 2020, was less than truthful.
I am aware, as are many others, of an employee complaint against Mr. Dillon. My assumption is the Salem BOS is going to investigate this complaint and will be paying for an outside entity to do the investigation, which is appropriate. The investigation should extend beyond the finite issue of the complaint the employee made.
The investigation should include investigating disparate treatment of employees by Mr. Dillon, the very real fear of retaliation by Mr. Dillon, and the HR Department being weaponized against employees.
The current complainant was treated much differently than Sgt. Verrocchi, Captain Wagner, and me. The employee, who filed the complaint, was not placed on Administrative Leave with pay, despite Mr. Dillon referring the complaint to a State Agency (Department of Revenue Administration) for potential criminal activity (See Exhibit 7 - Dillon complaint to DRA). This is not the first time Mr. Dillon has treated employees differently. In fact, the very same day (2-15-19) Sgt. Verrocchi and Captain Wagner were placed on Administrative Leave with Pay, the AG commenced an investigation on three other SPD officers (Sgt. Bob Genest, and others redacted for privacy purposes) These officers were also not placed on Administrative Leave with Pay, there was no press release, their careers were not destroyed. In fact, unbelievably, Bob Genest was promoted to Lieutenant while under investigation for a crime.
The Office of the Attorney General "conducted an investigation to determine whether any crime(s) may have been committed in connection to this incident". The Office of the Attorney General determined the investigation did not uncover any criminal actions by any Salem police officer. The AG investigation of this incident concluded in December of 2019. Bob Genest was promoted in July of 2019.
The Town of Salem's insurer, Primex settled with the complainant, in the above incident, for a sum much higher than the "nuisance" amount ceiling of $50,000. (See Exhibit 8 - AG letter to complainant's Atty). Though this letter is not written to Mr. Dillon, please don't be naïve to believe the AG conducted this criminal investigation without informing the Town and PD, just as they did for me, Sgt. Verrocchi and Captain Wagner (See Exhibit 4). The Office of the Attorney General does not investigate policy violations, they investigate crimes, please don't be fooled by any explanation that Mr. Dillon may provide. Mr. Dillon knew about the criminal investigation, and he treated these officers much differently. Just as he treated the current complainant differently. That is disparate treatment.
At the beginning of this writing, I informed you Mr. Dillon lied twice under oath. The first incident was December of 2020. The most recent incident was April 2022. In an arbitration hearing, under oath, Mr. Dillon was asked about his knowledge of the Office of the Attorney General's criminal investigation of Bob Genest, (others redacted.) Mr. Dillon denied knowledge, under oath. Mr. Dillon was then asked if he knew of any other Town Employee who were investigated by a State or Federal Agency, like the Revenue Department or IRS. Mr. Dillon denied any knowledge, under oath. Mr. Dillon then doubled down, under oath, when he was asked about, (redacted) the current complainant. The complaint Mr. Dillon sent to the DRA is subject to 91-A. It seems clear to me, Mr. Dillon perjured himself under oath. Dishonesty is certainly CAUSE to terminate. I suspect you will soon be receiving a more detailed complaint about this incident.
Not one of the above employees was treated the way I. Sgt. Verrocchi or Captain Wagner were. I will share with you a sampling of the tactics Mr. Dillon employed with me. Mr. Dillon was successful in destroying my career, as well as a few others.
Exhibit 9 is a series of letters Mr. Dillon sent to me. The first one dated 5-14-19 is about the Haverhill IA. Selectman Lyons should be familiar with this complaint since he was openly talking about it and stated, "something needs to be done about this" in August of 2017. There is a firsthand witness, and she is happy to provide an affidavit to that statement. Sadly, not only should Selectman Lyons not have had any knowledge of this complaint, but he certainly should not have been opining about my guilt, especially since he didn't know the facts.
The complainant in the Haverhill incident is currently a resident of Cedar Junction and will be for the next 8-10 years. I draw your attention to an affidavit from (redacted) a woman whom I don't know, but who came forward in September of 2019, after reading a story about this in the Eagle Tribune.
Where did Selectman Lyons get his poor information from? Please see statements from Chief Donovan, Jim Chase, Joel Dolan, and Atty. Heather Newell-Iworsky. You will also see a finding from the Clerk Magistrate, dated 5-12-17. Lastly, you will see an affidavit from Chief Donovan, explaining what happened in a meeting he had with former Town Manager Leon Goodwin and former HR Director Molly McKean in March of 2017. The proof, which supports Chief Donovan's assertions are under protective order.
Mr. Dillon hired a private investigator to conduct an IA in February of 2019 on the same incident, because he believed it was not investigated. The documents clearly show that assertion is not factual. Once again, Mr. Dillon and Ms. Fogarty were not pleased with the outcome, and neither was Ms. McKean. Mr. Dillon ordered an investigation on this incident more than 2.5 years after the incident allegedly occurred. The investigator hired, sustained 16 violations of SPD General Orders. I produced a 186-page rebuttal, with 23 exhibits, proving the investigator was wrong and clearly demonstrated, THE INVESTIGATION WAS SURFACE, AT BEST. Mr. Pattullo wrote a letter to Mr. Dillon, recommending termination based on the Investigator's finding, however never afforded me a hearing and therefore I was not given an opportunity to rebut the allegations until the termination hearing with Mr. Dillon, I was not terminated.
Please read the letter, dated 5-29-19 from Mr. Dillon, stating he is withholding my earned and unused sick time, because Mr. Dillon deemed, I did not leave on a "positive basis". I draw your attention to my retired ID, which says something very different. Although I had to wait 18 months for my arbitration hearing, I won and was awarded more than $35,000 dollars and my pension was re-calculated and is now nearly $600/mth higher.
Not only did Mr. Dillon withhold more than $35,000 that I earned over the course of 15 years, but he tried to impact my future income by more than $7,000 per year. Please read the letter from Mr. Pattullo, dated 9-3-19, advising of the intention to place me on the EES Schedule (Laurie List). I immediately requested a hearing. That hearing never happened.
When Joel Dolan was appointed Chief, he opted not to move forward. Hold that thought, you will understand why Joel chose not to hold that hearing very soon.
There are many communications from Mr. Dillon to the Office of the Attorney General, under protective order, which demonstrate Mr. Dillon basically begging the AG to act and providing unverified information, to include information about a selectman.
The current Chief of Police is guilty of "Double Dipping". Mr. Dillon knew of Joel Dolan's practice. because I told him. I also told Joel to cease the practice in November of 2017, when I was promoted to Deputy Chief. Yes, you can criticize me for not conducting an IA, believe me I wish I had now. You can't accuse me of covering it up, however, because I reported it to Mr. Dillon and told him how I handled it. Mr. Dillon was satisfied with how it was handled and did not request a formal IA. In fact, Mr. Dillon commended me for changing the policy. I informed Mr. Dillon there never was a policy that stated Double Dipping was allowable or appropriate. I told Mr. Dillon I was Joel's boss and told Joel to cease the practice immediately. Mr. Dillon chose another avenue, which has been very costly for the taxpayers. (See Exhibit 10- Anonymous letter sent to AG in March of 2019 and email from Dillon to Dan Linskey from Kroll)
Please don't fall for the explanation that I wrote that letter to the AG. I think it is beyond clear I have never done anything anonymously in my life. Also don't fall for the excuse that Joel Dolan had a lot of Administrative Time from attending BOS meetings, as Mr. Dillon states in the December 2020 deposition (See Exhibit 2, pgs. 110-124). I have the master schedule from 2017, which show more than 30-days in which Joel was not at work, but there are no time-off slips that accompany those days. You can pull and review every BOS meeting in 2017 and total the number of meetings Joel attended and the amount of time he was there. Joel Dolan knows I have the goods on him and that is why he did not want to move forward with placement on EES, which of course would have been foolish. The AG may have thrown a lot of it against the wall, but nothing stuck.
An entire MA State Police Barracks was closed, and several MA State Troopers were indicted, convicted, and sentenced to prison for the exact same thing. Joel Dolan is the guy Mr. Dillon chose to be the head of the Police Department. Joel Dolan has yet to be held to account. The AG received that anonymous letter (Exhibit 10) and sent it back to Salem to investigate, then accepted the explanation that Joel had Administrative Time. Mr. Dillon states in his deposition, he never saw the investigation, but Mr. Pattullo told him he looked into it." It seems odd to me, as it should you, Mr. Dillon accepted Mr. Pattullo's explanation, but did not accept Chief Donovan's explanations. I'm telling you; Joel Dolan did not have more than 240 hours of Administrative Time, and I have the master schedule to prove it.
The current Deputy Chief isn't any better suited for the position. Just six (6) days after Captain Wagner was placed on Administrative Leave, then Lt. Shane Smith shows up at HR and attempts to put the proverbial nail in Captain Wagner's coffin. I think you might be smart enough to see exactly what that was all about. You think maybe Shane was hoping to have Captain Wagner's job? (See Exhibit 11). Shane is now the Deputy Chief, a position which far exceeds his experience and intellect.
Mr. Dillon should be placed on Administrative Leave during the investigation for the exact same reasons he cites, in the first paragraph, to me in his letter dated 1-17-19 (Exhibit 4). This investigation will require interviews of many employees, who will not feel comfortable, nor will they likely give truthful responses, knowing Mr. Dillon is in the building for fear of retaliation. Placement on Administrative Leave with pay, will send a message to all employees that this complaint is being taken seriously and will also protect the integrity of the investigation.
Many good and real people were wronged by Mr. Dillon and Ms. Fogarty and thus far, it appears the Salem BOS is complicit. I believe Mr. Dillon is a liar, I believe he lies by omission, I believe he doesn't tell the whole story, rather only the parts he can spin.
I have heard, from many people, Mr. Dillon refers to me as a "disgruntled former employee." I am not disgruntled, I am disgusted by everything that has transpired, and the appearance that it has gone unchecked.
I look forward to your immediate action.
Sincerely,
Rob Morin
