STATE OF NEW HAMPSHIRE ROCKINGHAM, SS. da Zi 3 ie AH ‘92 SUPERIOR COURT Docket No. 90-E-00573 RICHARD SIMPSON ve THE TOWN OF EPPING, CHIEF GREGORY DODGE, AND THE EPPING BOARD OF SELECTMEN, LORRAINE RAUH, PAUL SPIDLE, AND MICHAEL JEAN AFFIDAVIT OF GREGORY DODGE AFFIDAVIT OF GREGORY DODGE I, Gregory Dodge, being duly sworn according to law, do say as follows: 1. am currently employed as the Chief of Police for the Town of Epping, New Hampshire. 2. Ihave been employed in this capacity since 1980. I held the title of chief of Police during the relevant period of this lawsuit. After an incident that occurred in West Epping, New Hampshire, on April 23, 1990, I received citizens’ complaints regarding alleged police misconduct on April 24th and April 26th, 1990. On May 2, 1990, I formally requested to have the incident investigated by the state police. On July 3, 1990, I received the incomplete state police investigation report. 4. After learning of the citizens’ complaints made against officers Todd and Simpson through a newspaper article, the members of the Board of Selectmen for the Town of Epping (the board) requested that I provide them with the state police report on the incident. Oy5. When the board requested to see the state police report, that report was still incomplete. At that time the report contained all of the investigations and interviews conducted by the state police, but did not include any conclusions or recommenda- tions. I gave the incomplete report to the chairman and then to the other board members on July 9, 1990. The board members had limited access to the report in that they each retained it only for a few hours. ‘The board did not review the state police report again until the officers’ disciplinary hearing. 6. The only communications I had with the Board of Selectmen regarding personnel issues prior to the officers’ disciplinary hearing were in executive sessions on July 9, 1990, and July 16, 1990. During those two sessions my disciplinary options with regard to the officers were discussed, but I did not indicate what disciplinary actions I would recommend. As of July 16, 1990, I had not personally decided what disciplinary actions I would be recommending to the board. Thus, I could not have been lobbying the board members, nor did I lobby the board members to "acquiesce" to my position with regard to discipline. 7. It is my firm belief that the Board of Selectmen were impartial and fair in their review of my disciplinary actions. The board did not in fact “rubber stamp" my recommendations, as is evidenced by the fact that they added a probationary period and an exclusion from overtime and details to the two week suspension I proposed for Officer Simpson.8. The foregoing statements are true and accurate to the best of my knowledge, information and belief. Gregory Doug COUNTY OF Q Subscribed and sworn before me this 2" day of Nyce , 1992. Notary Public/. ie Peace PATRICIA A. WOOD, Notary Public ‘My Commission Expires December 18, 1986