LYNCH, TRAUB, KEEFE AND ERRANTE A PROFESSIONAL CORPORATION ATTORNEYS AND COUNSELORS AT LAW 52 TRUMBULL STREET ‘panes Rene P.O. Box 1612 + Sraven J. ERRANTE NEW HAVEN, CONNECTICUT 06506-1612 vo JOHN J. Keare, Jk. PHONE (203) 787-0275 * Donn A. SWIET “Dy Tae Srmvcous For JosTice FoR OvER 50 Veans” Pax: (203) 782-0278 Cetanies E. TERNAN, ITT E-MAN: ——_LAWYERS@LTxE.comt Roser W. LYNCH INTERNET: HTTP: //WWW.LTKE.COM ‘RICHARD W. LYNCIL + Timomwy P. PoTIN + BoarD CeRTIHT=D CIVIL TRIAL LawvER Louis M. Ruspano ¢° BOARD CERTIFIED CRIMINAL TRIAL LAWYER + MARISA A. BELLAIR ** BOARD CERTIFIED CIVIL AND NANCY FITZPATRICK MYERS CRIMINAL TRIAL LAWYER BENJAMIN D. GETTINGER 4 Atso ADMITTED IN NEW YORK £ Atso ADMITTED IN FLORIDA ‘WILLIAM C. LYNCH, FOUNDER (3924-2006) March 30, 2011 Chief Daryl K, Roberts Hartford Police Department 50 Jennings Road Hartford, CT 06120 Re: Our File: 24754-1 Dear Chief Roberts: Please be advised that I represcnt 2 M—NNNMID regarding false accusations made against him and consequential treatment of him by your department. As I understand it, (7M, was brought into the office of Assistant Chief John Horvath elong with two other supervisors and was informed that there was hearsay information that he was using narcotics. He was asked if he would voluntarily submit to urinalysis to which he immediately agreed. Notwithstanding his ready agreement, no test was offered by the Department. The tone of the meeting was accusatory and despite the coercive atmosphere of it, 7 repeated his willingness to take a test in order to prove that the allegations were totally false. Because the Department did not follow through with a urinalysis, went to his private doctor and received a referral to~~ juest Diagnostics and a urinalysis was performed two days later:One week after the initial meeting, S///ZMMNNB was informed by Lt. $@MMMB that the Department was going to test him. Qa MMM vent to see Assistant Chief Horvath and communicated his is disappointment that he had offered to take a test and the Department failed to act on it. QD inquired by an internal investigation had not commenced and also about the source of the scurrilous and slanderous allegations. He was advised to “leave it alone” and that is was “over.” It is my understanding that [——/ QE subsequently met with you and presented his copy of the urinalysis and requested you to initiate an internal affairs investigation. I understand that you similarly advised him to “leave it alone.” In the meantime, as the investigation progressed, I understand that it was revealed that the false information came from a sergeant who had heard rumors. I also understand that Sergeant (MMMM report asserted information from a confidential source (later identified as Sergeant AMM) chet indicated that MMM vas utilizing cocaine and ecstasy. Sergeant QMMMBreportedly denied making such a statement. During the above proceedings, the Department failed to maintain confidentiality causing severe and irreparable damage to > QQ reputation. I understand that he was removed from his office, was not given access to his computer or even a phone to conduct his work. His belongings were packed up and locked in an office and he was deprived of access to a department vehicle. A meeting with the police union president resulted in > being informed that the Department was now again focused on investigating the use of narcotics by him. To date, he has been offered no test to disprove the allegation. He has taken five independent urinalysis examinations by different doctors and in different laboratories, including one at a hospital where he was taken because of chest pain. ‘SMES EYEE, 22s becn unable to function normally since the onset of this ordeal. It appears that he is being persecuted because he stood up to protect his reputation. His respective and competent previous supervisors have never raised any performance issues. Please consider this an official request pursuant to the State's Freedom of Information Act for the following: © All written memorenda, reports, witness statements, notes from meetings, interviews and investigative interviews regarding this matter;Department telephone records (both office and cell phone) during all relevant periods, from Assistant Chief John Horvath, Lt. [ily UMM. Sergeant GUND GMEB 26 Sergeant C I£ you have any questiens, please feel free to contact me. very truly yours, oe a Hugh F. Keefe HFK/mpa ceQuest sem i S&S Diagnostics ete nisin ‘ssvonn ccarve FINAD (uss? pIAGKOSTIes miconroRATSO capeeins puvszczaN cureur senvice 3-266-697-8378 Doe: AE ACE: aD GENDER: curENT ovoRtz08 SPECIMEN: WC145907P 3 1B g6177780 | Cesena REQUISITION: o0025¢s * “fons?” 860.863.5416 COLLECTED: 03/03/2011 11:18 BT RECEIVED: 03/03/2011 11:19 BT REPORTED: 03/04/2011 05:28 ET. Test Nane In Range Out of Range Reference Range Lab DRUG ABUSE PANEL 10-50 ca, NO CONFIRM * These results are for medical treatment only. + * Analysis was performed as non-forensic testing, * AMPHETANINES (1000 ng/ml SCREEN) NEGATIVE BARBITURATES NEGATIVE NEGATIVE COCAINE METABOLITES NEGATIVE MARIJUANA METABOLITES (50 ng/ml SCREEN) NEGATIVE NETHADONE NEGATIVE MBTEAQUALONE NEGATIVE OPIATES NEGATIVE PHENCYCLIDINE NEGATIVE PROPOXYPHENE NEGATIVE * Endnote 1 SEED sss07e Page 1 - Continued on Page 2