Affidavit of Special Agent Kevin D. Constantine I, Kevin D.

Constantine, being duly sworn, state that the following is true to the best of my knowledge, information and belief: 1. I am a Special Agent with the Federal Bureau of Investigation (FBI) in the

Boston Division and I have been employed by the FBI for 15 years. I am authorized to investigate violations of the laws of the United States and I have the authority to execute federal arrest and search warrants. As an FBI agent, I have directed, conducted, and participated in many investigations, including investigations of public corruption offenses. During those investigations, I have executed search and arrest warrants, utilized informants, interviewed witnesses, conducted surveillance and participated in trials. 2. This affidavit is submitted in support of an arrest warrant for CHRISTOPHER

HOFFMAN. Based on the facts set forth herein, there is probable cause to believe that HOFFMAN obstructed justice in violation of Title 18, United States Code, Sections 1512(b)(3) and 1512(d)(2). The information described in this affidavit is based on my own personal knowledge and information that I have received from other law enforcement officers involved in this investigation. This affidavit does not contain all facts known to me regarding this investigation; rather, it contains those facts necessary to establish probable cause for issuance of the requested warrant to arrest HOFFMAN. Relevant Statutes 3. Title 18, United States Code, Section 1512(b)(3) makes it illegal for any person

knowingly to use or attempt to use intimidation, threats or corrupt persuasion, or to engage in misleading conduct toward another person, with the intent to hinder, delay or prevent

communication with a law enforcement officer or judge of the United States regarding information related to the commission or possible commission of a Federal offense. 4. Similarly, Title 18, United States Code, Section 1512(d)(2) makes it illegal for

any person intentionally to harass another person, or attempt to do so, and thereby hinder, delay, prevent or dissuade the person from reporting to a law enforcement officer or judge of the United States information regarding the commission or possible commission of a Federal offense.

Factual Background 5. HOFFMAN began working as an associate probation officer in or about 2001.

He became a probation officer in 2004. In 2008, he was promoted to Acting Assistant Chief Probation Officer in Greenfield District Court. In 2009, HOFFMAN was promoted to Acting Chief of the Hampshire Superior Court in Northampton, Massachusetts. HOFFMAN held that position until on or about October 26, 2011 when he was placed on administrative leave. 6. From in or about 2001 to the present, Maureen Adams has been employed as a

probation officer in the Hampshire Superior Court. From in or about 2009 to on or about October 26, 2011, HOFFMAN was Adams direct supervisor. 7. On or about October 18, 2011, FBI Special Agent Dominic Barbara (Agent

Barbara) called Adams to set up an interview regarding an ongoing federal investigation into fraudulent hiring practices within the Office of the Commissioner of Probation (OCP). Adams agreed to be interviewed and the interview was scheduled for 3:00 pm on October 19, 2011. 8. Following the telephone call from Agent Barbara, Adams went to HOFFMANS

office to tell him she would need to leave work at 3:00 pm the following day for an interview with the FBI. HOFFMAN understood that the purpose of Adams interview was to discuss the 2

alleged fraudulent hiring practices within OCP. 9. At the time Adams told HOFFMAN about her interview, HOFFMAN knew there

was an ongoing federal investigation regarding the alleged fraudulent hiring practices within OCP. Indeed, the FBI interviewed HOFFMAN in connection with this investigation on August 31, 2011. 10. After Adams told HOFFMAN about her interview, HOFFMAN made several

comments to her throughout that day and the following day, October 19, 2011, prior to her interview. In sum and substance, HOFFMAN said the following to Adams prior to her interview with the FBI: (A) (B) (C) I will tell everyone that you are a rat; You will be in jail within a week; After the interview, you have to come back and tell me everything that they ask you and everything that you said; I only knew [Deputy Commissioner] Bill Burke because we grew up together in Hatfield, and I knew him as Mr. Burke; I only got to know Bill Burke once I became a probation officer [in 2001].

(D)

(E) 11.

HOFFMAN made each of the above-referenced statements while at work in the

Hampshire Superior Court. The statements referenced in paragraph 10, subsections (D) and (E), regarding HOFFMANS relationship with Deputy Commissioner William Burke were unsolicited. Based on her experience working for the probation department since 2001 and her understanding of HOFFMAN and Burkes relationship, Adams believed those statements to be false. Adams believed that the statements were made so that she would repeat them to the FBI if asked about HOFFMAN and Burkes relationship.

12.

Adams believed that all of HOFFMANS statements were intended to intimidate

her regarding her upcoming interview the FBI, and to influence her statements to the FBI, particularly with respect to any questions regarding HOFFMANS relationship with Deputy Commissioner William Burke. 13. As HOFFMAN was her direct supervisor, Adams felt intimidated by

HOFFMANS statements. In particular, Adams feared retribution by HOFFMAN, Burke and others as a result of her interview with the FBI. She became concerned for her job security. 14. Adams met with the FBI on October 19, 2011, as scheduled. The interview took

place at Friendlys Restaurant in Northampton, Massachusetts. When Adams arrived for the interview, she looked and sounded upset. She told Agent Barbara about HOFFMANS recent statements and expressed her concern that she would face recrimination as a result of her meeting with the FBI. 15. Following the interview, Adams returned to her office in the Hampshire Superior

Court. Shortly after, HOFFMAN came into her office and shut the door. HOFFMAN asked Adams whether she had discussed him (HOFFMAN) with the FBI. Adams said yes. HOFFMAN then left Adams office without saying anything. 16. The following day, October 20, 2011, Adams sent an email to the Commissioner

of OCP, Ronald Corbett. In that email, Adams told Corbett about some of the statements HOFFMAN made to her prior to her interview with the FBI. Adams also relayed the conversation she had with HOFFMAN after her interview with the FBI. Adams told Commissioner Corbett that she had concerns about retribution since he [HOFFMAN] is aware of my speaking to the FBI, as well as this email.

Conclusion 17. Based on the foregoing, there is probable cause to believe that HOFFMAN

obstructed justice by knowingly using intimidation and threats, and engaging in misleading conduct toward Adams, with the intent to hinder, delay and prevent her from communicating with the FBI regarding the federal investigation into the alleged fraudulent hiring practices at OCP. In addition, there is probable cause to believe that HOFFMAN obstructed justice by intentionally harassing Adams in an attempt to hinder, delay, prevent and dissuade her from reporting information regarding the fraudulent hiring practices at OCP to the FBI. WHEREFORE, this is probable cause to arrest HOFFMAN for violation of Title 18, United States Code, Sections 1512(b)(3) and 1512(d)(2).

_______________________________ Kevin D. Constantine Special Agent Federal Bureau of Investigation

Subscribed and sworn to before me this

day of December 2011.

________________________________ Timothy S. Hillman United States Magistrate Judge