SPECIAL INVESTIGATION - Patrick D. Kingpatrickdking.com/wp-content/uploads/2014/11/Special-Investigative...SPECIAL INVESTIGATION: ... to question whether documents were inputted

SPECIAL INVESTIGATION:

PATRICK KING'S COMPLAINT FILED WITH

MANSFIELD UNIVERSITY CAMPUS POLICE

BY: PIETRAGALLO GORDON ALFANO BOSICK AND RASP ANTI, LLP

DATED: March 27, 2013

Page 1 of 30Special-Investigative-Report-into-Missing-Police-Records.pdf

I. INTRODUCfiON

This firm was retained by the Pennsylvania State System of Higher Education

("PAS SHE") to determine whether a complaint made by Patrick King ("Mr. King'') to the

Mansfield University Campus Police ("Campus Police") on or about April 2004 was inputted

into the Campus Police PA-LEMIS 1 computer software/database, and if so, why in 2012 the PA-

LEMIS system lacks any record of Mr. King's complaint.

It is undisputed that on or about April 2004, Patrick King, then a student at Mansfield

University, made a complaint to the Campus Police concerning alleged inappropriate sexual

contact by a janitor, John Estep, that allegedly occurred in 2001 and 2002? The fact that Patrick

King made the complaint is evidenced by an email from Molly Bailey, Human Resources

Director at Mansfield University, to Dr. Halstead, President of Mansfield University, on May 6,

2004. This email, attached as Exhibit 1, memorializes that Ms. Bailey received a telephone

message from Campus Police Chief Christine Shegan ("Chief Shegan") sometime on or before

Ms. Bailey's May 6, 2004 email. According to Ms. Bailey's email, Chief Shegan stated in her

voicemail that Patrick King had made a complaint against John Estep for sexual

harassment/misconduct that occurred in 2001. See Exhibit 1. Chief Shegan testified in her

deposition in the King v. Mansfield University litigation that Campus Police policy required that

all complaints received by the Mansfield Police Department be inputted into the Campus Police

PA-LEMIS system. See Exhibit 2. The Campus Police officers who were interviewed

unanimously confirmed this policy. In 2012, Mr. King's counsel requested information

concerning Mr. King's 2004 complaint to Campus Police during discovery in the King v.

1 PA-LEMIS is an acronym for Pennsylvania Law Enforcement Management Information System ("PALEMIS").

2 The merits of Mr. King's allegations concerning Mr. Estep's conduct are at issue in Patrick King v. Mansfield University of Pennsylvania, 1:11-cv-01112 (US.DC M.D. PA, June 9, 2011) (''King v. Mansfield University"). This investigation does not address the merits of Mr. King's allegations.

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Mansfield University litigation, however, Mansfield University was unable to discover any PA-

LEMIS record that documented the King complaint against John Estep.3 This sequence of

events has led Mr. King and his counsel in the King v. Mansfield litigation, Ralph Pinskey,

Esquire, to question whether documents were inputted into the Mansfield University P A-LEMIS

system and then destroyed or otherwise tampered with by someone affiliated with Campus

Police or Mansfield University.

ll.EXEC~SUN.DdARY

Our investigation has concluded that Patrick King, on or about the end of April or

beginning of May 2004, made at least a verbal complaint to the Campus Police about the alleged

2001-2002 sexual harassment/misconduct by John Estep. This complaint described alleged

sexual solicitation of Mr. King by John Estep. While much of this complaint concerned

allegations of unwanted verbal conduct by Mr. Estep to Patrick King and the attempted provision

of unwanted alleged pornographic material by Mr. Estep to Mr. King, Mr. King's complaint also

alleged that Mr. Estep forcibly grabbed Mr. King's crotch in the 2001-2002 timeframe.4

The Campus Police had policies in place, since at least Chief Shegan's hiring, that

required Campus Police officers to log all contact with campus constituents into the PA-LEMIS

system. Our investigation has determined that Mr. King's complaint never was inputted into the

PA-LEMIS system by the officer who ultimately received and addressed Mr. King's complaint.

While the age and idiosyncratic nature of the PA-LEMIS software used by the Campus Police in

3 No written record of any complaint made by Patrick King to the Mansfield Police Department in April!May of 2004 has been found, except for the Molly Bailey email referenced earlier as Exhibit 1.

4 This alleged conduct, if true, would potentially form the basis for a charge of Indecent Assault, 18 PaC.S. §3126, depending on whether a fact finder determined that Mr. Estep's alleged touching was done for the purpose of Mr. Estep's sexual arousal. These allegations could also form the basis for charges of simple assauh and/or harassment.

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the relevant timeframe proved a challenge, and required significant additional investigation, we

·are conclusively able to determine that Mr. King's complaint was not entered into the system and

then deleted.

As discussed infra, a complaint entered into the P A-LEMIS System cannot be deleted

through the PA-LEMIS software except by an individual with a PA-LEMIS Administrator's

module password. None of the Campus Police officers had access to the Administrator password

except for the System Administrator, Sergeant Delosa, and likely Chief Shegan. We have

interviewed both and conclude that neither of them deleted any Complaint concerning Patrick

King. Further, a complaint that was deleted would result in the Complaint number also being

deleted from the PA-LEMIS System. Our review of the Complaints in the PA-LEMIS System

from March 2004 through May 2004 demonstrate that there are no gaps in complaint numbers

during that time frame; therefore, no complaints were deleted.

Further, based on interviews with Mr. King and the Campus Police officers who were

employed in the relevant April-May 2004 timeframe and other information obtained during this

investigation, we conclude that the complaint was never entered into the PA-LEMIS system, in

violation of Campus Police policy. While we have been unable to ascertain definitively why Mr.

King's complaint was not entered into the P A-LEMIS system, we base this conclusion on the

following reasons: Mr. Estep was known to many of the Campus Police and had longstanding

relationships with several of the officers of the Police Department; Mr. King was viewed with

disfavor by a few of the Campus Police officers because he was perceived as difficult and

excessively demanding; too much time was deemed to have passed between Mr. King's

complaint and the alleged conduct; and/or the responding officer understood that the Mansfield

University Human Resources Department was investigating Mr. King's complaint and

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improperly deferred to the Human Resources investigation. We are unable to conclude,

however, whether any of these reasons or a combination of these reasons actually explains the

absence of Mr. King's complaint in the PA-LEMIS System and in the Campus Police records.

This failure to document Mr. King's complaint in the PA-LEMIS system appears to be an

isolated occurrence at Mansfield University.5

ill.INVESTIGATION PROCESS

A. Interviews6

Interviews were conducted with all but one of the police officers employed by the

Campus Police in the April to May 2004 timeframe, including:

• James P. Cobb

• Paul J. Delosa

• Cecilia L. Ehrler

• Charles F. Flaherty

5 A review ofthe PA-LEMIS database from Fall2003 through to Spring of2005, found five complaints of alleged sexual assault and five complaints of alleged sexual harassment documented with three of the alleged sexual assaults dated in the February, March and October 2004 timeframes. Further, none of the officers interviewed indicated that they felt any pressure by Mansfield University administration to conceal, on a systematic basis, allegations of sexual assault made to Campus Police. The interviewed officers denied that they were ever instructed to not document allegations of sexual assault/harassment and all denied ever concealing the reports of sexual assaultlha.rassment that they received_

6 All individuals were provided the following introduction before the interview was conducted: the

interviewed individual was advised that the finn was retained by the General Counsel's Office for the Pennsylvania State System of Higher Education, and was not counsel for Mansfield University or any of its cmrent or former employees. A brief description of the matter investigated was provided, summarizing that the firm was retained to determine what occwred when Patrick King made a complaint to the Mansfield Campus Police on or about late April or early May 2004 concerning sexual harassment/misconduct by John Estep in 2001. All individuals were advised that the interview was not confidential, and it was not privileged in any way, either by the attorney/client privilege or any other legal privilege. All interviewed individuals were advised that a report would be produced, and any information that they provided that was relevant to the report may be included and that the report may be made public. Other than Mr. King, none of those individuals interviewed had attorneys present All individuals agreed to cooperate after being advised of this information. One individual expressed the desire to stop being interviewed before the interview was completed; the interviewer honored that request and immediately terminated the interview.

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• David R. Knowlton

• Anthony T. Regalbuto

• Stephan L. Smith

• Douglas E. Thomas

• Gregori J. Zagozewski. 7

In additio~ the following Mansfield University officials were interviewed:

• Chief Christine Shegan

• Dr. Joseph Maresco, University Vice President in the relevant timeframe

• Dr. John Halstead, President of the University in the relevant timeframe

• Molly Bailey, Director of Human Resources in the relevant timeframe. 8

The following individuals with knowledge of the PA-LEMIS system used by the Campus

Police in 2004 were interviewed:

• Chris Bra~ of the Pennsylvania Chief of Police Association

• Linda Rosenberg, currently Executive Director of the Pennsylvania Commission on

Crime and Delinquency.

Patrick King was also interviewed in the presence of his counsel, Ralph Pinskey, Esquire.

B. Document Review

The following records were reviewed:

• May 6, 2004 email from Molly Bailey to President Halstead

• P A-LEMIS printout of Complaints from November 1, 2003 through May 31, 2005

7 The only member of the Campus Police employed in the relevant timeframe not interviewed was Lisa Marie Anne Lindquist, who was ~temporary employee in 2004. She was contacted and refused to be interviewed.

8 Ron Smith, Social Equity Coordinator at Mansfield University, was contacted at his last known address by telephone, but did not return any of the messages that were left. Accordingly, Mr. Smith has not been interviewed for purposes of this investigation.

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• October 23,2012 deposition of Christine Shegan in King v. Mansfield matter

• October 23, 2012 deposition of Joseph R. Moresco in King v. Mansfield matter

• October 24,2012 deposition ofMoUy Bailey in King v. Mansfield matter

• Mr. King's letter to various politicians, attached as an Exhibit "Bailey 2" to the October

24,2012 deposition of Molly Bailey

• Mansfield University Non-Discrimination Policy and Procedures from 2004

• Mr. King's statement concerning Mr. Estep's alleged conduct, attached as Exhibit 3,

hereto

• Complaint, King v. Mansfield University

• Answer of Mansfield University, King v. Mansfield University

• Defendant Mansfield University's Responses to Plaintiff's First Set of Interrogatories in King v. Mansfield University

• Pennsylvania Law Enforcement Management Information System User's Manual, Volumes I and II, and Administrator's Manual, for the PA-LEMIS System used by the Campus Police in the relevant time frame.

IV.PA-LEMIS

The Campus Police used the PA-LEMIS software/database ("database") in 2004 to

record complaints and prepare documents for criminal investigations. The PA-LEMIS database

is DOS-based software, using "D-base" database architecture, and was loaded onto a single

desktop computer in the Campus Police office. Data was stored on the desktop computer's hard

drive. Sergeant Delosa, who served as the Campus Police's primary authority on PA-LEMIS

and the System Administrator for PA-LEMIS, recalls seeing backup disks at some point, but

Campus Police have been unable to locate any backup disks for the P A-LEMIS system. The

desktop with the PA-LEMIS software and information is maintained by the Campus Police and

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is still functional. It was searched when Mansfield University was preparing to respond to

discovery in the King v. Mansfield University litigation. No responsive documents concerning

Mr. King's 2004 complaint were located.

The PA-LEMIS software was developed by an entity called SEARCH, described by

current PCCD Director Linda Rosenberg as a consortium of criminal justice agencies. PCCD

provided a grant to SEARCH in the early/mid 1990's to develop the PA-LEMIS software.

SEARCH then sold the PA-LEMIS software to various law enforcement agencies for

approximately $594.

The Pennsylvania Chief of Police Association provided support to agencies using the P A

LEMIS software from 1996 through to approximately 2002. It stopped supporting the P A

LEMIS software in or about 2003, when competing software with similar or enhanced

functionality evolved using the ACCESS database software. The Campus Police switched

software for complaints and investigative reports in approximately January 2008 and no longer

actively used the PA-LEMIS system after that date.

PA-LEMIS was reported by those interviewed to contain an "audit trail" function, which

tracked additions, deletions, and user patterns by individual users. Sergeant Delosa explained

that one of the idiosyncratic tendencies of the P A-LEMIS software was that the audit trail data

quickly overwhelmed the computer memory. As a result, the audit trail routinely required

purging approximately once a month to maintain the System's functionality. The

Administrator's Manual for P A-LEMIS confirms this information and provides instructions to

purge the audit trail. The PA-LEMIS software provided the option to print the audit trail prior to

purging, but Sergeant Delosa stated that he did not do so. He confinned that, since the System

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was used until approximately January 2008, that the 2004 audit trail data has been purged and

that no printout of that data was performed .. 9

The various individuals interviewed have different recollections of a user's ability to

delete or edit information inputted and saved in the P A-LEMIS database. According to Chris

Braun of the Pennsylvania Chief of Police Association, P A-LEMIS had two separate modules -

an Administrator module and a User module. His best recollection is that only the Administrator

module, accessible only by password, would permit P A-LEMIS data to be deleted or modified.10

The User module was the module employed on a day-to-day basis to record complaints and

investigative reports. To the best of Mr. Braun's reeollection, the User module did not permit a

user to delete data. He could not recall whether the user could edit data when accessing P A-

LEMIS through the User module.

At our request, Mr. Braun located the appropriate version of the PA-LEMIS manual, and

forwarded the manual to us on March 22, 2013 for review. Our review of the PA-LEMIS

manual confirmed that the User's module did not permit a user to delete a Complaint from the

PA-LEMIS System. 11 While a user could edit Complaints, the manual explains that there would

be a time stamp indicating the date the Complaint was changed. P A-LEMIS allowed officers to

create other records, using other screens - Incident, Accident, Arrest, Offense, Property, and

others - to compile additional data for investigative and arrest reports. While the data associated

with these screens could be deleted by a user in the User's module, the data associated with the

Complaint screen could not be deleted by the user in the User's module.

9 Sergeant Delosa, prior to being employed by the Campus Police, worked for a municipal law enforcement department which used PA-LEMIS. Sergeant Delosa's experience was that the printed audit trail was never used and became difficuh to maintain. Based on this experience, he decided not to print the audit trail when employed by the Campus Police.

10 lhis function was used, for example, to honor expungement orders. 11 "Complaint" was PA-LEMIS' vernacular for the first record completed in the PA-LEMIS System. The

Complaint contained fields for biographical information concerning the complainant and a brief description of the reason for the complainant's contact with the Campus Police.

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A Complaint could only be deleted through the Administrator's module. The

Administrator module had to be accessed separately, logged onto with an administrator

password, and then a record could be deleted. Sergeant Delosa explained in his interview that

he, as the System Administrator, had the password to access the Administrator's module, and to

his knowledge no one else had that password, with the exception of possibly Chief Shegan.

Sergeant Delosa credibly stated that he deleted no complaint involving Patrick King or John

Estep from PA-LEMIS. Chief Shegan credibly stated that she did not delete any such complaint

either.12

Fwther, such a deletion would leave a gap in the Complaint number sequence. 13 A

review of the complaints from March 2004 through May 2004 determined that no such gap in

complaint numbers exists. Therefore, no complaint was deleted in the relevant time frame.

Accordingly, for these reasons, we conclude that no data concerning Patrick King's complaint

was deleted from the PA-LEMIS System. 14

V. EXPLANATION OF FINDINGS

Mr. King was interviewed on January 31, 2013 at 2:00p.m. in the presence of his counsel

Ralph Pinskey, Esquire. The interview was conducted at the Dixon Center at the request of both

Mr. Pinskey and Mr. King. Mr. King provided the following information:

12 Sergeant Delosa explained that there were two other ways that a Complaint could be deleted from the PA-LEMIS System. One was the use of a file, Fix.exe, that could be accessed through DOS on the computer. Sergeant Delosa stated that, to his knowledge, no one else in the Campus Police was aware of this file, and he does not recall that the Campus Police had access to that file in the relevant time frame. The second was to access the data using D-base software. Either way required sophisticated programming and technological knowledge, which we conclude the Campus Police employees, other than Sergeant Delosa, lacked. Finally, if the data was deleted in this way, the Complaint number would also be deleted, leaving a gap in Complaint numbers. As noted, our review demonstrates that no such gap in Complaint number exists.

13 Whenever a Complaint was created in the Campus Police PA-LEMIS System, the software automatically assigned the next sequential number as the Complaint number.

14 Given the conclusions of this report, and this additional information, this firm did not believe that hiring a computer consultant to review the P A-LEMIS system was justified.

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Mr. King stated that near the end of April 2004, or sometime in the first week of May

2004, he was in the office of Dr. Phil Savoy, a professor at the University. Mr. King disclosed to

Dr. Savoy problems that he had with John Estep in the 2001 to 2002 timeframe. Mr. King also

4iscussed with Dr. Savoy the difficulties that he currently was having with his professors, the

nature of which are docwnented in Mr. King's complaint against Mansfield University. Dr.

Savoy recalled that another student also had an issue with John Estep, and recommended that

Mr. King file a complaint with the Campus Police.

Mr. King left Dr. Savoy's office, and decided to type a statement to memorialize his

experiences with John Estep before going to Campus Police to file a complaint. Mr. King

recalled that approximately a few days after his conversation with Dr. Savoy, he went to the

Campus Police at the Doane Center on the University of Mansfield's campus and filed his

complaint.

Mr. King recalled that, upon entering the Campus Police office, he approached a person

sitting at the reception desk behind a secured partition. He believed that it was a student worker,

although it could have been a non-uniformed employee of the Police Department. Mr. King told

the receptionist that he was there to make a complaint but could not recall if he characterized it

as a sexual assault complaint. Mr. King does not remember signing a log-in book and he does

not believe that the receptionist took any notes on a computer or otherwise when he first arrived.

The receptionist escorted Mr. King through the secured door into the main hallway of the

Campus Police Department and escorted him to a conference room off one of the hallways

across from the vending machines. Mr. King recalled sitting at a table in the conference room

and the receptionist providing him some sort of official form, which he was asked to complete.

Mr. King described the form as having space for biographical information on the top and a space

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on the bottom for his statement. Mr. King copied verbatim his pre-typed statement on to that

form. He believes that he signed and dated the form. A copy of the typed statement that Mr.

King stated that he brought with him that day is attached as Exhibit 3. After he finished, the

receptionist returned to the room, took the completed complaint form from Mr. King, and said

that a police officer would follow up and get back to Mr. King. Mr. King went home. Mr. King

does not recall that he met a police officer the day that he went to the station to make a

complaint, and he does not remember seeing anyone in uniform in the Campus Police office

when he was there.

Either in the late afternoon of the same day or within a few days of filing the complaint,

Mr. King received a call on his cell phone. Mr. King recalled that it was a male voice, stating

that he was calling in response to the complaint that Mr .. King had filed recently. Mr. King did

not recognize the voice and did not recall the name of the person, but he recalls that the man

identified himself as a police officer. Mr. King recalls that the male officer made some statement

to the effect that he believed that there was not much he would be able to do about the complaint

because the events occurred "a while ago" (in 2001 and 2002; it was then 2004).

Mr. King recalled telling the officer during the call about his concern that, since the

Campus Police answered to Mansfield University administration, the police may not want to

respond to his complaint Mr. King recalls the male officer saying something to the effect of, "as

far as he was concerned, he was answerable to the Governor." Mr. King indicated that it was a

brief conversation and that this was the sum of his recollection. Mr. King stated that the officer

never said that he would not follow-up on the complaint but Mr. King was doubtful that anything

would happen. Mr. King stated that he did not follow-up with the Campus Police after this

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telephone call and never returned to the police department to pursue further his complaint about

John Estep.

Mi. King believes he met with Molly Bailey after this cell phone call. 15 Mr. King never

contacted Chief Shegan, with whom he had significant prior contact about unrelated matters,

about his complaint against John Estep. Mr. King explained that while he was doubtful that the

police would do anything, he was not sure that they would not do anything. Mr. King explained

that, since he also raised his concerns about Mr. Estep with President Halstead and Molly Bailey

in Mansfield University's Administration and Ms. Bailey was investigating his complaints, he

did not think to follow up with the police.

We found Mr. King's recollection of filing a complaint with Campus Police in 2004 both

detailed and credible. In addition, Ms. Bailey's email of May 6, 2004 corroborates Mr. King's

recollection of filing the complaint with Campus Police. Further, the details of Mr. King's

complaint are consistent with Mr. King's recitations of his allegations to other third parties in

2004.

All male officers and all but one female officer who were employed by the Campus

Police in the April to May 2004 time:frame (according to the University's records), were

interviewed. No male officer recalled receiving or handling a complaint from Patrick King

regarding John Estep. No officer recalled any other officer mentioning that a complaint had been

flied against John Estep by Patrick King. Some of the officers had grown up in Mansfield with

John Estep or members of his family, or knew Mr. Estep and his wife from around town or

campus. A few of the officers recalled, or believed that they recalled, Patrick King. A few who

15 Ms. Bailey was assigned by President Halstead to investigate Mr. King's allegations against Mr. Estep, after Mr. King wrote Dr. Halstead and a number of Commonwealth officials about Mr. Estep's conduct and its impact on Mr. King's studies, as well as Mr. King's complaints about the faihn"e of his professors' to accommodate Mr. King in his studies. Ms. Bailey descn"bes her investigation in her deposition in King v. Mansfield.

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were interviewed recalled Patrick King as demanding and occasionally difficult. Every officer

interviewed expressed a clear understanding that Chief Shegan and Campus Police policy

required every contact with any individual on campus to be inputted into the PA-LEMIS system.

All officers who were questioned also acknowledged that the type of complaint filed by Mr.

King should have been entered into the PA-LEMIS system.

Chief Shegan has no recollection of hearing about the complaint against John Estep from

any of her officers, nor does she recall making the phone call or leaving the message that was

documented by Ms. Bailey in her email of May 6, 2004.16 Chief Shegan stated tha~ in an effort

to respond to Mr. King's discovery requests in the King v. Mansfield litigation, she and Sergeant

Delosa reviewed all hard copies of complaints filed in 2004 that were maintained by the Campus

Police to locate any documentation of a written complaint submitted by Mr. King about John

Estep. None were found. Chief Shegan also confinned that her office searched the P A-LEMIS

system and was unable to find any complaints filed by Patrick King against John Estep.

Chief Shegan also stated that it would have violated Campus Police policy (the policy in

effect in 2004) for a student dispatcher (''receptionist") to have escorted Mr. King to the secured

area of the Police Department and to have provided him a statement form to fill out, without a

police officer present in the office or available to interview Mr. King about his compl_aint at that

time. Nevertheless, Chief Shegan did not refute the possibility that a student dispatcher could

provide a complaint form without an officer available. Chief Shegan also concedes the

possibility that, if an officer was present but otherwise unavailable, the officer may have

instructed the student dispatcher to take the complainant into an interview room and provide the

16 Chief Shegan's contact with Molly Bailey of Human Resources is consistent with Campus Police's policy to notify Human Resources whenever a complaint is made against a University employee, in order to ensure that any employee disciplinary proceedings required by University policy occur, in addition to the processing of the complaint by Campus Police.

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complainant with the statement form. In this circumstance, the officer (or another officer on

duty), by policy, should have met with the complainant after the statement form was completed.

Chief Shegan stated that it is also possible that an officer could be lax and allow a student

dispatcher to take the complaint, even if the officer was available to meet with the complainant

that day. Chief Shegan confirmed that this latter scenario would have violated Campus Police

policy in effect in 2004.

Chief Shegan confirmed that the statement form used in 2004 is the same statement form

used today. An example of the statement form is attached as Exhibit 4. This statement form

matches the description provided by Mr. King of the form he was provided in 2004.

Chief Shegan confirmed that policy in 2004 required the Campus Police to open an

investigation file, with the statement form completed by the complainant as the first document in

the hard copy file. This hard copy file would have been stored with the other 2004 files. As no

documents concerning Mr. King's complaint can be found, the accumulated evidence leads to

the conclusion that the officer who received Mr. King's complaint likely discarded or misplaced

the paper complaint after speaking with Mr. King on the telephone.

VI. CONCLUSION

This investigation was challenged by the substantial amount of time that has passed since

the conduct under investigation occurred in 2004. This investigation concludes that: 1) Mr.

King's complaint was submitted to the Campus Police; 2) the Campus Police did not enter the

complaint into the PA-LEMIS system; 3) the hard copy report submitted by Mr. King was either

misplaced or discarded; and 4) the Campus Police acted inconsistently with its policies in the

handling of Mr. King's complaint.

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While a definite conclusion could not be reached as to why Mr. King's complaint was

handled in this fashion, the evidence suggests that the officer who ultimately received and

responded to Mr. King's complaint determined that the allegations against Mr. King should not

be addressed by the Campus Police. There. are many likely reasons, or a combination of reasons,

why the complaint was not pursued by the responding officer: Mr. King's complaint was

deemed too far removed from the alleged sexual misconduct/harassment for an investigation to

be effective; Mr. Estep was known to the officer and Mr. King's complaint was given little

credence; Mr. King was known to the officer and not liked, and his complaint, therefore,

afforded little credibility; and/or the officer understood that Mansfield University Human

Resources Department was investigating the complaint and improperly deferred to the

administration's investigation as a substitute for the Campus Police investigation. We are unable

to conclude, however, whether any one of these reasons or any combination of these reasons

actually explains the absence of Mr. King's complaint in the PA-LEMIS system and in the Police

Department's records.

2469415vl

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Documents

SPECIAL INVESTIGATION - Patrick D. Kingpatrickdking.com/wp-content/uploads/2014/11/Special-Investigative...SPECIAL INVESTIGATION: ... to question whether documents were inputted