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Bombshell lawsuit: Ex-Police Commissioner Tom Donlon claims Mayor Adams and NYPD leaders ran department as ‘criminal enterprise’
by Adam Daly
Posted on July 16, 2025
https://www.amny.com/police-fire/nypd-c ... nterprise/

-- REPORT OF THE SPECIAL COMMITTEE OF THE BOARD OF ALDERMEN APPOINTED TO INVESTIGATE THE "RING" FRAUDS, TOGETHER WITH THE TESTIMONY ELICITED DURING THE INVESTIGATION, by BOARD OF ALDERMEN, JANUARY 4, 1878

-- REPORT OF THE SPECIAL COMMITTEE APPOINTED TO INVESTIGATE THE POLICE DEPARTMENT OF THE CITY OF NEW YORK, 1895 (LEXOW COMMITTEE). INVESTIGATION OF THE POLICE DEPARTMENT OF THE CITY OF NEW YORK, BY STATE OF NEW YORK IN SENATE, JANUARY 18, 1895

-- REPORT OF THE SPECIAL COMMITTEE OF THE BOARD OF ALDERMEN OF THE CITY OF NEW YORK, APPOINTED AUGUST 5, 1912 TO INVESTIGATE THE POLICE DEPARTMENT, by BOARD OF ALDERMEN, SUBMITTED JUNE 10, 1913

-- The Knapp Commission Report on Police Corruption: Commission to Investigate Allegations of Police Corruption and the City's Anti-Corruption Procedures, by Whitman Knapp, Chairman, December 26, 1972

-- THE CITY OF NEW YORK -- COMMISSION REPORT: COMMISSION TO INVESTIGATE ALLEGATIONS OF POLICE CORRUPTION AND THE ANTI-CORRUPTION PROCEDURES OF THE POLICE DEPARTMENT, by Milton Mollen, Chair, July 7, 1994

-- Rudy: An Investigative Biography of Rudolph Giuliani, by Wayne Barrett, Assisted by Adam Fifield, © 2000 by Wayne Barrett

--The Brotherhoods: The True Story of Two Cops Who Murdered for the Mafia, by Guy Lawson & William Oldham ,© 2006 by Guy Lawson & William Oldham

https://drive.google.com/file/d/12ebrrGiIv9hhokl8_uLJsy5_PWIFRder/edit
Case 1:25-cv-05831 Document 1 Filed 07/16/25 Page 1 of 251
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
__________________________________________________X
THOMAS G. DONLON,
Plaintiff COMPLAINT
-against- Docket Number:
CITY OF NEW YORK, ERIC ADAMS, TANIA KINSELLA,
Individually, JEFFREY MADDREY, Individually, JOHN
CHELL, Individually, KAZ DAUGHTRY, Individually,
TARIK SHEPPARD, Individually, MICHAEL GERBER,
Individually, PAUL SARACENO, Individually, and
ANTHONY MARINO, Individually
Defendants
__________________________________________________X
Plaintiff THOMAS G. DONLON, by his attorneys, Law Office of John A. Scola

[x]
Tom Donlon sworn in as interim NYPD commissioner in September 2024, a role he now claims in a federal lawsuit was undermined by systemic corruption and political interference. Photo by Michael Appleton/Mayoral Photography Office

Former interim Police Commissioner Tom Donlon filed a bombshell, 251-page federal lawsuit Wednesday, accusing Mayor Eric Adams and senior NYPD leadership of using the department as a racketeering enterprise that allegedly engaged in corruption, obstruction of justice, and retaliation against whistleblowers.

In the July 16 lawsuit, Donlon, a former senior FBI executive appointed by Adams in September 2024, accuses the mayor and top NYPD officials of violating the Racketeer Influenced and Corrupt Organizations Act (RICO). He claims he was used as a public figurehead amid federal probes of City Hall while real control of the NYPD remained within Adams’ inner circle.

The lawsuit also names First Deputy Commissioner Tania Kinsella, former Chief of Department Jeffrey Maddrey, Chief of Department John Chell, former Deputy Commissioner and current First Deputy Mayor of Public Safety Kaz Daughtry, and Deputy Commissioners Tarik Sheppard and Michael Gerber.

According to the complaint, Donlon — who served in the interim post between September and November 2024 before giving way to current Police Commissioner Jessica Tisch — said he uncovered a coordinated scheme to promote politically connected officers without merit, obstruct internal oversight, and manipulate investigations into misconduct.

He alleges that NYPD leaders forged internal documents using his official police commissioner stamp to legitimize unauthorized promotions, resulting in millions of dollars in unearned salaries, overtime, pensions, and benefits.

A City Hall spokesperson said in a statement that Donlon’s suit is “nothing more than an attempt to seek compensation at the taxpayer’s expense,” saying he was “rightfully removed from the role of interim police commissioner. “

“These are baseless accusations from a disgruntled former employee who — when given the opportunity to lead the greatest police department in the world — proved himself to be ineffective,” the spokesperson said. “We will respond in court, where we are confident these absurd claims will be disproven.”

Donlon countered that the lawsuit is not a personal grievance but rather a “statement against a corrupt system that betrays the public, silences truth, and punishes integrity.”

“Serving as the NYPD police commissioner was never about power or position. It was for the good cops—the honest ones trying to do their jobs while corruption festered above them,” Donlon said in a statement. “The goal is to drive real change, hold the corrupt, deceitful, and abusively powerful accountable, and restore the voice of every honorable officer who has been silenced or denied justice.”

When asked about the lawsuit during a scheduled press call in the Bronx Wednesday morning, Mayor Adams said he struggled to make sense of its allegations and suggested the timing of the suit was politically motivated, calling it “the season” for such accusations.

“I have to keep running the city,” Adams said, brushing off the allegations as a personal grievance blown out of proportion, and insisted the matter would ultimately be decided in court.

“The lawyers will figure this out, but it’s just a baseless lawsuit of a disgruntled employee,” he said.

[x]
Mayor Eric Adams with interim Police Commissioner Thomas Donlon at a Sept. 18, 2024 announcement in Queens. Michael Appleton/Mayoral Photography Office

Donlon alleges that Sheppard, then the Deputy Commissioner for Public Information, forged his signature on official NYPD promotion memos, using the Police Commissioner’s stamp without consent.

Donlon said he confronted Sheppard after discovering Sheppard wearing insignia for a rank he never lawfully earned, calling it “a testament to his disregard for regulation and unequivocally stolen valor.”

Sheppard, who retired from the force in May after 21 years following a demotion, told amNewYork that he was already a deputy commissioner with a three-star insignia before Donlon arrived. He claimed his dual role as deputy commissioner and chief of staff was a unique situation during Donlon’s interim leadership, not a promotion he orchestrated.

“If Commissioner Donlon had a better understanding of the NYPD, he would know that’s not a promotion,” Sheppard said, adding that the claim that he used Donlon’s official stamp was false, “as there was no stamp issued in his name that I was aware of.” He also claimed that Donlon apologized to him over the incident at the time.

According to Donlon, however, after Sheppard allegedly denied any wrongdoing, he brought the matter to Maddrey, the Chief of Department at the time, and Mayor Adams.

He claims Maddrey and Adams acknowledged that Sheppard’s promotion was unauthorized but said neither took disciplinary action.

According to the lawsuit, Maddrey reportedly promised to address the issue and notify Internal Affairs, but did neither.

Despite Donlon’s repeated orders, he said Sheppard continued to wear the Bureau Chief insignia until November 2024, when Sheppard allegedly threatened to kill Donlon, after which Sheppard was finally demoted “from his stolen Bureau Chief rank.”

Sheppard called the allegation that he threatened Donlon “absolutely false.”

Donlon alleges that after the incident with Sheppard in particular, he was systematically excluded from decision-making, stripped of operational authority, and ultimately removed as police commissioner in retaliation.

The complaint also describes a personal retaliation campaign, including the arrest of Donlon’s wife, Deirdre O’Connor-Donlon, a retired New York State Supreme Court attorney, orchestrated by senior NYPD officials to intimidate Donlon after his whistleblowing.

She was handcuffed, searched, and told she would be sent to central booking, according to Donlon. Following her arrest, he claims personal information about the couple was leaked to the press by the NYPD.

“This coordinated humiliation was a direct warning: the NYPD Defendants would stop at nothing to silence and personally destroy Donlon, even if it meant violating the constitutional rights of his spouse,” the lawsuit states.

Sheppard dismissed claims that he orchestrated the arrest of Donlon’s wife, calling it “bizarre” and impossible to arrange.

He said the arrest stemmed from a routine traffic stop when her license came up as suspended and implied Donlon’s accusation confirmed concerns about his judgment.

Sheppard also denied leaking Donlon’s phone number to the press and suggested that Donlon’s accusations only emerged after he stopped working at City Hall, implying his motives are merely financial.

“None of these complaints existed when he was being paid by the city,” Sheppard said.

Sheppard repeatedly questioned Donlon’s mental health and cognitive abilities during a phone interview, claiming Donlon showed memory issues and lacked a basic understanding of police procedures during his time as Commissioner.

“He was showing signs of having some cognitive issues… that’s why the mayor asked him to step down,” he said.

In response, John Scola, attorney for Donlon, said it was not surprising that Sheppard would make false and defamatory claims about Donlon’s cognitive health in an effort to “deflect from the serious criminal conduct” outlined in the complaint.

“The idea that Donlon was cognitively impaired is contradicted by the fact that he was immediately reassigned as a senior advisor to Mayor Adams following his removal as Commissioner. If he was unfit to lead, why was he entrusted with advising the Mayor directly?” Scola told amNewYork.

He added that the accusations against Sheppard in the lawsuit are not political disputes but “potential felonies.”

“Sheppard will be fortunate if he isn’t criminally charged before this case even reaches trial,” Scola added.

[x]
Interim Police Commissioner Tom Donlon speaks about a shooting in Brooklyn on Sept. 15, 2024. Looking on are (background, l. to r.) Police Benevolent Association President Thomas Hendry, Mayor Eric Adams, then-Assistant Commissioner Kaz Daughtry and then-Chief of Department Jeffrey Maddrey. Photo by Dean Moses

Alleged ‘predicate acts’ committed

Donlon accuses the named officials of multiple federal crimes as predicate acts under RICO, including wire fraud, mail fraud, obstruction of justice, honest services fraud, and witness retaliation.

He claims these actions formed part of a deliberate and ongoing criminal conspiracy directed from both City Hall and NYPD headquarters.

The lawsuit also details a broader culture of corruption, alleging that Adams’s administration systematically protected NYPD executives with histories of misconduct, including allegations of violence, dishonesty, sexual harassment, and abuse of authority, while sidelining those who spoke out.

Promotions, overtime, and key assignments were allegedly distributed as political rewards or used to silence dissent.

Donlon also claims that, beyond professional retaliation, Adams and NYPD leadership undermined the integrity of law enforcement and public safety.

Donlon stepped in to serve as interim Police Commissioner in September 2024 following Edward Caban’s resignation amid a federal corruption investigation into the department that involved his brother.

Tisch took over the role from Donlon some two months later, becoming Mayor Adams’ fourth police commissioner during his first term.

The lawsuit claims that Donlon was relieved of his duties as Police Commissioner less than three weeks following his last reporting directly to Adams about “the criminal acts” of Sheppard and the failure of Maddrey, Chell, and Daughtry to take corrective action.

After his removal as interim commissioner in November 2024, Donlon says he was reassigned as a senior advisor on public safety before being abruptly terminated in May of this year.

The lawsuit alleges his firing was part of a broader pattern of retaliation and an effort to erase his influence from city government.

Donlon also alleges emotional and reputational harm, financial loss, and the destruction of his law enforcement career.

The lawsuit seeks damages and the appointment of a federal monitor to oversee NYPD disciplinary practices, whistleblower protections, and promotion processes.

John Scola argues that the alleged conduct represents a systemic abuse of power that continues to threaten institutional integrity and public trust in New York City.

“The NYPD has been hollowed out by Adams’s political machine. The chain of command collapsed under the weight of corruption, and the rank and file have been left demoralized, watching the worst rise while the best are pushed out,” said Scola. “This is what happens when loyalty to power matters more than service to the public.”

Donlon’s lawsuit follows the bombshell lawsuits filed last week by four former NYPD chiefs who claimed they were forced out of the department after raising concerns about misconduct, political favoritism, and violations of department policy tied to Mayor Eric Adams’ inner circle.

– With additional reporting from Sadie Brown

[admin]

https://drive.google.com/file/d/12ebrrG ... FRder/edit
Case 1:25-cv-05831 Document 1 Filed 07/16/25 Page 1 of 251

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

THOMAS G. DONLON,

Plaintiff

-against-

CITY OF NEW YORK, ERIC ADAMS, TANIA KINSELLA,
Individually, JEFFREY MADDREY, Individually, JOHN
CHELL, Individually, KAZ DAUGHTRY, Individually,
TARIK SHEPPARD, Individually, MICHAEL GERBER,
Individually, PAUL SARACENO, Individually, and
ANTHONY MARINO, Individually

Defendants.

Case 1:25-cv-05831

COMPLAINT

Plaintiff THOMAS G. DONLON, by his attorneys, Law Office of John A. Scola, PLLC,
complaining of the Defendants respectfully as follows:

PRELIMINARY STATEMENT

1. The New York City Police Department (“NYPD”), under the direction of Defendant
ADAMS, functions as a racketeering enterprise in violation of the Racketeer Influenced
and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1961 et seq. Senior leadership had
abandoned lawful governance, and engaged in outright malfeasance by using the NYPD to
consolidate political power, obstruct justice, and punish dissent.

2. A coordinated criminal conspiracy had taken root at the highest levels of City
government—carried out through wire fraud, mail fraud, honest services fraud, obstruction
of justice and retaliation against whistleblowers. This enterprise—the NYPD—was
criminal at its core. The Defendants engaged in a coordinated pattern of racketeering
activity that was deliberate, sustained, and directed from the highest levels of the NYPD
and City Hall. As detailed throughout this Complaint, the Defendants obstructed justice in
violation of 18 U.S.C. § 1503 by sabotaging internal oversight efforts—canceling Donlon’s
meetings, altering his schedule, spying on his communications, and systematically
excluding him from operational decisions.

3. They manipulated the Internal Affairs Bureau to prevent disciplinary referrals and block
investigations into executive misconduct. The Defendants used Donlon’s official Police
Commissioner stamp without authorization to forge internal documents that were then used
to promote unqualified, politically connected officers over those who had earned
advancement through merit. This corruption triggered a massive, unlawful transfer of
public wealth—millions of dollars in unearned salary increases, overtime eligibility,
pension enhancements, and post-retirement benefits. The Defendants committed wire and
mail fraud under §§ 1341 and 1343 by disseminating materially false information through
official City systems, including promotional lists and internal communications. They
engaged in honest services fraud under § 1346 by subverting the promotion process—
trading public trust for loyalty, silence, and political protection. And they retaliated against
whistleblower Thomas G. Donlon in violation of § 1513 by dismantling his authority,
orchestrating his removal, and targeting his wife with unlawful arrest and defamatory leaks.

4. These predicate acts were not isolated—they were coordinated and systemic, forming an
unlawful scheme to preserve power, punish dissent, and defraud the public. As part of the
relief sought, Plaintiff demands the appointment of an independent federal monitor with
full authority to oversee and report on NYPD disciplinary processes, whistleblower
protections, and promotion decisions, to ensure compliance with law and prevent further
abuse.

5. Defendant ADAMS publicly appointed Plaintiff Thomas G. Donlon—a distinguished
former Senior Executive in the Federal Bureau of Investigation (“FBI”)—as interim Police
Commissioner amid a wave of criminal investigations targeting his administration.

6. But the appointment was illusory. In reality, Donlon was Commissioner in name only. True
authority remained with Defendant ADAMS’s corrupt inner circle: Defendants First
Deputy Commissioner TANIA KINSELLA, Chief of Department JEFFREY MADDREY,
Chief of Patrol JOHN CHELL, Deputy Commissioner KAZ DAUGHTRY, Deputy
Commissioner of Public Information TARIK SHEPPARD, and Deputy Commissioner of
Legal Matters MICHAEL GERBER.

7. These individuals exercised unchecked power while Donlon was sidelined and used as a
public relations shield. The Defendants undermined Donlon’s authority by blocking his
merit-based promotions and instead elevating unvetted individuals of their choosing. The
Defendants then fraudulently used Donlon’s official Police Commissioner stamp—without
his consent—to legitimize and carry out their corrupt scheme.

8. Upon assuming his position, Donlon quickly uncovered systemic corruption and criminal
conduct being perpetrated by the NYPD’s executive leadership. He reported these findings
directly to Defendant ADAMS.

9. Specifically, Donlon informed Defendant ADAMS of fabricated promotions, systemic
fraud, retaliatory policing, and the obstruction of internal investigations by high-ranking
officials—most notably Defendant SHEPPARD, who had a documented history of
unlawful violence, including the tasering and false arrest of protestors, resulting in civil
rights lawsuits and monetary settlements. Defendant ADAMS took no action in response.
Instead, he condoned the misconduct and allowed the NYPD to function as a criminal
enterprise.

10. As a direct result of Defendant ADAMS’s failure and unwillingness to manage the NYPD,
Defendant SHEPPARD fraudulently orchestrated his own promotion—granting himself
greater authority and a higher salary.

11. Donlon confronted Defendant SHEPPARD directly, denouncing the act as “stolen valor,”
but the rebuke had no deterrent effect. When Donlon demanded accountability for the
NYPD Defendants’ collective misconduct, they turned against him. He was frozen out of
operational and administrative decisions, stripped of real authority, and ultimately removed
from his role as interim Police Commissioner in retaliation for his internal complaints to
Defendants ADAMS concerning the corruption, dereliction of duty, and criminal
misconduct he had witnessed.

12. From the outset, Donlon’s mission was clear: to protect and guide the honest rank-and-file
officers and supervisors who had been abandoned by a leadership class rotting from the
top.

13. He sought to restore integrity, raise morale, and defend those who risk their lives daily to
protect and serve. These officers had been betrayed by corrupt high-level executives and a
mayor more interested in political loyalty than public safety. Donlon tried to be that leader.
For this, he was unlawfully targeted.

14. The retaliation extended beyond professional consequences. In a calculated and deeply personal act of vengeance, Defendants DAUGHTRY, SHEPPARD, and GERBER
orchestrated the false arrest and unlawful detention of Donlon’s wife, Mrs. Deirdre
O’Connor-Donlon—a private citizen1 with no connection to his official duties—by NYPD
officers under their control. This was not a mistake. It was a deliberate abuse of power
designed to punish and intimidate Donlon for exposing their misconduct. Mrs. Donlon-
O’Connor was handcuffed behind her back, subjected to a full body and personal-effects
search at the 17th Precinct, and told by Officer Vargas that she would be transported to
Central Booking. This coordinated humiliation was a direct warning: the NYPD
Defendants would stop at nothing to silence and personally destroy Donlon, even if it meant
violating the constitutional rights of his spouse.

15. Donlon receives press calls within minutes of his wife’s release. Donlon received a call on
his personal cell phone from a New York Post reporter asking for comment—followed by
a call to Mrs. Donlon-O’Connor. The source of the leak was soon revealed: the Office of
the Deputy Commissioner for Public Information (DCPI), led by Defendant SHEPPARD,
had disseminated the Donlons’ personal phone numbers and intimate family details to the
press. By 11:06 PM, a vicious and factually incorrect article was published, complete with
home addresses, dates of birth, and other private information, syndicated across multiple
media outlets. This malicious media leak could only have come from inside the NYPD.
Despite the egregious abuse of authority and the widespread coverage it generated, neither
Defendant ADAMS nor Police Commissioner Tisch ever contacted Donlon or his wife to
explain or apologize. For Donlon and his wife—who have always held the NYPD in the
highest regard—this incident marked a devastating betrayal by a department they once
trusted.

1 It should be noted, Mrs. Deirdre O’Connor-Donlon is a retired New York State Supreme Court Attorney who dedicated 28 years of public service to NYS and its people.

16. Collectively, these acts unlawful arrest, unauthorized disclosure of private data, obstruction
of internal probes, and a leadership that rewards silence comprise a pattern of racketeering
under RICO. In collusion with Defendant ADAMS’s office and NYPD command,
promotions and favors were allegedly traded to suppress dissent and bury accountability.
It was known that this matter was discussed with the Mayor and his Administration and
also by the NYPD Police Commissioner, but no contact was made with Donlon or his wife.

17. The Defendants leveraged governmental authority and infrastructure to commit crimes,
cover up misconduct, and retaliate against internal dissenters. Their conduct meets the legal
definition of a RICO enterprise: an association-in-fact engaged in a pattern of racketeering
activity through public channels.

18. With New York City and NYPD under the control of Defendants ADAMS and
MADDREY respectively, promotions were traded for silence. Investigations were
obstructed. Dissent was punished. Accountability was buried.

19. As a direct and proximate result of these RICO violations by all the Defendants, Donlon
suffered extensive financial harm. He lost his income, pension eligibility, and career
prospects, both in the law enforcement/intelligence communities, along with private and
public sector positions. His professional reputation—built over decades of federal and state
law enforcement and intelligence service—was deliberately destroyed. The emotional toll
of the retaliation against his entire family was and is incalculable. These were precisely the
kinds of injuries RICO was designed to remedy, and this Complaint seeks redress for
Donlon, whose unwavering aspiration from the beginning was to protect and serve the
NYPD’s Finest.

TABLE OF CONTENTS

Preliminary Statement 1
Jurisdiction 15
Venue 15
Parties 15
1. BASIS FOR RACKETEERING INFLUENCE AND
CORRUPT ORGANIZATION ACT (“RICO”)
18 U.S.C. § 1961 et seq. CLAIMS 24
A. RACKETEERING SCHEME WITHIN THE NYPD
and CITY HALL 24
B. OVERVIEW OF RICO (18 U.S.C. § 1962(c)) CLAIMS 26
C. OVERVIEW OF RICO CONSPIRACY(18 U.S.C. § 1962(d)) 31
D. CIVIL RICO PREDICATE CHART 34
2. FACTUAL ALLEGATIONS PRE-DATING PLAINTIFF
THOMAS G. DONLON’S EMPLOYMENT AS POLICE
COMMISSIONER 35
A. A systemic Criminal Enterprise Within City Hall and the NYPD 35
B. A Culture of Impunity; The NYPD Fails to
Punish the Many Disciplinary Issues of the Individual 38
Defendants
C. Defendant Maddrey’s Admitted Dishonesty and the NYPD’s
Double Standard 42
D. Proven Sexual Misconduct Results in Rewards For NYPD Bad Actors 44
E. Defendant ADAMS Consolidates Power and Elevates Loyalists 46
a. City Hall’s Takeover of NYPD Leadership 46
b. A Shadow Chain of Command: Banks and Pearson
Control Promotions: 49
c. Defendant ADAMS Continues to Reward Bad
Actors in the NYPD 51
F. The Critical Response Team (CRT): A Rogue Unit Created to
Project Power Not Ensure Safety 54
a. Formation of CRT Outside of Lawful Oversight Channels 54
b. Patterns of Unconstitutional Policing and Excessive Force 56
c. Public Endorsement of Lawlessness by Defendant ADAMS 58
G. Retaliation, Suppression and First Amendment Violations 60
a. Retaliation Against Whistleblowers Within the NYPD: 60
b. Weaponization of Internal Affairs and Legal Processes 60
H. City Liability Under Monell and Federal Civil Rights Law 61
a. A Policy and Practice of Protecting Abusers and Punishing
Reformers 62
b. Tim Pearson Exerts Unlawful Influence Over NYPD
Operation and Promotions 65
c. CRT’s Unconstitutional Reign of Violence and Abuse
Spreads Across New York City 67
I. Mismanagement, Retaliation and Corruption Continue Unchecked,
Defendant ADAMS Takes No Action 69
J. Plaintiff’s Counsel Warns Defendants Of First Amendment
Retaliation, City Responds With Further Indifference 72
K. Captain Promoted Following Sexual Harassment and City
Payout, then Arrested For Violent Felony 75
L. Defendant ADAMS Rewards and Further Emboldens The Defendants 76
M. The Sexual Misconduct Within the Administration Becomes
Fully Known, Again No Disciplinary Action is Taken 78
N. The Defendants Attempt to Distract the Public From Defendant
ADAMS’s Escalating Legal Troubles 81
O. Defendant ADAMS Allows Defendants CHELL, DAUGHTRY
and SHEPPARD to Openly Defy the New York City Council and
Violate Ethics Rules 84
P. Defendant ADAMS Forces the Law Department to Break
Policy to Indemnify Co-Conspirator Tim Pearson, Forcing
the Resignation of the City’s Highest- Ranking Attorney 86
Q. As Repeated Lawsuits Continue to be Filed, NYPD Defendants are
Rewarded by Defendant ADAMS 88
3. FACTUAL ALLEGATIONS FOLLOWING PLAINTIFF
THOMAS G. DONLON EMPLOYMENT AS INTERIM
POLICE COMMISSIONER 92
A. The Scope of the Criminal Investigations and Potential Criminal
Activity Surrounding Defendant ADAMS’s Appointees Becomes
Known 92
B. Defendant ADAMS Uses Donlon’s Credibility to Legitimize
a Corrupt Administration, Then Targeted Him When He Refused to
Stay Silent 94
C. Donlon is Named Interim Police Commissioner Based on
His Concerns With the Position 97
D. Donlon’s Attempt To Discuss and Provide Guidance On NYPD
Social Media Guidelines and Procedures: 102
E. Donlon Immediately Undermined by Defendant ADAMS 106
F. Following a Police Officer Being Shot in the Line of
Duty, Commissioner Donlon Discovers Widespread Incompetency
in the Highest Ranks of the NYPD 113
G. Defendant SHEPPARD Interferes With the Police Commissioner’s
Security Detail 118
H. The Culture of Corruption: How Donlon Was Sabotaged by a
Corrupt Command Staff Enabled by Defendant ADAMS 122
I. Donlon Gains Knowledge of the Defendants First RICO
Predicate Felony and Tells Defendant ADAMS, Who Does Nothing 124
J. Defendant ADAMS is Indicted on Corruption Charges 128
K. The NYPD Roosevelt Avenue Task Force Is Created As a
Result of a Dream of Defendant DAUGHTRY 129
L. Defendant DAUGHTRY’S Arrogance and the Politicization of the
NYPD Drone Program 133
M. Contrary to Their Stated Goals of Reducing Crime along the Roosevelt
Avenue Corridor, the Defendants Refused Federal Assistance
Through Dereliction of Duty 136
N. The Incompetence of Operation Restore Roosevelt Avenue Results in
Failure 141
O. Defendant ADAMS Further Solidifies Donlon’s Lack of
Authority As the Defendants Maneuver for Control 142
P. Actual Police Work and Public Safety is a Secondary Concern
for the Defendants 144
Q. Defendant SHEPPARD Undercuts and Embarrasses Donlon 146
R. The Promotion Process Hijacked by Corruption and Collusion
Resulting In Several RICO Predicate Acts 147
S. Forgery, Fraud, and the Theft of Command Authority 149
T. Retaliation and Conspiracy to Silence a Whistleblower 150
U. Defendant ADAMS refuses to act, Further Undermines Donlon 151
V. A Toxic Environment Engineered by Defendant ADAMS 152
W. NYPD Leadership Acts to Shield Compromised Personnel and
Obstruct Federal Corruption 153
a. Defendant GERBER’S Pattern of Deception, Retaliation
and Hostility to Collaboration with Federal Agencies 153
b. Defendant MADDREY Uses Strategically Placed Spies,
like Defendant GERBER, in the NYPD Legal Bureau to
Prevent Donlon His Job as Police Commissioner. 157
c. Sergeant Venus Overrules the Police Commissioner Over his
Holiday Party 160
d. Defendant MADDREY Alters Donlon’s Schedule Without
Permission 163
e. IT Technician In Donlon’s Office Exposes Venus and
Defendant MADDREY 164
f. Former Chief of Staff, Raul Pintos, Also Uses Venus To
Gather Information on Donlon 166
g. Exposing Defendants MADDREY and SARACENO 166
X. Internal Espionage and Institutional Sabotage 168
a. Defendant SHEPPARD Spreads False Narrative to NYPD
Police Foundation to Undermine Donlon 168
b. Donlon’s Conversation with and Warnings from Chief Pintos 169
c. WPIX Interview Organized By Defendant SHEPPARD 170
d. Defendant SHEPPARD’S Devious Insubordination Of Donlon 172
Y. Donlon Complains Directly To Defendant ADAMS who Takes
No Action 173
Z. Donlon Discovers Glaring Problems in the NYPD Evidence
Warehouses: A Crisis of Neglect and Failed Leadership 174
AA. Madison Square Rally, NYC, for Presidential candidate
President Donald J. Trump 179
BB. Defendant SHEPPARD Publicly Makes Terroristic
Threats (Another Felony) at Donlon Which is Covered Up
By the Defendants 183
CC. Donlon Complains to Defendant ADAMS About
Defendant SHEPPARD’s Crime- But No Action is Taken 186
DD. Defendants KINSELLA and MADDREY Scold
Donlon For Reporting Crimes 188
EE. Donlon has his Transfers Rescinded- Suffering Further
Retaliation 190
FF. President Trump Wins the 2024 Presidential Election 193
GG. Overtime scandal in the office of Defendant MADDREY. 193
HH. Defendant MADDREY Unlawfully Manipulates the NYPD
Promotional List- Usurping the Authority of the Police
Commissioner. 195
II. The Betrayal of the Badge: Corruption at the Top of the NYPD 198
JJ. Donlon is Terminated As Police Commissioner, Replaced
by Tisch 205
KK. Donlon Is Relegated to City Hall Where He
Works in Public Safety, A Demotion 207
LL. Donlon’s Security is Further Harmed 208
MM. Donlon Repeatedly Attempts to Contact
Commissioner Tisch But Is Ignored 209
NN. Additional RICO-Predicate Criminal Acts Uncovered by
Defendants 213
OO. Defendant ADAMS asks Defendant MADDREY to
Submit His Retirement Papers Who Refuses 217
PP. DOI Determines Community Response Team Had No
Oversight 218
QQ. Donlon’s Wife, Deirdre O’Connor-Donlon is Falsely Arrested 219
RR. Defendant MADDREY’s Sexual Abuse and Overtime
Violations Exposed 230
SS. Department of Investigation Finds Social Media Abuse
Similar to Donlon’s Prior Determinations 233
TT. After the Incident the NYPD Destroys Evidence of the Summons
issued to Mrs. O’Connor-Donlon, and Retaliates Against Donlon 234
UU. Donlon Is Placed in an Administrative Position and
Set Up to Fail 235
VV. Final Retaliation of Donlon- Termination from Employment from
Defendant CITY 237
Causes of Action
Count I – Civil RICO (18 U.S.C. § 1962(c)) 241
Count II RICO CONSPIRACY (18 U.S.C. § 1962(d)) 243
Count III- First Amendment Retaliation (42 U.S.C. § 1983) 243
Count IV – Municipal Liability Under Monell (42 U.S.C. § 1983) 244
Count V- Substantive Due Process Claim (42 U.S.C. § 1983) 246
Count VI-Violation to Right to Freedom of Intimate Association
42 U.S.C. § 1983 247
Count VII – Whistleblower Retaliation Under Civil Service Law § 75-b 248
Prayer For Relief 250
JURISDICTION
20. This action is brought pursuant to 42 U.S.C. §§ 1983 and 1988, and the First Amendment
and Fourteenth Amendment to the United States Constitution.
21. This Court has supplemental jurisdiction over Plaintiff’s related claims arising under state
and local law pursuant to 28 U.S.C. § 1367(a).
22. Jurisdiction is founded upon 28 U.S.C. §§ 1331 and 1343.