1

COMMONWEALTH OF MASSACHUSETTS

SUFFOLK, ss. SUPERIOR COURT DEPARTMENT

OF THE TRIAL COURT

)
BOSTON POLICE COMMISSIONER ) E-FILED 5/14/2021
DENNIS WHITE, )
)
Plaintiff, )
)
v. ) Civil Action No.
)
CITY OF BOSTON AND )
ACTING MAYOR KIM JANEY, )
)
Defendants. )
)

COMPLAINT AND JURY DEMAND

1. Boston Police Commissioner Dennis White (“White”) brings this

Complaint against the City of Boston and Acting Mayor Kim Janey (“Janey”) who

unlawfully seek to remove him from his position as Boston Police Commissioner

(“Commissioner”) in violation of his rights under law. Chapter 322, Section 7, of the

Acts of 1962 (the “Removal Statute”) provides that the Mayor of Boston who seeks to

remove the Commissioner must provide him due notice and a hearing and may only

remove him for cause.1 Janey now seeks to remove Commissioner White, but has not

provided him the process that he is entitled to by statute, and she lacks cause to remove

him. For these reasons, Commissioner White seeks a declaratory judgment to protect his

procedural rights and to enjoin his removal as Commissioner.

2. Commissioner White was duly appointed Commissioner by Mayor Martin

Walsh on February 1, 2021. He was placed on administrative leave two days later due to

1
A copy of the Removal Statute is attached for the Court’s convenience.
publicity surrounding a twenty-year old (false) allegation of domestic violence in order

that the City could investigate the allegation. There was no basis for the investigation, as

detailed in the attached correspondence with the City dated February 25, 2021 (Exh. A),

March 2, 2021 (Exh. B), March 11, 2021 (Exh. C), March 12, 2021 (Exh. D), March 19,

2021 (Exh. E), April 6, 2021 (Exh. F),and April 9, 2021 (Exh. G).

3. The City hired an outside investigator to conduct the investigation. The

investigation was suspect in its purpose and in how it unfolded procedurally. On

February 24, it was cancelled, but then on March 1 it was resumed. See March 12 letter

(Exh D). No explanation was given. The investigation was biased. Clear evidence of

that bias emerged during the investigation. The final report, which was delivered to

Commissioner White only two hours ago, is also based on hearsay. Accordingly, the

result is utterly unreliable and inadmissible.

4. The delay in providing the investigator’s report was unlawful and further

evidence of a procedurally deficient process, which amounts to an ambush of

Commissioner White. The report was provided to the City on or about Thursday, April

29, 2021. The report constitutes a personnel record on which the City is now relying to

make its termination decision. See M.G.L. c. 149, sec. 52C. As a result, Commissioner

White had a right to receive a copy within 5 business days. Despite his immediate and

repeated written requests for a copy of the report, Janey and the City refused to provide it.

See emails to the City’s Corporate Counsel (May 1, May 2, May 3, May 4, May 7, May

10 and May 12, 2021 (Exh. H).

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 5. On May 14, 2021, at approximately 10:00 a.m., Janey called

Commissioner White to notify him that she planned on terminating him and would hold a

“hearing” that afternoon at 3:00 p.m.

6. Janey’s actions violate the Removal Statute. First, she has not provided

due and meaningful notice. Second, the Statute does not permit her to hold a hearing as

the presiding prosecutor, judge and jury. The Statute clearly contemplates and requires a

judicial hearing that would provide independence and fairness. A hearing where the

“judge” has made up her mind beforehand is no hearing.

7. Finally, there is no cause. Commissioner White did nothing during his

two days as active Commissioner to warrant his removal. The allegations by his ex-wife

from twenty years ago, which were resolved in court in 1999 and known to the City and

Boston Police Department throughout the following two decades as he was promoted

multiple times, including to Commissioner, do not constitute cause to remove White.

Count 1 - Declaratory Judgment

Commissioner White seeks a declaratory judgment that the City and Acting Mayor

Janey have not satisfied the requirements of the Removal Statute, Chapter 322, Section 7,

of the Acts of 1962, and that the City and Janey are not permitted to remove Commissioner

White without providing him due notice and a judicial hearing to determine if there is cause

to remove him.

Count 2 – Temporary and Permanent Injunction

Commissioner White seeks a temporary and permanent injunction to enjoin the

the City and Acting Mayor Janey from removing him as Commissioner of the Boston

Police Department unless and until the requirements of the Removal Statute are satisfied,

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namely, he must be provided due notice, and proper judicial hearing before the Superior

Court of Massachusetts, and removed only if and when cause is found after such a

hearing.

WHEREFORE, Commissioner White requests that this Court:

A. Find in his favor on Counts 1 and 2 of this Complaint;

B. Declare that the process to remove him and his removal is unlawful;

C. Enjoin the City from removing him unless and until the requirements of

the Removal Statute are satisfied, namely, he must be provided due notice, and proper

judicial hearing before the Superior Court of Massachusetts, and only if and when cause

is found.

DEMAND FOR JURY TRIAL

Dennis White hereby demands a trial by jury on all claims so triable.

Respectfully submitted,

BOSTON POLICE COMMISSION DENNIS

WHITE,

By his attorneys,

Nicholas B. Carter (BBO No. 561147)

Tara D. Dunn (BBO No. 699329)
TODD & WELD, LLP
One Federal Street, 27th Floor
Boston, MA 02110
Tel: (617) 720-2626
Email: [email protected]
[email protected]
Dated: May 14, 2021

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EXHIBIT 1
166 Acts, 1962. —Chaps, 320, 321, 322.
Chap. 320. An Act kelative to the term op office op the mod
erator OP THE TOWN OP FALMOUTH.

Be it enacted, etc., asfollows:

Section 6 of chapter 349 of the acts of 1935 is hereby amended by
striking out the firat sentence and inserting in place thereof the fol
lowing sentence; — A moderator shall be elected by ballot at each an
nual town meeting for a term of one year, and shall serve as moderator
of all town meetings, except as otherwise provided by law, until a suc
cessor is elected and qualified; provided,.however, that if at any town
meeting the town votes that the term of the modemtor shall be three
years, a moderator shall be elected at the next annual town meeting,
and at each third annual town meeting thereafter, for a term of three
years, such three year term to commence with the annual town meeting
next following such election. A'p'proved AprU 4,1968.

Chap. 321. An Act providino for the payment of overtime com

pensation OWED to a police OFFICER AT THE TIME OF
HIS DEATH OR RETIREMENT.

Be it enacted, etc., asfollows:

Section 1. Chapter 147 of the General Laws is hereby amended by
inserting,after section 17D, inserted by section 2 of chapter 246 of the
acts of 1961, the following.section: —
Section 17E. Whenever the employment of any police officer subject
to section one hundred and eleven H of chapter forty-one or sections
seventeen A, seventeen B, and seventeen C of this chapter is terminated
during a year by dismissal through no fault or delinquency on his part or
by resignation, retirement or death, without his having received the
compensation to which he is entitled under such sections, he, or in case
of his death, his estate, shall be paid the full amount of such compensa
tion, provided that no monetaiy or other allowance has already been
made therefor. The oifficial head of the department in which the police
officer was last employed shall enter on the departmental payroll all
amounts payable under this section.
Section 2. Section 111 I of chapter 41 of the General Laws, as
amended by section 3 of chapter 562 of the acts of 1954,is hereby further
amended by inserting after the letter "F", in line 6, the words: — or
section seventeen E of chapter one himdred and forty-seven.
Approved April 4,1968,

Chap. 322. An Act providing for the appointment by the mayor

OP THE CITY OF BOSTON OF THE POLICE COMMISSIONER FOR
SAID CITY.

Be it enacted, etc., asfollows:

Section 1. Chapter 291 of the acts of 1906 is hereby amended by
striking out sections 7, 8, 9, 10, 11, 12, 13 and 14, as amended, and in
serting in place thereof the following sections: —
Section 7. There shall be iii the city of Boston a department, known
as the police department, which shall be under the charge of an officer.
 Acts, 1962. — Chap. 322. 157
known as the poJice commissioner, appointed by the mayor for a term
of five yeans .commencing on May first of the year in which he is ap
pointed, except that any vacancy in. said office shall be filled for the
balance of the unexpired term. Such officer shall at the time of his ap
pointment have had at least ten years' experience as a member of a
federal, state or local police force or law enforcement agency. Notwith
standing the provisions of section fourteen of chapter four hundred and
cigMy-isix of the acts of nineteen hundred and nine such o£6cer may,
after notice and hearing, be removed by the mayor of said city for cause.
Such officer shall not engage in any other business, and shall receive an
annual salary of fifteen thousand dollars or such oilier sum as may from
time to time be fixed by the city council with the approval of the mayor.
Section 8. In case of the absence or disability of the police commis
sioner or of vacancy in his office without a temporary police commis
sioner having been appointed under section sixty-one A of chapter
forty-one of the General Laws, the superintendent of police hereinafter
provided for or, in case of his absence or disability or vacancy in his
office, the next ranking officer of the police force or, where there are two
such officers of equal rank, the senior officer in date of appointment,
shall be acting police commissioner. An acting police commissioner
shall receive no extra compensation for his services as such.
Section 9, The police commissioner shall appoint a secretary, who
shall be exempt from the civil service laws and rules, shall be sworn to
the faithful performance of his duties, shall ser\'e at the pleasure of the
police commissioner, and shall keep such record.", issue such notices and
attest such papers and orders as the poJice commissioner shall direct.
Such secretary shall receive such annual salary as shall be fixed by the
police commissioner with the approval of the mayor.
Section 10. The police commissioner shall have authority to appoint,
establish and organize the police of said city, and shall appoint from said
police, and as a part thereof, a superintendent of police, who shall receive
such annual salary as shall from time to time be fixed by the police com
missioner with the approval of the mayor.
The police commissioner shall appoint from said police and as a part
thereof such number of deputy superintendents, captains and other
officers as he may from time to time deem proper. The police commis
sioner with the approval of the mayor shall establish, and may from
time to time revise, a compensation plan for the deputy superintendents,
captains and other officers and members of said police, who shall be
compensated in accordance therewith; provided,• however, that a
deputy :^perintendent shall not receive as an annual salary less than
ninety-eight hundred and forty dollars, nor a captain less than eight
thousand dollars, nor a lieutenant less than sixty-nine hundred and
sixty dollars, nor a sergeant less than sixty-two hundred and eighty
dollars, nor a patrolman after the second year of service less than fifty-
five hundred dollars or in the .second year of service less than five thou
sand and thirty dollars or in the first year of service less than forty-
eight hundred and eighty dollars; and provided, further, that lieutenant
detectives shall receive an annual salary three hundred dollars in excess
of the annual salary of lieutenants, and sergeant detectives shall re
ceive an annual salary three hundred dollars in excess of the annual
salary of sergeants, and first gmde detectives, second grade detectives
and third grade detectives shall receive an annual salary five hundred
168 Acjts, 1962. —Chap. 322.
dollars, four hundred dollars and three hundred dollars, respect!velyj
in excess of the maximum annual salary of patrolmen.
No person shall be appointed to said police unless at the time of his
appointment he is, and for at least two years immediately prior thereto
has been, a resident of said city, except that this requirement shall not
apply to any appointment of a police commissioner. Women shall be
eligible for appointment to said police in the discretion of the police
commissioner; and a separate list of women shall be established by the
division of civil service.'
The civil service laws and rules shall not apply to the appointment
of the superintendent of police or any deputy superintendent; nor shall
said laws and rules apply to the removal of a superintendent of police
or of a deputy superintendent if, upon such removal, he is transferred
back to the rank held by him immediately prior to Hs appointment as
superintendent of police or deputy superintendent.
Section 11. The police commissioner shall have cognizance and con
trol of the government, administration, disposition and discipline of the
department, and of the police force of the department and shall make all
needful rules and regulations for the efficiency of said police; provided,
however, that no such rule or regulation shall forbid any officer or mem
ber of said police from organizing or belonging to any organization com
posed solely of officers or members, or both, of said police and not affili
ated with any outside organization other than the Massachusetts Police
Association, and having among its objects the improvement of their
conditions of employment, including leaves of absence, hours of labor
and compensation. Officers and members of said police shall, whether
on or off duty, be subject to the rules and regulations made under this
section.
Any officer or member of said police shall have the right to petition
the general court or the dty council of said city and to appear before
any committee thereof; provided, that this paragraph shall not authorize
any officer or member to absent himself from duty without permission.
SecUon 12. The police commissioner shall from time to time appoint
a trial board, consisting of three captains, to hear the evidence in such
complaints against officers or members ofsaid police as said commissioner
may deem it advisable to refer to said board. Said board shall report its
findings to said commissioner, who may review the same and take such
action thereon as he may deem advisable.
Section IS. The police commissioner shall also have the powers and
perform the duties from time to time conferred or imposed on him by
statute. All licenses issued by said commissioner shall be signed by
him and recorded in his office; and he may,in his discretion, at any time
without a hearing and for any cause deemed satisfactory to him,suspend
for such period as he may deem proper any license issued by him.
. Section 14. The superintendent of police and the other officers and
members of said police shall have the powers and perform the duties from
time to time conferred or imposed upon the chief and other police officers
of cities by section ninety-eight of chapter forty-one of the General
Laws, except that they shall when on duty carry such weapons as the
police commissioner shall determine. The superintendent of police and
the other officers and members of said police shall also have the powers
and perform the duties from time to time conferred or imposed on police
 Acts^ 1962. — Chap. 323. 159
or police oflScers in this commonwealth by general laws applicable to
Boston.
Section 2. All the powers and duties conferred or imposed upon the
police commissioner of the city of Boston by statutoiy provisions in force
immediately prior to the taking effect of this act, except the provisions,
so in force, of sections seven to fourteen, inclusive, of chapter two hun
dred and ninety-one of the acts of nineteen hundred and six, are hereby
conferred and imposed upon Uie police commi^oner provided for by
this act. All officers and members of the police of said city in office on
the effective date of this act and all persons holding, on said date, by
appointment of said police commissioner employment subject to the
civil service laws and rules shall continue to hold their several offices or
employment until their resignation, retirement or removal in accordance
with law; and the rules and regulations of.the police commissioner ofsaid
city in force immediately prior to the taking effect of this act shall con
tinue in force until otherwise ordered by the police commissioner pro
vided for by this act.'
Sectio-v 2A. The office of police commissioner of the city of Boston
as an office filled by appointment of the governor with the advice and
consent of the council, as provided by section seven of chapter two liun-
dred and ninety-one of the acts of nineteen hundred and six, as amended
by section one of chapter three hundred and seventy-seven of the acts of
nineteen hundred and thirty eight, and as in effect immediately prior
to tiie effective date of this act, shall be abolished, and the term of office
of any incumbent thereof shall terminate upon the qualification of the
police commissioner initially appointed by the mayor under the pro
visions of section seven of chapter two hundred and ninety-one of the
acts of nineteen hundred and six, as amended by section one of this act;
and upon such qualification siich incumbent, or, if there be no incum
bent, the acting police commissioner, shall forthwith deliver all books,
records and papers in his custody to the police commissioner so ap
pointed.
Section 3. This act shall take effect upon its passage.
Approved AprU S, 196&,

Chap. 323. An Act relative to the issuance op bonds or notes

BY THE CITY OF CHICOPEE FOR THE PURPOSE OF AIDING
IN THE CONSTRUCTION AND WORK FOR THE IMPROVEMENT
OP CERTAIN STREAMS.

Be it enacted, etc., asfollows:

Section 1. The first sentence of section 1 of chapter 636 of the acts
of 1960 is hereby amended by striking out, in line 9, the words "one
year" and inserting in place thereof the woras: — five years.
Section 2. The authorization of the issuance of bonds or notes by
the city of Chicopee under chapter six hundred and thirty-six of the
acts of nineteen hundred and sixty prior to the passage of this act shall
be treated as having been made under said chapter six hundred and
thirty-six, as amended by section one of th'is act. The note for two
hundred fifty thousand dollaj-s issued by the city of Chicopee on Septem
ber fifth, nineteen hundred and sixty under said chapter six hundred and
EXHIBIT
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Todd&Weld LLP
w Nicholas B. Carter
E-mail: [email protected]

February 25, 2021

VIA FIRST CLASS MAIL AND EMAIL

Eugene O'Flaherty
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201

Dear Mr. O'Flaherty:

I write on behalf of Commissioner Dennis White, who has retained me and my law firm,
Todd & Weld LLP. Commissioner White demands immediate reactivation as Commissioner of
the Boston Police Department (BPD). He has been treated poorly and in a troublingly disparate
manner when compared to his predecessors who were promoted to Commissioner based on their
proven excellence, competence, professionalism and personal integrity.
The process has been grossly improper and unfair. The City deactivated him as
Commissioner based on nothing other than a decades old, unsubstantiated allegation of domestic
violence made by his then estranged wife, Sybil White, in the context of their divorce.
Commissioner White vehemently denied the charge then, as he continues to do today. Their
oldest daughter, Tiffany White, who was a teenager at the time and the best witness to their
family dynamic, has stated publicly that the allegation is untrue, and that Commissioner White
never used or threatened violence in the home. On the contrary, she says her mother, who is a
powerful person (and a Boston police officer) was the aggressor in her parents' relationship.
Further, Commissioner White has never otherwise been accused of domestic violence or
violence or other inappropriate conduct toward women of any kind.
As the City should know, false allegations are common in divorce proceedings to spite
the partner or to extract a financial advantage. That is what happened here. Ms. White made the
allegation and obtained a civil restraining order against Commissioner White after he told her he
was filing for a divorce. She then was able to force him to be separated from his children and to
leave his house — they were keeping separate homes in the same multi-family house at the time.
But she reversed course and withdrew the restraining order early for financial gain so that
Commissioner White could work overtime to provide her additional support. Ms. White's
already questionable allegation should have lost any weight whatsoever given her ready
willingness to abandon the restraining order for financial gain.
There is no basis not to reactivate Commissioner White immediately. Yet, the City now
has launched a full-blown investigation into him without basis. No other Commissioner has
been treated this way. There is no ground to treat Commissioner White this way. The City has
been aware of Ms. White's allegation since it was made in 1999. During the last 22 years,
Commissioner White has been promoted 5 times, joining the Command Staff in 2014 and

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
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Todd&WeldLIP February 25, 2021
VV Page 2 of 2

ultimately being elevated to Superintendent Chief of Staff in 2018 — the third highest ranking
officer at the BPD. Each of these Command Staff promotions were during Mayor's Walsh's
tenure and with his approval. Commissioner White has served with excellence and without
incident.
If the City does not immediately reinstate Commissioner White, the City will further
demonstrate its willingness to destroy the reputation of an honorable, decent and highly
accomplished public servant. A senior white male officer of Commissioner White's standing
and service would never be treated with such a complete lack of respect. This improper
treatment has not been lost on other Black leaders in the City. The National Organization of
Black Law Enforcement Executives (NOBLE), including Suffolk County District Attorney
Rachel Rollins, Suffolk County Sheriff Steven Tompkins, and former BPD Commissioner
William Gross, have called for Commissioner White's immediate reinstatement. NAACP
Executive Director Tanisha Sullivan, who serves with Commissioner White on Boston's Police
Reform Task Force, has praised his voice in calling for reform at the BPD and has also called for
his reinstatement.
Please let us know if the City will immediately reinstate Commissioner White, without
further delay.
Very truly yours,

Nicholas B. Carter
NBC/adc

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
EXHIBIT
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Todd &Weld LLP
w Nicholas B. Carter
E-mail: [email protected]

March 2, 2021

VIA FIRST CLASS MAIL AND EMAIL

Eugene O'Flaherty
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201
eutl,ene.ollaherty(Ooston.gov

Dear Mr. O'Flaherty:

Based on my communications with the City, it was my clear understanding that Mayor
Walsh intended to reinstate Commissioner White as Commissioner of the Boston Police
Department. Consistent with that promise, the independent investigation was cancelled. I
received notice of that cancellation from the investigator. Her email is attached.
However, I learned yesterday that the City has decided to recommence the independent
investigation. I received an email yesterday from the investigator, which is also attached. I
spoke to the investigator and she informed me that she is looking for every bit of information on
Commissioner White that she can obtain, and she expects the investigation will take at least until
the end of March and perhaps longer. As she said, "I will not be rushed by anyone."
At this point, Commissioner White can only reasonably conclude that this full-blown
investigation is merely a delay tactic with an ulterior purpose: Commissioner White's discharge.
Mayor Walsh is on the verge of confirmation. He then will be required to resign as Mayor of
Boston so that he can fulfill his duties as Secretary of Labor. There is simply no way the
investigation will be complete before Mayor Walsh departs for his new post.
Commissioner White will not agree to an investigation that is not being undertaken in
good faith. Further, none of Commissioner White's predecessors who were promoted to
Commissioner from the ranks of the Boston Police Department were subjected to any additional
investigation and were judged based on their record at the BPD. Commissioner White demands
similar treatment. He has demonstrated the highest level of competence, professionalism and
integrity as a police officer and supervisor at the BPD for over three decades.
There is nothing more to know that that the City does not already know about his ability
to lead the Boston Police Department. The City has been aware of Ms. White's allegation since
it was made in 1999. During the last 22 years, Commissioner White has been promoted 5 times,
joining the Command Staff in 2014 and ultimately being elevated to Superintendent Chief of
Staff in 2018 — the third highest ranking officer at the BPD. Each of these Command Staff
promotions were during Mayor's Walsh's tenure and with his approval. Commissioner White
has served with excellence and without incident.

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
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Todd &Weld LIP March 2, 2021
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The City has inflicted tremendous harm on Commissioner White. It is now time to end
that mistreatment and to reinstate him. I look forward to hearing from you today.

Very truly yours,

Nicholas B. Carter
NBC/adc

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
EXHIBIT
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T
Todd&Weld LLP
w Nicholas B. Carter
E-mail: [email protected]

March 11, 2021

VIA FIRST CLASS MAIL AND EMAIL

Eugene O'Flaherty
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201
[email protected]

Dear Mr. O'Flaherty:

Following up on my letter to you and the City on March 2, 2021, I have been informed
that the City inquired in the last week if the City could terminate Commissioner White due to an
alleged residency requirement when he was BPD Chief of Staff. The City retreated from that
effort as soon as the City was informed it would have to terminate Greg Long based on the same
rationale. It is also my understanding that both Greg Long and Commissioner White were
grandfathered into the Command Staff before that residency requirement took effect, therefore it
does not apply.
This information underscores that the City's alleged investigation of Commissioner
White is not being undertaken in good faith. If the process were in fact fair and without a pre-
determined goal in mind, the City would not be inquiring simultaneously about terminating him.
It also is troubling that the City would be prepared to terminate Dennis White, a Black man, until
it learns that Greg Long, a White man, would also have to be terminated. Please let me know
who initiated this inquiry, who had any involvement and who was aware of it.
The best way forward is for Mayor Walsh to reinstate Commissioner White immediately.
His leadership at the BPD has been exemplary. His record is and has been known for decades, to
the City and BPD. Because of his strong record, he was elevated to Chief of Staff of the BPD
and more recently chosen to serve with a handful of other community leaders to review the BPD
and make recommendations for reform as part of the Boston Police Reform Task Force. He has
the support of the community, as well as key law enforcement partners including outgoing
Commissioner William Gross, Suffolk County D.A. Rachel Rollins and Suffolk County Sheriff
Steve Tompkins, all of whom have called for his immediate reinstatement.
The ongoing, unfair process is causing significant harm to Commissioner White, who is
and has been a dedicated public servant.
I look forward to the City's prompt response. Thank you.

Todd & Weld LLP • Attorneys at Law • One Federal Street. Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
 Todd&Weld March 11, 2021
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Very truly yours,

Nicholas B. Carter
NBC/adc

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
EXHIBIT
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Todd&Weld LLP Nicholas B. Carter
E-mail: [email protected]

March 12, 2021

VIA FIRST CLASS MAIL AND EMAIL

Henry Luthin
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201
[email protected]

Dear Mr. Luthin:

As discussed in our call yesterday, I have requested Commissioner White's contract with
the City and all documents reflecting the agreement regarding the terms of his appointment as
Commissioner. I also have requested by e-mail to you earlier today that the City provide a copy
of Commissioner White's IA file and personnel file, and any complaint or police report
concerning Sybil White allegation concerning Commissioner White.
You mentioned yesterday that it was your understanding that Commissioner White is not
cooperating with the independent investigation. Without rehashing in full what I have already
communicated to the City, there are a few points that need to be made so the City understands
Commissioner White's position regarding the investigation.
First, there is no basis for an investigation to determine if he is qualified to serve as
Commissioner. Mayor Walsh already determined that he was qualified and the right person for
the position, and therefore appointed him based on his entire record. That record includes his
many years of exemplary service as a senior member of the Command Staff and an officer at the
BPD. It also includes the decades-old allegation of Sybil White which was fully vetted when it
was made and has been known to the BPD and the City ever since. After a full investigation by
the BPD, her allegations were not sustained. She did not file a criminal complaint, because no
crime was committed. She and Commissioner White have continuously served on the same
Boston police force for over two decades professionally and without incident since their divorce;
they have met courteously at social gatherings. Notably, she did not surface this old story, nor
seek to block Commissioner White's appointment.
Second, the investigation is being conducted in bad faith. During the investigation, the
City considered trying to terminate Commissioner White based on a groundless theory that he
had not satisfied an alleged residency requirement when he served on the Command Staff. He
has never been in violation of any residency requirement. The so-called investigation must be
considered in that context. It appears to be a means to a pre-determined goal of finding a way to
terminate him. That is not a trustworthy process.
Third, your predecessor, Eugene O'Flaherty, told me there was no need for a further
investigation. The City knew all it needed to know about Commissioner White based on his

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston. MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
 Todd&Weld LLP March 12, 2021
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thirty-eight years with the BPD. Accordingly, the independent investigation was terminated on
February 24, 2021. I have attached the email from the independent investigator informing me of
that fact. Without explanation, she informed me that the City had resumed the independent
investigation a week later. I have attached that email. The City has not explained the reason for
resuming the investigation or what the scope or purpose of the resumed investigation is. Given
that the investigator told me when I first spoke with her on February 22nd that the investigation
was unlimited in scope, she would decide what information she put in the report and the report
would be made public, you can understand why Commissioner White would have legitimate
privacy concerns.
Fourth, the City's investigation has already caused substantial harm to Commissioner
White and his family. Commissioner White and Sybil White went through a difficult and painful
divorce more than twenty years ago. Sybil White's allegations were made during that divorce.
The City's decision to put Commissioner White on leave while her allegations are (again)
investigated has already re-opened old wounds and threatens to tear apart Commissioner White's
family again, many years later. Anyone reading the newspaper is now witness to old, personal
wounds being re-opened and new wounds within the family being created. The City's
investigation into this stale matter is disrespectful to his family and unnecessary. It certainly
raises troubling concerns about disparate treatment.
Fifth, no other person appointed to the position of Commissioner from within the ranks of
the BPD has had to undergo any investigation beyond a review of their record as an officer at the
BPD. Commissioner White was appointed consistent with that precedent. There is no precedent
for subjecting a Commissioner to an investigation after he has been appointed.
Sixth, the investigation into Commissioner White is not only limitless in scope, there is
no deadline for its completion. The investigator has stated she will not complete the
investigation until at least the end of March 2021, and it may take longer. According to her, she
"will not be rushed." It should have been completed already, within days given that his entire
relevant record is his thirty-two years with the BPD. The length of this investigation appears to
be designed as a delay tactic so that the City can avoid making a decision before Mayor Walsh's
confirmation as Secretary of Labor and his departure as Mayor.
Commissioner White would have participated in a fair and appropriate investigation.
However, the current investigation is anything but fair and appropriate. It has already caused
Commissioner White and his family significant harm, and it threatens to cause them more
unnecessary harm.

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
 Todd&Weld LLP March 12, 2021
Page 3 of 3

I am available to discuss if you or the City has any questions or concerns.

Very truly yours,

Nicholas B. Carter
NBC/adc

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
ATTACHMENT
From: Tamsin Kaplan <[email protected]>
Sent: Monday, March 1, 2021 4:53 PM
To: Carter, Nick <[email protected]>
Subject: Re: Independent investigation

Good afternoon Nick.

I have been informed this afternoon that the investigation is to resume and continue effective immediately. Do you have
the completed disclosure and authorization forms from Commissioner White for me? Please let me know when I can
expect to receive those.

Thank you.

Tamsin R. Kaplan
Sent from my iPhone

> On Feb 24, 2021, at 5:05 PM, Tamsin Kaplan <[email protected]> wrote:

> Hello Nick,

> Please be aware that the independent investigation was terminated at 5 PM today at the direction of the City of
Boston's Corporation counsel. As the investigation is in a preliminary phase, I'm unable to make any findings at this time.
In view of the high level of public trust that is essential to the position of police commissioner, I have recommended that
the independent investigation be resumed and allowed to progress to completion.

> Tamsin

> Tamsin R. Kaplan

> Sent from my iPhone

TAMSIN KAPLAN
Attorney at Law
Davis Malm
One Boston Place, 37th Floor I Boston, MA 02108
P: 617.589.3892 I F: 617.523.6215
[email protected] I www.davisrnal "cam

DAVIS MAIM
ATTC)RNEVS
Ce e4141. 14G 40 ,, kAF“,

1
Disclaimer
This e-mail may contain confidential or privileged material and is for use solely by the above referenced recipient. Any
review, copying, printing, disclosure, distribution, or other use by any other person or entity is strictly prohibited. If you are
not the named recipient, or believe you have received this e-mail in error, please immediately notify Davis, MaIm &
D'Agostine, P.C. at (617) 367-2500 and delete the copy you received. Thank you.

2
EXHIBIT
E
 T
Todd&Weld LLP
w Nicholas B. Carter
E-mail: ncartergtoddweld.com

March 19, 2021

VIA FIRST CLASS MAIL AND EMAIL

Henry Luthin
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201
hen ry .1 uth in(Ciboston.gov

Dear Mr. Luthin:

I have received important information from Sergeant Detective Mary-Ann Riva (Ret.),
who was assigned to investigate Sybil White's allegation of abuse against Commissioner White
more than twenty years ago. The results of her investigation are contained in her affidavit, which
is attached. This information should put an end to any question about Commissioner White's
qualification to serve as Commissioner of the Boston Police Department.
What the affidavit and accompanying records show demonstrates beyond a shadow of
doubt that Commissioner White did not abuse or threaten to abuse Sybil White. By Ms. White's
own admission, there was "no physical abuse" by Commissioner White.
The one allegation raised by Sybil White concerned a statement that Commissioner
White allegedly made to a friend of the parties, Linda Figueroa. According to Linda Figueroa,
Commissioner White expressed his feeling of being angry and hurt by Sybil White, when she
refused to speak with him and drove off with another man. Clearly, Ms. Figueroa did not view
the comment as a real threat to the safety of Ms. White, because Ms. Figueroa did not even relay
the comment to Ms. White for more than three months.
Ms. White also did not view the comment as a real threat, because she did not act on the
comment immediately. In fact, she did not act on the statement until three weeks later, when
Commissioner White called her to tell her to hire a divorce attorney. Immediately after she
received that call, she exploded in anger at him and left an expletive laced message for him at his
police station, which the receiving officer called "abusive." After that call, Ms. White
immediately reported the statement that Commissioner White had made to Linda Figueroa four
months earlier and obtained a restraining order the next day. Notably, she mischaracterized the
statement both to the police and to the court. As evidenced by Linda Figueroa and Sgt. Det.
Riva, Commissioner White never said he was "going to shoot" Ms. White as Ms. White falsely
reported to the police and the court. In fact, he never expressed any intent to harm her, then or
ever. There is no evidence to the contrary.
The alleged abuse of Ms. White is what purportedly caused the City to put Commissioner
White on paid leave, even though her allegations were not new and had already been fully vetted
by the City. With this affidavit and the accompanying records, it is clear Commissioner White

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 021 I0 • I': 617.720.2626 • F: 617.227.5777 • www.toddweld.com
 Todd&Weld LLP March 19, 2021
Page 2 of 2

never abused Sybil White or even actually threatened her. The City should reinstate
Commissioner White immediately.
I am available to discuss if you or the City has any questions.

Very truly yours,

KJ J ---
Nicholas B. Carter
NBC/adc
(enclosure)

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
 Affidavit of Mary-Ann Riva

Mary-Ann Riva, on oath, hereby states as follows:

1, I served as a Detective in the Domestic Violence Unit (DVU) for approximately 10 years
and as Sergeant Detective in the DVU for 4 years before retiring from the Boston Police
Department in 2016 after more than two decades as a detective.

2. As a detective, I specialized in domestic violence investigations. I handled more than

7,000 domestic violence cases.

3. Before the DVU, I handled domestic violence investigations at the district level.

4. On May 5, 1999, I was notified of a report of alleged domestic violence being made by
Sybil White against Dennis White. Both were Boston police officers. I did not know
Sybil White, and only knew Dennis White a little. I had never worked with either. I was
assigned to investigate,

5. I interviewed Sybil White and her friend Linda Figueroa at the Dorchester District Court.
Tiffany White, Sybil White's teenage daughter, was present. I recommended that Tiffany
White not be present for the interviews, but Sybil White insisted that she remain. I did
not think that was appropriate because we were discussing the parents' difficult
relationship and adult matters.

6. According to Linda Figueroa, Dennis White spoke to her on December 26, 1998 about a
prior incident with Sybil White and her friend "Steve." It was my understanding that
Steve was Sybil White's boyfriend at the time. On December 26, Dennis White told Ms.
Figueroa that Sybil White had refused to speak to him about a matter and drove away
instead with Steve. Dennis White told Ms. Figueroa: "You don't know how I felt. I
wanted to shoot her and him." Ms. Figueroa said that Dennis White sounded mad and
hurt when he said this.

7. In my experience as a domestic violence detective, Dennis White was expressing a

human feeling of anger, but not an intent to commit violence. Dennis White and Sybil
White were having significant relationship problems and had already separated, but they
lived in the same building.

8. According to Sybil White, Dennis White had told Tiffany White a couple of weeks earlier
that he sleeps with his service weapon under his pillow and that Tiffany should not come
upstairs and startle him when he's sleeping. Dennis White apparently lived in an upstairs
apartment, Sybil White lived in a downstairs apartment and the children moved between
the two apartments because the parents were separated.
9. I did not consider this statement to be a threat. He was telling his daughter not to surprise
him at night when he was sleeping. I was not concerned at the time that Dennis White
kept his service weapon with him at night, because that was a common practice at the
time for police officers based on my experience.

10. A copy of my report of these interviews is attached to this affidavit.

11. As part of my investigation, I obtained a police report concerning a call by Sybil White
the day before my interview with her. On May 4, at 5:30 pm, Sybil White called the
police station where Dennis White worked and stated in a "loud and abusive manner"
(according to the police officer on the call), "Would you put flicking Sergeant White back
on the flicking phone." When the officer asked who was calling, she said, "His fucking
wife." The officer wrote a report, which is attached.

12. As part of my investigation, I also reviewed Sybil White's report to the police that she
made on May 4 at 6:10pm, shortly after her call to the police station. According to the
report, Sybil White was "separated from husband for 4 years." She "lives on 1st Floor
and husband lives on 3rd Floor of jointly owned building." Sybil White also reported,
"they have had arguments in past but no physical abuse." A copy of this report is
attached.

13. As part of my investigation, I also reviewed Sybil White's affidavit dated May 5, 1999, in
connection with her application for a restraining order. In that affidavit, she reported that
her friend Linda told her 2-3 weeks previously that Dennis White said "he was going to
shoot me and another friend of mine because I left him standing on the sidewalk and went
out with my friend." This statement mischaracterized what Dennis White said to Linda
Figueroa, as Linda Figueroa reported it. Dennis White did not say he was "going to
shoot" Sybil White. People in anger might say they feel angry enough to kill someone,
but that is different from making a threat to actually kill someone. As I understood it,
Dennis White was describing his feelings, not an intent to act.

14. The Boston Police Department wanted me and other domestic violence investigators to
pay careful attention to domestic violence allegations against a police officer and to
assess whether that officer presented a risk of violence, should have his gun taken away,
or should be removed from the police force. Based on my investigation, including
communications with Sybil White, Tiffany White and Linda Figueroa, I did not believe
that Dennis White presented a threat of violence to Sybil White. I did not recommend
that he should have his gun taken away or that he should be removed from the police
force.

15. In my view, based on my experience as a domestic violence detective, Sybil White was
angry and upset about the divorce which Dennis White had initiated and her statements
 were made in that context. In my experience as a domestic violence detective, it is not
uncommon for incorrect statements to be made by one partner against another during a
divorce proceeding. That is not always the case, but it is sometimes the case. It was my
opinion that Sybil White's request for a restraining order was motivated out of her being
upset and angry, not because there was a real threat that Dennis White would commit
violence against her. Sybil White voluntarily vacated the restraining order against Dennis
White on June 23, 1999, more than ten months before it was scheduled to expire.

16. In my view, based on my experience and investigation, Dennis White did not make a
threat to commit violence on Sybil White, and did not present a threat of violence to her.

SIGNED UNDER THE PENALTIES OF PERJURY THIS 18TH DAY OF MARCH, 2021.

Mary-Ann Ri
 20.2014
Plaza. 8osion, MA O2 3
a• I M r 1 Schram:let

To: Captain Albert Goslin

From: Detective Mary-Ann Riva, ID # 7470
Subject: Interview of Sybil White
Sir:

at approximately
I respectfully report that on May 5, 1999
Figueroa at the
2:30 PM I interviewed Sybil White and Linda December
Dorchester Court House. Linda Figueroa stated that on
was operating
26,1998 sometime between 12:00 noon and 4:00 PM she observed t
her motor vehicle on Dudley St at Washington St when she
overand got ou
Dennis White flashing his highbeams at her. She pulled
with
of her m/v and after giving him a hug and kiss, had a conversation
and her
him. They talked about different things and then about Sybil
relationship with Linda and with Dennis. He then told Linda about an
incident that had occurred at Steve's house (a co-worker of Sybil's). He
talc! that he wanted to talk to Sybil and she wouldn't talk to him and
hen drove off and left him standing in the street. Dennis said to Linda
You don't know how I felt, I wanted to shoot her and him). He
rimer stated to Linda that Sybil is not going to realize how good she
ad it with Dennis and Linda. Linda then told Dennis about Steve
fling the house and cluestioning why she was answering the phone,
fling Dennis that it was disrespectful of Steve to ask those questions.
e said Dennis sounded mad and hurt when be spoke of shooting Sybil.
Sybil White stated that she has been having marital
s with Dennis for a long time. She further stated that there was
cident at her friend Steve's home and that she had a conversation
nis outside and at some point Sybil got into her motor vehicle
,• . lying Dennis standing on the sidewalk. She said that Linda
at this conversation that she had with Dennis sometime
d that the comment made by Dennis about shooting her
greatly. On today's date 5-5-99 Sybil got a restraining
Tlester court # 907r.o.0593 , expiring on 5-19-99. Sybil
eft the department was not taking her seriously.
present was Tiffany White daughter of Dennis and
ted that approximately 2 weeks ago her father
said
.Is e when you
come up cause I sleep with a gun
By states that her father sleeps upstairs
and
see him she is very quiet on the stairs.

• nvnissioner Pool F. Evon3

PIIIIIIIIIII IIIIIIIIIIIIIIMIIMMMIMMI

IVN" O2 1 2O 2O14
igle warnitieStle itili3 WI'
lbir father was a about the
ArdMiti toininfehebS, her but did not tell her
thougtft ih'e their father, after the
She not to startle until a few days
Brittany not tell her mother
sister
stated she did
gun. Tiffany
officer would follow
incident.
informesi Sybil that a Superior taking
I knew who would be
report and that as soon as I
through on this k now. I a lso a
dvised her to go to Probate court
this case Iproceedings
would let her there. She stated she has been in touch with Sgt.
and start matter.
Domestic Violence Unit about this
Gaine.s of the

Respectfully submitted,

Mary-Ann Riva

1.4

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/44 1: : t .7.2•P'4V-' . F.
 A t
t e 10A) Pa it el 0 TRIAL COURT Or MASSACHUSETT.
• ...-4 Ziell.4121(14).::' 'raft

Nks.sItOK nt i voir Denali White

35 Bullard Street 13.4.411111-- t— Pier IRV.
Dorobersier. NA.
Mat/maim Dletticl Court
MO Wes tilnaton Weal
N Mr (Tre -areirtie
- • rawer Neve Nedra airi°22.4"41114--- "3"22°
D0eChaator. MA. 02124
IX '' ca
i . tree(' Nem f
2081864 Itralwir
P.gR15_6—CAMINAL OFFENSk_Rne fitalltkiimialtemaRtintiaLka
A. THE COURT HAS ISSUED THE FOLLOWING ORDERS TO
THE DEFENDANT: rony dem erne eldeabodead op*/
54. Ma Order was mow *Pow I.:Nance notice because L3 nits unite
the Cowl oaterrnined that there is a subslantisl s cerressiwaieo by sentare lam re amts armedMoe ix
tharshocki or touneasto 'simper GI abuse.
I. YOU ARE ORDERED NOT TO ABUSE THE PLAINTIFF by hatmIng,
Plainolti.h rear of atiminnnt sonata phyrical boon. Of by wane form lloratorting or attetr, to harm Use PleeNT fgt by 011= 4)
.• ,
thteat or duress ;As 04 PID1110 4 et leeseueet r
t. YOU ARE ORDERED NOT TO CONTACT THE puknerirE, wept as geoNtled In et to rioeb.. Foca:Mans
on this section. *Met In person, by telephona. In riling es othsteiss, sabre end go slat al lesser_ ) mica
110114 IM
t threell 'i-IhI wee
IWIll area It UM P4,1011 seetra to attar. a to cutnset Notes n ot t....Iutt Probaaandg 11 P •WME"'" or p?
ourritt C *rho. autnonzed olIcer whet) requited by " SY t'T
Ltalut• or wits.
4. Ire 3. YOU ARC ORDERED TO IMMEDIATELY LEAVE Art0 STAY AWAY MOM
'4; THE PLAINTIFF'S RESIDENCE. " 44" at P4ralkii4e 418 twic ''
--V
ODD '''"—itallard-
i '2444ai?ok
lix -8,---11Dreatat02121 0e wileftron eke you may nave reason In know ma P1Lit,H1 nay reesea. The Cart
you Ill) la ulffer,00I
£•4° An/ eye ere thin madame II; th0 PltlinIRI. (b} flot to darn!** any beiC‘OrtOS al lb. Par= or ant 05‘e
=Word. (C) 1101 10 ehtil OR or cause to be thin on any utdolot or mu mu-vervain:. Maker!, and Oh not 4° InWig" ift carry way with 1°4
Plailillitt ft (iota to posses* 1,141 tertAIIHICA. except by appr °peaks Waal proceedings

SC/ II this Om ts chitsmead. Ins Court moo ORDERS you to ,mmedunkty way* am /amain away born into snore alumna?, tarkleSt or PPP,' wag.*
tamely throb/vet WWI he Plabears itrutIonon a lastsd
0 4. PLAINTIFFS ADDRESS IMPOUNDED. The Court ORDERS that ma address oh iho PlairttOs ratgiento ig to C''' 'n P°Vrrkke'
Mostar no Probase to that a is not efacioard to you. your attorney. or tear plAsSe. by 6/°Claa.MagitUW4) Cm
• . . .. ,
0 S. YOU ARE ORDERED TO STAY AWAY FROM THE PLAINTIFF'S WORKPLACE tocatod at __ ' ' ' • ....-• - • .' - -,-' , • ' " `I
, _ _,;14070,''. . - " I
S. CUSTODY OF TIE FOLLOWING CHILDREN IS AWARDED TO THE PLAINTIFP
WLdtc /13-6782 N
Brittany White O 12124186 A
8 E t417-44, -
I 7. YOU ARE ORDERED NOT TO CONTACT THE CHILDREN USTED ABOVE OR ANY CHILDS COWIN:0 P LISTED
eerier in person. oy *WIbO4W. in tenting or othenmse. eater cErectly 0, thrcuph 00me0n0 els*. anti to stay at 'rat y wen: 1114C. Urifir:CC
morn* written fOrtrue.5.011 IM tn the Court to do otronvis.o.
Y are also y away horn the loacetwep . day cam other. —
N f HI ILn, O ..., id Xl —hip____
A -tint.. . Or!
I. i 0a t
FA M ilitii ,JA. _141IS erVul . i
0
8 E weir
E
LISTED IN SECTION 8 IS PERMITTED ONLY AS FOLLOWS (may be adored by Probate matin
0 RAN:STATION WITH THE CaliLDREN
1.

ncrenyvited and in me presence of at tor vikrerno btu;

0 vlsitstron e only aborted
- lo tar pato for by

0 Trartwortatroo d edvldson to and troth des edaahon Is ha be done by r.

j q L3 You ma/ contact the PLVIIIRI tr, lefe5g10ne putt 10 arrange Mit yeettaatn
U A ORDERED TO PAY SUPPORT to
_. the PLontet and I.1 your cIatd or children toted above, oi Owl tete a
__, dearth lo ttin throuott the Probooron Office al
Tre, ; _ . bearvsne_
mase.sr.nusens Ctep.annurru w Sveu.../e n Dy .4uornin
$ I.(1 0/ YOU MAY PICK UP YOUR
PERSONAL BELONGINGS in the eornparly of poke at a time agreed by tho Monitor,
losses outlined as a rarect rowa al U.e d
1. • I t YOU ARE ORDERED TO COMPENSATE THE PLAINTIFF to
or botoit _ 199 delicily it, too Pl:rrrn€I1 I 1 UV0U911 Probithart Spice d Ud3 co,„It
iJ l73. THERE Sit TAIMAL IKE OF IMLIEEKATE DANGER OF ABUSE. YOU ARE ORDERED TO IMMEOLATEL
_
L.,— _POIKe Papannwit At gura~ artatturation. gun Beim:, ;. IMO FA) truck. You,
)four I card. d any ma numNruled anntochata4
a pertain. the Coen will ktaMM
S' You may *1, 171)0*A lo duttpa eirs Oran( by acing to UN Court and Mine
► Nicar Irs t entnecraatrty surrender We nem tested ebcteu. and alit comp* sadt sit uthH OnAws ITO
p you naiad A broom, nee, Ovosinsdl, nutvane b,nt. arranuretron tor your tob, you May Pall NO fteetinititrtU

I 111 YOU ARE ALSO ORDERED

&Wallet* most sr sdimaaa **OM.' ot isag 0.64. may It. nw s'ar—Zir,Tai7;r

, vrikkr
—Tria77.0'
meg gnbedsd fr.,14groi drewerwe ery too .441. rrr oneete......
a as Osikaw.ado Op* Mt MOW, stark deo
ter Only Wore ay samdtase wavy
 / PREVENTION ORDER
„44
(CA L. c. 200A) Page 2 012 9907R0_0593 (A„;1 TRIAL COURT OF MASSACHUSETTS'
IDO(.54-11:46

'sport* are on td. at the

• TANOING WARRANTS FOR THE DEFENDANTS ARREST:Peace Department.
! I& An imminent threat of bodily injury
(DOCKET •E) (PCF
exists to the petitioner Notice issued to Peke
Depertmenest by f ! telephone L2 other

LI B. NOTICE TO LAW ENFORCEMENT. •

An appropinto taw enforcement officer stroll
1 •
serve upon
Order (and Summons), and make return of service to thisthe Defendant in hand it copy el the Complake and a eallftl Copy Dl this
Court. If Ihrs box Is cher*ed I 1
moles et the Defendants arkkoss shown on Page 1 but only it tee officer is unable to del GOPtiCe may Instead be +wide by leaving duct
0 2. Defendant Information Form accompanies this Order i cope,* In hand to the Delandent
(I4Defendant has been served in heed by th 's designee: Nemo .. CatR_ticli
-":7-.1- 57,*--
DATE OF OIFIDEA fTIME of OAOEFTM it I AMP ATE OF onDEn A*XT NEARING OATS
05/05/99 11:45 O PM
esoFM 3 'TA in
The and sny it guent Orden es** on the sApinnion dues -
on lissome:I Heanno SIG JNAME OF Ju
Ow to cons.nuo for mocAF Onfore w5 en Ie
on dart's and In.) IrwAr.sloo
C. PRIOR COURT ORDER EXTENDED. (<1
Alter a hearing al rota the Defendant r appeared O did not appear, Ihe Court has ORDERED that the prior Omer
dal , 199 shad continue in effect unlit the norl oxpiraIlon data below 0 wiihout modification
iYwith Te follow; modrlica ionls1'

6
LI' °Sun p5,A.,A
PM 5
7
O Return of items ordered &wondered or suspended in A.12. on Page 1 presents a likelihood of bu
, Ekes no WOE of-OW;
5 +WOO
NEXT REilinikG DATE:
WARM
7 P44
6 5 zoo°
P
to the Plaintiff

CovrIroom
St
t 314
#

D. FURTHB.R SION.
Atter a hearing . which the Defendant O appeared CT:i did not appear. the Court has ORDERED that the prior Older
dated 199 shaft continue in effeCt unt,I the next expiration date below O without modlti
O with the following modificahon(5)*
Fs-

Return of items ordered surrendered or suspended in A.12. on Page 1 Pr d'.O Pla‘he3

DATE of ORDER TAW CF ORDER O Am rreittATicie DATE Of ORDER INEXI
r
P i.1 I at4 RM. 1 at c,, • M x r omen
-•.
SIGNATURE/NAME OF JUDGE

O E. PRIOR COURT ORDER MODIFIED.

L.1 appeared ri did
Defendant and after a hearing at which the Plaintiff
Upon motion oy the E.! Plaintiff O
not appear. the Coun has ORDERED that the prior Order dated
and the Defendant 7 appeared O did ,1C
shall be modified as indicated below.

Page 1 presents a mamma at abuse 10

U Return or items ordered surrendered or suspended in A.12. on
leXPIRATION DATE of ORDER RtXT HEATIPK; DATE
DATE OF ORDER ! ME Of °Merl L?
a14FM nt 1 Att
1r to
SIGrocruriotamE OF JUDGE

F. PRIOR COURT ORDER VACATED.

Thi5 Courts prof Order ff, vacated. Law ereorcernerit agencies
shall destroy all records of such Oro
y . VACATED AT PLAINTIFFS REQUe.ST. `I t&
DATE OF ORQER
SIGNA 1.1FIE,I4AME OF JUDGE
64 d
A truer .err
WITNESS 51 "CHIEF JU TiCE

FA 2A Pr*
EXHIBIT
F
T
Todd&Weld LLP
w Nicholas B. Carter
E-mail: [email protected]

April 6, 2021

VIA FIRST CLASS MAIL AND EMAIL

Henry Luthin
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201
henry.luthin(Aboston.gm

Dear Mr. Luthin:

I am following up on the meeting last week between Mayor Janey and Commissioner
White at which we discussed reinstatement and the investigation. What led to the investigation
and the City removing Commissioner White from active duty was the recent, renewed disclosure
of Sybil White's allegations in 1999 concerning her relationship with Commissioner White. I
say "renewed" because she made these allegations publicly in court in 1999 during their divorce.
After a full investigation at that time, Commissioner White was exonerated. Ms. White
did not seek a criminal complaint as there was no crime, and she voluntarily vacated a restraining
order shortly after she had it put in place, permitting Commissioner White to return to living in
their home. Ms. White did not allege physical assault, and as found by Sergeant Detective Mary-
Ann Riva, one of BPD's most experienced domestic violence investigators, there was no
threatened assault. She wrote under oath:
"In my view, based on my experience as a domestic violence detective, Sybil White was
angry and upset about the divorce which Dennis White had initiated and her statements were
made in that context. In my experience as a domestic violence detective, it is not uncommon
for incorrect statements to be made by one partner against another during a divorce
proceeding. That is not always the case, but it is sometimes the case. It was my opinion that
Sybil White's request for a restraining order was motivated out of her being upset and angry,
not because there was a real threat that Dennis White would commit violence against her.
Sybil White voluntarily vacated the restraining order against Dennis White on June 23, 1999,
more than ten months before it was scheduled to expire. In my view, based on my
experience and investigation, Dennis White did not make a threat to commit violence on
Sybil White, and did not present a threat of violence to her."

There is no basis for any investigation. The City already knew Commissioner White's record
based on more than three decades with the BPD and another six years with the Boston Fire
Department. He was promoted because the City was more than satisfied with his record. The
City is not entitled to conduct a free-wheeling, unbounded investigation of the Commissioner,
especially where it has no cause to remove him from office. The purpose of Chapter 322,
Section 7 of the Acts of 1962 is to protect the BPD Commissioner from political meddling and

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
T
Todd&Weld LLP April 6, 2021
W Page 2 of 2

influences that undermine the Commissioner's ability to run the police department
independently. The City's "independent investigation" threatens to violate the Commissioner's
independence and this statute.
Nevertheless, as an accommodation to Mayor Janey and in the interests of trying to move
beyond the current situation without litigation, and without waiving any of the Commissioner's
rights, Commissioner White will agree to participate in the renewed investigation into Ms.
White's allegations of an alleged shooting threat in 1999 and he will also sign a release agreeing
to the City's review of his CORI.

Very truly yours,

Nicholas B. Carter
NBC/adc

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
EXHIBIT
G
 TOdd&WeIdLLP
Nicholas B. Carter
E-mail: [email protected]

April 9, 2021

VIA FIRST CLASS MAIL AND EMAIL

Henry Luthin
Corporation Counsel
City of Boston
1 City Hall Square, Room 615
Boston, MA 02201
henry . I uth i n(o?boston.gov

Dear Mr. Luthin:

I am following up on our communication today about the investigation. First, thank you
for sending the investigator's engagement documentation. I have also requested that you send
me all other correspondence with the investigator. You have indicated we can get that
correspondence when the investigation is complete and the documents become public records. I
believe Commissioner White should be allowed to get that correspondence now, especially
because the scope of the investigation may be an issue. If the City has provided direction to the
investigator, Commissioner White should be made aware of those instructions. Please let me
know if the City will agree to provide Commissioner White with a copy of its correspondence
with the investigator.
I also learned that after we provided the notarized CORI authorization form, it was
improperly sent to the City/BPD to do the CORI check. The form authorized Creative Services,
Inc. I was, therefore, confused that our agreement was not followed. You have assured me that
you will take care of it. My concern is that the agreements we reach are followed.
Thank you.
Very truly yours,

Nicholas B. Carter
NBC/adc

Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02 1 10 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com
EXHIBIT
H
Carter, Nick

From: Carter, Nick

Sent: Wednesday, May 12, 2021 9:04 AM
To: Henry Luthin
Subject: RE: Update

Henry: I hope your medical procedure went smoothly yesterday. As for Commissioner White, his day went less well. Six
different reporters contacted his family yesterday. I am extremely concerned that the City has leaked some or all of the
investigator's report, or information concerning it, to members of the press. That would be a gross violation of his rights
and an extreme act of discourtesy and disrespect to him. The report should and must be made available to him
immediately. It would also help to discuss the status of this matter to ensure all parties are treated properly in this
process. You can reach me at 617 686 8169.

I look forward to your prompt response.

Nick

From: Henry Luthin <[email protected]>

Sent: Monday, May 10, 2021 4:32 PM
To: Carter, Nick <[email protected]>
Subject: Update

Hello Nick,

I am sorry I could not get back to you today. I will be in touch. I am out tomorrow with some minor medical stuff, but
should be in Wednesday.

Henry

Henry C. Luthin
Corporation Counsel
City of Boston Law Department
City Hall, Room 615
Boston, MA 02201

617.635.4099 (o)
617.594.1645 (c)

1
Carter, Nick

From: Carter, Nick

Sent: Monday, May 10, 2021 4:43 PM
To: Henry Luthin
Subject: Re: Update

Hi Henry: Please call me. 617 686 8169. The City is now in violation of Commissioner White's right to see a copy of the
report. I'd also like to discuss the status.

Nick

Nick Carter
Todd & Weld
One Federal Street
Boston, MA 02110
617.624.4727

> On May 10, 2021, at 4:39 PM, Henry Luthin <[email protected]> wrote:
>
> 4099

1
Carter, Nick

From: Carter, Nick

Sent: Monday, May 10, 2021 9:25 AM
To: Henry Luthin
Subject: RE: Tamsin Kaplan report

Hi Henry: As a reminder, please send the investigator's report as soon as possible this morning. Also, I'd like to discuss
the status of this matter. Pls let me know a good time to discuss. Thank you.

Nick

From: Henry Luthin <[email protected]>

Sent: Saturday, May 8, 2021 11:19 AM
To: Carter, Nick <[email protected]>
Subject: Re: Tamsin Kaplan report

Nick,

I was tied up yesterday. Will see to it Monday.

Henry

Henry C. Luthin
Corporation Counsel
City of Boston Law Department
City Hall, Room 615
Boston, MA 02201

617.635.4099 (o)
617.594.1645 (c)

On Fri, May 7, 2021 at 3:46 PM Carter, Nick <[email protected]> wrote:

Henry: By statute, you are required to provide the report to us no later than today. Please send it to me. Thank you.

Nick

From: Carter, Nick

Sent: Tuesday, May 4, 2021 6:15 PM

1
To: Henry Luthin <[email protected]>
Subject: Re: Tamsin Kaplan report

Henry: I repeat our request for the report. Please advise when we will receive it. Thank you.

Nick Carter

Todd & Weld

One Federal Street

Boston, MA 02110

617.624.4727

On May 3, 2021, at 5:14 PM, Carter, Nick <ncarterPtoddweld.com> wrote:

Henry: I repeat Commissioner White's request for the investigator's report, which he is entitled
to. Please let me know if and when the City will provide the report to us. Thank you.

Nick

From: Carter, Nick

Sent: Sunday, May 2, 2021 12:36 PM
To: Henry Luthin <[email protected]>
Subject: RE: Tamsin Kaplan report

Henry: I reiterate the request for a copy of the investigator's report concerning Commissioner
White. He is entitled to a copy out of fairness, due process and because it's a personnel record. See
M.G.L. c. 149, sec. 52C.

Nick

From: Henry Luthin <henrv.luthinpboston.gov>

Sent: Saturday, May 1, 2021 1:18 PM
2
To: Carter, Nick <[email protected]>
Subject: Re: Tamsin Kaplan report

Let's be clear. I said I would get back to you.

Henry C. Luthin

Corporation Counsel

City of Boston Law Department

City Hall, Room 615

Boston, MA 02201

617.635.4099 (o)

617.594.1645 (c)

On Sat, May 1, 2021 at 10:18 AM Carter, Nick <ncartergtoddweld.corn> wrote:

Henry: As discussed just now, please provide a copy of the investigator's report on Commissioner
White to me this morning. Thank you.

Nick Carter
Todd & Weld
One Federal Street
Boston, MA 02110
617.624.4727

This e-mail, and any attachments thereto, is intended only for the addressee(s) named
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received this e-mail in error, please immediately notify me by return e-mail and
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