Former 6/10 Construction Project Supervisor Pleads Guilty to Making False Statements
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Former 6/10 Construction Project Supervisor Pleads Guilty to Making False Statements
GoLocal unveiled the dumping of the contaminated material in September 2020, which sparked both the federal and state investigations.
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Ferreira falsely represented the origin and environmental quality of railroad ballast (loose stone) and the origin of soil imported into the 6/10 Project.
Rhode Island Department of Environmental Management (DEM) officials deemed the material to be contaminated, after Rhode Island Department of Transportation Director Peter Alviti repeatedly lied, claiming the material was clean.
Ferreira was a former employee of Barletta Heavy Division, Inc., the Massachusetts construction company, and the lead contractor on the project budgeted for more than $400 million.
Ferreira, in his role for Barletta, was responsible for the construction of the Route 6/10 Interchange Project and he admitted to a federal judge that, in July 2020, he falsely reported to the Rhode Island Department of Transportation (RIDOT) the origin of 93 truckloads of railroad ballast imported to the 6/10 Project from Massachusetts; 52 truckloads of dirt imported to the 6/10 Project from the Barletta Pawtucket/Central Falls Rail Station Project; and that he was responsible for a report submitted to RIDOT by Barletta stating that the stone imported from Massachusetts had been tested and met environmental criteria as required in a Soil and Materials Management Plan (SMMP) prepared by RIDOT. In fact, the stone had not been tested and did not meet the environmental criteria.
In October, United States Attorney Cunha announced the resolution of federal criminal and civil investigations into Barletta and Ferreira. The resolutions included Ferreira’s agreement to plead guilty; a civil resolution that will recover from Barletta more than twice the amount paid by the government as a result of the conduct; and a non-prosecution agreement with the construction firm.
Federal investigations into contracting and procurement on portions of the federally-funded 6/10 Project centered on false statements by Ferreira and the company, as well as billing submissions made to the federal government for the stone and dirt. This fill, which was required to either be used at its original location, or subjected to additional testing and handling, did not meet the requirements of the contract.
Ferreira is scheduled to be sentenced on March 16, 2023. The defendant’s sentence will be determined by a federal district judge after consideration of the U.S. Sentencing Guidelines and other statutory factors.
More About Case
The United States has separately entered into a Non-Prosecution Agreement with Barletta in connection with the false statements that were made to the Federal Highway Administration and RIDOT. These statements were meant to conceal the fact that Barletta had imported regulated material in violation of the SMMP, which was part of the contract governing the 6/10 Project. Under the Agreement, Barletta accepts responsibility for the actions of its employees and admits to the facts that constitute making false statements in connection with a federally funded highway project.
In addition to paying a $500,000 criminal fine, the agreement requires Barletta to implement ongoing monitoring, reporting, and compliance measures for a period of three years; failure to comply with these conditions will make the company subject to prosecution for the conduct set forth in an agreed-upon Statement of Facts.
Barletta has entered into a False Claims Act settlement that resolves allegations that the company knowingly submitted claims for payment for work on the project in connection with the movement of dirt that did not comply with contract requirements, in violation of the federal and Rhode Island state False Claims Acts. Barletta will pay $1,000,000 to the government, representing more than twice the government funds paid as a result of the relevant claims.
Assistant U.S. Attorneys Dulce Donovan and Bethany Wong are handling the prosecution and litigation of these matters.
The matter was investigated by the U.S. Department of Transportation, Office of Inspector General, and the U.S. Department of Labor, Office of Inspector General, with assistance from the Rhode Island Department of Environmental Management, Division of Law Enforcement.
This story was first published 12/14/22 5:10 PM
Who Are The Players -- Contamination at $410 Million 6/10 Project
Vincent Barletta, CEO and President of Barletta
Vincent "Vin" Barletta is the man in charge of the family-owned construction company located in Canton, MA.
He has been at the helm during the 6/10 project and, in addition, has landed hundreds of millions of dollars of contracts from the RI Department of Transportation, including the Henderson and Washington bridge projects.
He has refused to respond to dozens of requests for comment. His attorneys have sent multiple letters to GoLocal threatening litigation in response to GoLocal's nearly two years of reporting.
The company has two segments:
Barletta Engineering Corporation constructs water and sewage treatment facilities, gas-fired and renewable energy power plants, green roofs and spaces, and commercial buildings.
Barletta Heavy Division, Inc. is focused on work such as airports, roads, highways, bridges and tunnels, public transportation projects, railroad and light rail tracks, landscaping, environmental remediation, sitework and utilities.
Vincent Barletta was Barred in MA From Making Political Contributions
In 2016, the Massachusetts campaign finance agency said that Vincent Barletta made or reimbursed donations improperly to 10 candidates, including Gov. Charlie Baker, Lt. Gov. Karyn Polito, former Gov. Deval Patrick, former Lt. Gov. Tim Murray, Boston Mayor Martin Walsh and former Weymouth Mayor Sue Kay.
As part of the agreement between Barletta and state officials, he was forced to pay a "civil forfeiture" payment of $185,000. In the 16-page agreement signed by Barletta, "Respondents First Fidelity Corp., Puma Corp. and Vincent Barletta, jointly and severally, shall make payments totaling $185,000 to the Commonwealth of Massachusetts in the nature of a civil forfeiture."
And the agreement stipulated further, "The Respondents agree not to make any contributions to influence Massachusetts elections for a period of five ( 5) years from the date of this Agreement. The Respondents agree not to fund any independent expenditures or electioneering communications for a period of five ( 5) years from the date of this Agreement. Vincent Barletta agrees not to solicit contributions for any Massachusetts candidate or candidate committee from any employee of Barletta Engineering or its related corporate entities for a period of five (5) years from the date of this Agreement."
Barletta has not made any donations in Rhode Island to date. But, he and his wife attended a major fundraiser for then-Governor Gina Raimondo and then-Speaker of the House Nick Mattiello.
The prohibition in the Commonwealth has now expired.
PHOTO: GoLocal
Peter Alviti, Director of the RI Department of Transportation
Appointed to head RIDOT by Governor Gina Raimondo. Alviti, when notified of the contaminated soil by union leader James White in July of 2020, denied there was contamination.
Repeatedly, Alviti told the public that there was no contamination, and even after it was proven, he tried to minimize the impact.
GoLocal's exclusive reporting revealing the contamination at the 6/10 site was published on Tuesday, September 8, 2020 -- and two days later, Alviti was on the radio making statements -- that documents obtained by GoLocal now show to be false.
“So basically we've proven that the fill that was brought in is OK, but we're concerned and I think the investigation is going to continue, because we're concerned that another agenda is going on here. We don't know what it is,” said Alviti on the Gene Valicenti radio show, two days after the first GoLocal investigative story.
Alviti has refused multiple requests for interviews.
Gina Raimondo, Former Governor of RI and Now U.S. Secretary of Commerce
The dumping of the contaminated soil took place under the Raimondo administration.
Her appointee Peter Alviti of RIDOT, repeatedly claimed there was no cover-up.
Then-RIDEM director Janet Coit -- under Raimondo -- refused to respond to whistleblower James White's letters about the contamination.
The Carmona Family
Contaminated soil was piled up to the second story of their home — and state officials turned a blind eye to its impact.
Once the contamination was found, no one from the state contacted the Carmonas or any other neighbors. GoLocal told them about the contamination.
The Carmona family has lived on their one-block street for twenty years — and they just so happen to be located adjacent to the staging area for the state for the $410 million Rhode Island Department of Transportation 6/10 Reconstruction Project.
The family says they have suffered from the project that was loud and dirty. They worried about the impact of the soil constantly blowing onto their property. The family says the construction site has been far more than a nuisance — they say it has done damage to their home and their lives.
When they told the state they needed to have their pregnant daughter live elsewhere due to concerns for her well-being, the state tried to get them to sign an ironclad agreement — for $12,600, that was subject to taxes — that would prohibit the Carmonas from taking any further legal action against the state, the contractor, or dozens of connected entities.
Ever.
Luckily for the Carmonas, they were advised by friends not to agree to the state’s terms.
The Carmonas have lawyers now, and the state is the subject of local and federal investigations.
It might be David vs. Goliath, but the state can no longer ignore —or try to buy off — the welfare of its residents, ever again.
David Walsh, Acting Manager of Project Management at the Rhode Island Department of Transportation
David Walsh tried to pressure the Carmona family to sign an agreement with the State of Rhode Island to release the state from any and all claims.
“In October of 2019, David Walsh tried to get us to sign a release for any damages, we showed it to a family friend who said ‘do not sign’ the release. [Walsh] asked us repeatedly [to sign the agreement] and told us to hurry,” said Teofilo Carmona during an interview in his backyard.
Walsh, who serves as Assistant Director of Administrative Services, told GoLocal, “Sometime this summer, someone from Barletta went over and talked to the Carmonas about the problems."
“You probably should speak to someone at RDOT's communication office. I do know this, the supervisor for Barletta went to Mr. Carmona and talked to him,” Walsh added before ending the call.
GoLocal reached out to Barletta’s then-supervisor on the site, Dennis Ferreira, who is the contact for the Carmonas — he did not respond to phone calls or texts. The company did not respond to requests and the company’s attorney did not respond to requests to connect GoLocal with Ferreira.
Walsh joined in March 2018.
Prior to joining RI DOT, Walsh served as Vice President, Licensed Retail for Bassett Furniture Industries for 11 years.
He is paid $145,837.84, according to state records.
PHOTO: LinkedIn
Timothy Barletta, Brother of Vincent Barletta
Timothy Barletta, Vincent Barletta's brother, was a major donor to a Rhode Island political fundraiser for then-Governor Gina Raimondo, then-Speaker of the House Nick Mattiello and the Democratic party.
READ ABOUT THE FACTS OF THE INCIDENT HERE
At the December 2017, RI political fundraiser, Timothy Barletta made donations at the high-profile Rhode Island event, held at Deepwater Wind’s then-headquarters. Timothy Barletta made combined contributions totaling $5,000 for the event.
In connection with these donations, Timothy Barletta filled out a campaign donation card that listed his employer as Barletta Engineering.
Barletta Attorneys Deny Tim Barletta Is Involved in Company -- But Federal and State Campaign Records Say Otherwise
Lawyers for the company, however, dispute that Timothy Barletta was employed by Barletta Engineering at the time. Attorneys for Barletta Engineering claim in a letter to GoLocal that there has been no association between Timothy Barletta and the company for some time.
“For over 10 years Tim Barletta has not had any involvement with the Barletta Companies as an executive, employee, owner, shareholder, board member, or officer. That Tim Barletta happens to be Vincent F. Barletta's brother is immaterial. [sic] GoLocal's assertions about Tim Barletta clearly were made to accuse The Barletta Companies of making political contributions to the Governor's political party in an effort to curry favor with the State of Rhode Island's awarding authorities. GoLocal omitted from its article, [sic] is the fact that 6/10 Constructors Joint Venture was awarded a contract on the '410 million 6/10 construction project' because its public bid price of 248 million was more than 82 million dollars less than the next low bidder, yielding substantial savings to the State of Rhode Island. To be clear, no person at The Barletta Companies ever requested Tim Barletta to make any political contributions in the State of Rhode Island, nor were such contributions in any way related to the award of this publicly bid project to the 6/10 Constructors Joint Venture."
According to those organizing the event, it event raised $26,000 in total, with the Barletta donations totaling $5,000, or nearly 20% of the total take.
Not only did Timothy Barletta list his employer as Barletta Engineer in connection with the donations to the Rhode Island Democratic Party in December 2017, but he also listed Barletta Engineering in another Rhode Island donation to a Democratic PAC, as well as on multiple federal campaign donations in the past few years.
For example, in filings with the Federal Election Campaign Commission, Timothy Barletta listed his employer as Barletta Engineering in donations to U.S. Congressman Dutch Rappersberger (D-MD).
According to FEC records, Timothy Barletta made two donations totaling $2,000 to Ruppersberger for Congress Committee. And, he made a $2,000 donation to U.S. Congressman Andy Harris (R-MD) in March of 2016, and again, listing Barletta Engineering as his employer.
GoLocal spoke to Richard Thornton of the state of Rhode Island’s Campaign Finance Division and asked if a Barletta attorney or the political committee or the PAC to which Timothy Barletta donated in 2017 had contacted the office about changing Barletta’s employment affiliation, and Thornton said no.
GoLocal has reached out to both Vincent Barletta and attorneys for the Barletta companies more than a half-dozen times for comment via email, phone, and social media relating to these inconsistencies with what was filed with state and federal election agencies and their accusations. They have not responded to any of the requests.
Dennis Ferreira, Former Construction Supervisor at 6/10 Project for Barletta
Ferriera was Barletta's man on the ground on the project -- the long-time Barletta employee was with the company for years.
According to those interviewed by GoLocal -- Ferreira pressured one of the families impacted by the contamination to sign a RIDOT legal release that would indemnify not only RIDOT, but all the contractors, including Barletta.
Ferreira has now pleaded quilty to three federal charges and awaits sentencing.
Ordered the Contaminated Material Be Dumped
On Sunday, March 7, 2021, federal agents interviewed Barletta supervisor Jeremy Oliveira about the Pawtucket/Central Falls Train Station project at his home in Dartmouth, Massachusetts about moving contaminated soil from the Pawtucket site to the 6/10 project site.
Oliveira in a phone interview with GoLocal in April of 2021 confirmed that federal agents visited his home, but denied that he knew where the contaminated soil was being taken for disposal after it left the Pawtucket/Central Falls Train Station site.
“It was my job to load the trucks,” said Oliveira, referring to the dozens of trucks that moved material from the Pawtucket/Central Falls site to the 6/10 Olneyville site on Plainfield Street.
"Nothing goes without Dennis' approval," said Oliveira. "He instructed the trucks to take it to the 6/10 site."
Oliveira’s reference to "Dennis" is Dennis Ferreira. He is the project supervisor on the 6/10 Project who oversees the day-to-day operation of the massive construction project that each day is working on multiple sites across acres and acres in Providence neighborhoods and involves hundreds of workers.
6/10 Project Material Moved to Ferreira's Daughter's Home
GoLocal tracked the transportation of concrete retaining wall blocks from the 6/10 construction site in Providence to the home of the daughter of Barletta Engineering’s supervisor in Weymouth, MA for the family's private use.
The contract to Barletta and its partners was awarded by the Rhode Island Department of Transportation -- and is worth hundreds of millions of dollars.
Massive concrete retaining blocks were loaded onto a trailer in Providence and then trucked to the home of Barletta’s Dennis Ferreira’s daughter’s home in Weymouth. Identical types of blocks are being installed at the taxpayer supported 6/10 project.
According to Weymouth town records, the home at 485 East Street is co-owned by Ferreira's daughter Laken and her husband Brendan O’Brien and they purchased the property in 2019 for $488,000 — the home is now valued for as much as $540,000.
The concrete blocks are being used in a new retaining wall being installed on the privately owned Weymouth property.
Ferreira reached by phone, told GoLocal, "I have no comment."
GoLocal tried to reach Ferreira's daughter -- the homeowner of the house in Weymouth -- and she did not respond to questions.
It is unclear why RIDOT inspectors did not detect the removal of the material.
James White, President of Local 57 of the International Union of Operating Engineers
James White, President of Local 57 was the first to blow the whistle on the contaminated soil being dumped on the 6/10 Project.
He told GoLocal, “I first brought concerns to Barletta in July [2020] and they did nothing. Our folks are trained in identifying hazardous materials and we had concerns about the soil materials they were bringing on to the site.”
"We have a woman who works on this site and she goes home and hugs her daughter. When she leaves she is covered with dust from working this site. I don't want her and her daughter harmed," said White.
“Steve Rogers, our business agent for the union, tracked the trucks which were dumping on the site 6/10 Connector and followed the trucks and found that they were not coming from the site that Barletta told us. The soil was coming from another Barletta project — MBTA railroad station in Jamaica Plain, Massachusetts,” said White.
Steve Rogers, Local 57, International Union of Operating Engineers
Steve Rogers was the business agent for Local 57 of the International Union of Operating Engineers at the time of the dumping.
He tracked the trucks with materials believed to be contaminated, from Massachusetts to Plainfield Avenue.
“Steve Rogers, our business agent for the union, tracked the trucks which were dumping on the site 6/10 Connector and followed the trucks and found that they were not coming from the site that Barletta told us. The soil was coming from another Barletta project — MBTA railroad station in Jamaica Plain, Massachusetts,” said James White, President of the Union.
Local 57 local union of the International Union of Operating Engineers, which represents over 1,000 heavy equipment operators and mechanics in the Rhode Island area.
PHOTO: Rogers
Janet Coit, RI Department of Environmental Management
Whistleblower James White wrote to Coit, then the Director of the RI Department of Environmental Management, alerting her of the contamination and forwarding to her the independent analysis of the contaminated soil.
"It is shocking to think that the State of Rhode Island would allow thousands of tons of hazardous waste to be trucked in from Massachusetts and dumped in the middle of Providence for use on a construction project. This hazardous waste is being buried in close proximity to businesses, homes and a school," wrote White in his letter to Coit on August 31.
But, White never received a response to his letter.
Today, Coit works for former RI Governor Gina Raimondo, at the United Sttaes Commerce Department.
Susan Murphy, Special Agent, U.S. Department of Labor, Office of Inspector General
Just days after GoLocal's first article on the contamination -- federal agents began to ask questions.
The investigators with the U.S. Department of Labor’s Office of Inspector General, Office of Labor Racketeering & Fraud Investigation as well as from the U.S. Department of Transportation began interviewing key players in the contamination controversy relating to the $410 million project.
Special Agent Susan Murphy of the Office of Inspector General has conducted interviews in Rhode Island. She was accompanied by Todd Collins, a Criminal Investigator with the U.S. DOT's Office of Inspector General
Of the total project cost, Barletta and its partners in the 6-10 Constructors Joint Venture's portion of the project is $247 million. The project was awarded to 6-10 Constructors Joint Venture after it was, the Barletta entities claim, the low bid by “more than 80 million dollars.”
This is not Murphy's first investigation in Rhode Island. She also led a 2018 insurance fraud case.
In 2021, she won recognition from the Association of Certified Fraud Examiners for her work.
Murphy did not respond to requests for comment.
James Manni, Former Superintendent of the Rhode Island State Police
On Tuesday, September 8, 2020, Manni was summed to Governor Gina Raimondo's office the morning GoLocal's first story on the contamination was published.
A State Police officer had begun looking into the contamination just days earlier.
But only hours after GoLocal's initial expose and the meeting in Raimondo's office, Capt. Moynihan sent a memo to Casey ordering him to stop investigating and any further action would subject him to a charge of insubordination.
Moynihan's memo stated:
“As I had instructed you on Saturday and again today, you are not to do anything further regarding this complaint. You should not be contacting anyone regarding the status of this investigation. It has been assigned to the Detective Bureau and they will be coordinating all further investigative activities. REDACTED
I have been very clear that this will not be investigated by you or members from the Uniform Bureau. The allegations are extremely serious and the Division must ensure our investigative efforts are thorough and performed with confidentiality in order to identify any potential wrongdoing.
“Any further action on your part will be considered insubordination as I feel I have been very clear that this will not be investigated by you or members from the Uniform Bureau,” wrote Moynihan.
Both Manni and Moynihan have left the State Police.
Today, Manni is the town manager and Moynihan is the police chief in South Kingstown.
Zachary A. Cunha, U.S. Attorney for the District of RI
Zachary Cunha was sworn in as U.S. Attorney for Rhode Island in December of 2021.
Cunha joined the U.S. Attorney’s Office for the District of Rhode Island in 2014. He earned a promotion to chief of the civil division in February 2018. Prior to being appointed to his current post, he served as the Affirmative Civil Enforcement Coordinator in the U.S. Attorney’s Office for the District of Rhode Island. In that capacity, he was responsible for cases in which the United States, as plaintiff, seek to vindicate governmental interests, combat fraud, and recover funds under the Federal False Claims Act.
Cunha began his career with the Justice Department in the Eastern District of New York, where he served as an Assistant U.S. Attorney from 2005 to 2008.
Before joining the Department, Cunha worked as an Assistant Corporation Counsel for the City of New York, representing the City and its officers in federal litigation. Cunha also served as an Assistant U.S. Attorney in the District of Massachusetts for five years, commuting to Boston from his home in Rhode Island. Cunha and his family are long-time Rhode Island residents.
In 2010, Cunha received the Attorney General’s Award for Exceptional Service, the highest honor conferred by the U.S. Department of Justice, for his work as part of the prosecution team that achieved a $2.3 billion dollar civil and criminal resolution of charges against Pfizer, Inc. for illegal marketing conduct.
At the time, this case represented the largest civil recovery and fine ever collected by the Department of Justice in a health care fraud case.
According to his bio, Cunha earned a Bachelor of Arts, with honors, from Brown University in 1998, and a Juris Doctorate, also with honors, from George Washington University Law School in 2001.
Peter Neronha, RI Attorney General
Neronha has had a mixed record on environmental issues.
In his first two years as RI Attorney General, Neronha took little action on environmental crimes.
More recently, he has levied fines and taken enforcement action against a group of landlords for lead violations.
In August, he announced Rhode Island’s combined recoveries from settlements as part of ongoing MTBE litigation totaling over $18 million. But that litigation began two years before Neronha came to office. The contamination took place 20 years ago.
As U.S. Attorney, environmental enforcement plummeted during the Neronha era. Under Neronha between 2013 and 2018, his office issued more than 820 press releases and just two dealt with the environment. One of the announcements regarded a 20+-year-old Superfund case and the other was a settlement agreement by U.S. Environmental Protection Agency against RIDOT.
Bethany Wong - Civil Division Chief, U.S. Attorney's Office
Wong is the lead prosecutor for the U.S. Attorney on the 6/10 case.
She was named Chief of the Civil Division in January 2022, and had been appointed an Assistant United States Attorney in the office’s Civil Division in August 2014. In addition to representing the United States in a wide range of civil affirmative and defensive matters, Wong has also served as the office’s Affirmative Civil Enforcement coordinator since October 2018.
Prior to joining the U.S. Attorney’s Office, Wong served as a staff attorney at the Women Against Abuse Legal Center in Philadelphia, where she represented victims of domestic violence seeking legal protection in Family and Superior Court. She was also an associate at Morgan, Lewis & Bockius LLP, where she advocated on behalf of clients in civil, criminal, and appellate matters in federal and state courts in Pennsylvania. She graduated summa cum laude from Grove City College in Grove City, Pennsylvania in 2005, and earned her Juris Doctor at the University of Virginia School of Law in 2008.
State Police Lt. Michael Casey (Retired)
Lt. Michael Casey of the Rhode Island State Police was the first investigator to look at the claims of contamination.
When he tried to advance the investigation, the State Police threatened to charge him with insubordination.
Here is what GoLocal learned:
A GoLocal Access to Public Records Act (APRA) request unveils that the RISP officer who first uncovered the illegal dumping was not only ordered off the investigation, but threatened with discipline if he took further action.
On Saturday, September 5, 2020, Lt. Michael Casey wrote in a detailed memo to Captain Matthew C. Moynihan, then-a member of the State Police's command staff, unveiling contamination associated with one of the state's most expensive transportation projects.
The memo stated that a retired state trooper had contacted Casey to alert him to the issue of illegal dumping. But nearly as soon as the investigation began, it was over.
On Tuesday, September 8, 2020, GoLocal broke the story of the contamination, in the article "EXCLUSIVE: Union Official Says RIDOT Allows Contractor to Illegally Dump Contaminates at 6/10 Site."
Later that Tuesday morning a meeting was held by Governor Gina Raimondo's office hosted by staffer Nicole Verdi -- that meeting included top staff RISP, RIDOT, and the Rhode Island Department of Environmental Management (RIDEM).
In a memo, written hours after GoLocal's story and the subsequent emergency meeting in Raimondo's office, Moynihan wrote at 9:13 PM to Casey ordering him to abandon the investigation and threatened him with disciplinary action.
The documents released to the GoLocal by the State Police in response to the APRA request were redacted, but GoLocal has learned what was printed under the blackened area in one of the key redactions.
Moynihan's memo stated:
“As I had instructed you on Saturday and again today, you are not to do anything further regarding this complaint. You should not be contacting anyone regarding the status of this investigation. It has been assigned to the Detective Bureau and they will be coordinating all further investigative activities. REDACTED
I have been very clear that this will not be investigated by you or members from the Uniform Bureau. The allegations are extremely serious and the Division must ensure our investigative efforts are thorough and performed with confidentiality in order to identify any potential wrongdoing.
We will ensure the case narrative report is accessible to you in the morning in order for you to .review and finalize your reports."
What Was Redacted by RI State Police
GoLocal has learned what Moynihan wrote in the email to Casey that was redacted by the State Police’s legal counsel Andrew Sholes before releasing the documents to GoLocal was a threat of disciplinary action, the redacted portion states:
“Any further action on your part will be considered insubordination as I feel I have been very clear that this will not be investigated by you or members from the Uniform Bureau,” wrote Moynihan.
