oregon department of corrections human resources...

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Oregon Department of Corrections Human Resources Investigation Report

CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION

DO NOT DISCLOSE OR DISTRIBUTE WITHOUT EXPRESS PERMISSION OF LEGAL COUNSEL

SUBJECT: Inspector General Leonard Williamson

COMPLETED: October 19, 2015 INVESTIGATOR: Martin Imhoff, Labor Relations Manager 2767 22nd Street SE Salem, OR 97302 (503) 378-6470 CONTENTS: Issue one, former dog handlers’ complaint………….pages 2 to 17

Issue two, complaint…………………...pages 18 to 32

DATES, Allegedly occurred: On and after September 30, 2014 ISSUE ONE: Reported: Spring, 2015 REPORTING , Inspector 2, former dog handler PARTIES, , Inspector 2, former dog handler ISSUE ONE: , Inspector 2, former dog handler

DATES, Allegedly occurred: August 1 - 12, 2013 ISSUE TWO: Reported: April, 2015 REPORTING , Inspector 2 PARTY, ISSUE TWO:

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ISSUE ONE, FORMER DOG HANDLERS’ COMPLAINT:

Initiation of Investigation…………………………... pages 3 - 4

Focus of Investigation statement…………............... page 4

Summary……………..……….……………………..page 5

Findings with citations to appendices……………….pages 6 - 15

Analysis……………………………………………...pages 15 - 17

testimony and follow up………………… Appendix A Inspector 2, Coffee Creek Correctional Facility testimony………………………………Appendix B Inspector 2, Coffee Creek Correctional Facility testimony and information.......................... Appendix C Inspector 2, Oregon State Correctional Institution testimony and information.................. Appendix D Inspector 2, Eastern Oregon Correctional Institution

and Two Rivers Correctional Institution testimonies…………… Appendix E STM Lieutenant, TRCI; Inspector 2, TRCI; Officer, EOCI testimony………………………………....Appendix F STM Lieutenant, Oregon State Correctional Institution testimony and information……………...Appendix G Inspector 2, Oregon State Penitentiary testimony……………………………….Appendix H STM Lieutenant, Eastern Oregon Correctional Institution testimony…………………………….Appendix I STM Lieutenant, Oregon State Penitentiary testimony……………………...…Appendix J Inspector 3, Dome Building Jean Bergen testimony………………………….…Appendix K ESS2, Director’s Office, Dome Building Colette Peters testimony…………………………...Appendix L Director, Oregon Dept. of Corrections, Dome Building Ken Jeske testimony……………………………….Appendix M Administrator, Oregon Correctional Enterprises

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Garrett Laney testimony…………………………...Appendix N Deputy Inspector General, Dome Mike Gower testimony…………………………….Appendix O Assistant Director of Operations, Dome Leonard Williamson testimony…………………….Appendix P Inspector General, Dome Leonard Williamson correspondence………………Appendix Q Inspector General, Dome correspondence………………………Appendix R Investigations Manager, Oregon State Board of Nursing Marcia Ventura testimony………………………….Appendix S Legal Coordinator, Office of Inspector General, Dome Emily Benavidez testimony and information………Appendix T Management Assistant, OIG, Dome Mitch Morrow correspondence……………………..Appendix U Former Deputy Director, ODOC

INITIATION OF INVESTIGATION:

Following consultation with the Department of Justice, on June 12, 2015, DOC Deputy Director Kim Brockamp assigned me to investigate two allegations regarding the conduct of Inspector General Leonard Williamson. Thereafter, I learned from conversation with Ms. Brockamp that multiple Office of the Inspector General (OIG) staff had spoken to either Director Colette Peters or herself during Spring 2015 and identified concerns with Mr. Williamson’s conduct as Inspector General. From among the concerns, they identified two allegations of sufficient substance and detail, which multiple staff had described. Ms. Brockamp provided me with materials which former dog handler staff had earlier provided to Director Peters:

o Letter dated November 4, 2014 from Leonard Williamson to , explaining the termination of the dog program

o Memo dated May 22, 2014 from Deputy Inspector General Garrett Laney to K-9 Unit/Handlers, clarifying how to measure their work

o E-mail dated April 28, 2014 from Leonard Williamson to Garrett Laney making detailed suggestions to his “white paper” about the dog handler status

o Oregon Police Canine Association (OPCA) Certificate of Attendance, 2014 Fall Seminar, , September 22 – 24, Newport Oregon, signed by Kyle Joye, OPCA President, plus 24

pages of supporting documentation showing actual scenario training results with his dog Dixie o OPCA Certificate of Attendance, 2014 Fall Seminar, , September 22 – 24, Newport

Oregon, signed by Kyle Joye, OPCA President, plus 21 pages of supporting documentation showing actual scenario training results with his dog Sprint

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o OPCA Certificate of Attendance, 2014 Fall Seminar, , September 22 – 24, Newport Oregon, signed by Kyle Joye, OPCA President, plus 29 pages of supporting documentation showing actual scenario training results with his dog Baxter

Additional information from Ms. Brockamp included the following:

o E-mail dated April 14, 2014 from Leonard Williamson to then-Deputy Director Mitch Morrow and Assistant Director Mike Gower explaining had just passed standards testing, meaning he and his dog Dixie were a certified team

o E-mail dated August 6, 2012 from then-Inspector 3 to then-Investigations Administrator explaining how he successfully employs his drug detection dog Jackson at Deer Ridge Correctional Institution without obtaining OPCA team certification

o E-mail string dated May 11 – May 31, 2012, between then-Chief Administrator of HR Daryl Borello and Leonard Williamson about 5 issues Mr. Williamson wanted Mr. Borello’s assistance with

o Office of the Inspector General document dated March 31, 2014, 8 pages describing the status of the Special Investigations Unit (SIU) Caning (K9) Operations; I came to learn this was called the “dog program white paper” or “the dog handler report.”

All of the above items reside in the investigation file. Some of them were also independently submitted to me by different witnesses; those documents which I judged as having enough investigative relevance are detailed in those witness appendices. Following my meeting with Ms. Brockamp to initiate the investigation on June 12, 2015, she e-mailed former dog handlers , , and to explain that I was assigned to investigate their concerns. At or around the same time, she also communicated this information to Leonard Williamson.

FOCUS OF INVESTIGATION, ISSUE ONE: This issue focuses on actions and statements attributed to Inspector General Leonard Williamson which led to the shut-down of the DOC drug- and contraband-detection dog program. Mr. Williamson is alleged to have made false statements to Policy Group members and other DOC staff concerning the conduct of DOC dog handler staff at an off-site training. He allegedly told stakeholders and witnesses in multiple setting words to the effect, they attended the conference and “brought their wives, not their dogs” and the dog handler teams did not certify. Central to the analysis of this matter is the origin and dissemination of statements by Mr. Williamson leading hearers to believe the west side dog handler staff brought their wives instead of their dogs to a training and certification event. The dissemination of this statement, with its negative connotation that the training was not work-focused, had a powerful impact on decision-making to shut-down the dog program. It caused the dog handler staff to believe they were untruthfully disparaged in multiple venues. This statement was the primary reason the former dog handlers complained to the Director’s Office.

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SUMMARY: It appears that on September 30, 2014, Mr. Williamson, put on the spot by then Deputy Director Morrow to report to the Policy Group1 that morning, was not prepared to provide a full factual report on the status of the dog program or what occurred during the Sept. 2014 off-site Oregon Police Canine Association (OPCA) training attended by four dog-handler teams. At the time he reported to Policy Group, while he had some preliminary information from his deputy, details had not been verified. Mr. Williamson sought answers to fundamental questions he had via mobile device e-mail as he waited his turn to present to Policy Group. He never received the answers he sought from his staff, who were also not aware he was presenting about the dog program to Policy Group. Mr. Williamson proceeded to present to Policy Group in a manner which caused Policy Group members to believe the west side dog handlers had brought their wives and not their dogs to the OPCA training and certification event. By the manner in which Mr. Williamson presented the content, Policy Group accepted on its face the accuracy of the information presented. The incorrect information had strong negative impact and the Policy Group consensus was to authorize Mr. Williamson to discuss the possibility of discontinuing the dog program with Mr. Morrow and Director Peters. A timely review of alleged events at the off-site training did not occur. Though this responsibility had been delegated to his deputy, Mr. Williamson apparently did not request or receive any status reports on the review nor did he follow up to obtain answers to fundamental questions he had raised directly with his staff on the morning he presented to Policy Group. Mr. Williamson carried forward to other stakeholder groups the representations he made to Policy Group, without qualification. Phone calls to the dog handlers in question, or the east side dog handler who attended the same conference, could have provided Mr. Williamson with information to answer the questions at hand – whether the dog handlers had their dogs at the conference, whether spouses accompanied the handlers, and whether they certified. Had Mr. Williamson awaited presentation to Policy Group until he understood the fundamental facts he sought, or at least taken steps in short order to verify the information himself or timely asked for a status update from the staff to whom he delegated, the Director, who discontinued the program based in part on the inaccurate information she received about the alleged events at the off-site training, may have elected a different course.

1 Policy group is the Director’s executive leadership staff and includes the following positions: Deputy Director, OCE Administrator, Diversity & Inclusion Administrator, Planning and Budget Administrator, Government Efficiencies & Communications Administrator, Inspector General, Assistant Director of Operations, Assistant Director of Offender Management & Rehabilitation, Assistant Director of Community Corrections, Assistant Director of Human Resources, and Assistant Director of General Services.

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FINDINGS:

Explanation of format: All gathered information was organized into appendices according to the source of the information. Many of the witnesses provided extensive detail in their statements, including background information to provide a context for their perceptions and conclusions. Some of this information is not directly relevant and is incorporated into appendices without being directly referenced in this report. Some findings were supported by multiple information sources, beyond what is expressly cited, and the reader is encouraged to read each citation and the context it came from for best understanding. A. The performance of the DOC detection-dog program and its staff had long been a subject of management discussion.

1. The DOC detection-dog program had received high-level DOC scrutiny before Leonard Williamson became Inspector General on September 1, 2011. See Peters page 1; Jeske page 1; Gower page 1; Williamson correspondence pages 31 – 32; Morrow page 18.

2. Mr. Williamson was first perceived as employing bullying managerial tactics in January 2012 when he threatened employees they would lose their jobs if they divulged information from a meeting about a drug task force being organized. See page 2.

3. Leadership changes affecting the dog program and altering how the dog handlers did their jobs were being felt in early 2012. See page 1; page 1.

4. Dog handlers experienced pressure from supervisors to do their work differently starting in late 2012. They were told they were Inspector 2s first and dog handlers second; they were told to be visible in Visiting and Yard. The dog handlers did not see these as changes which would make them more effective. See page 1, page 6, seven listed items; pages 1 - 2, 3; page 1; Williamson correspondence pages 33 – 34.

5. Two east side staff noticed why there might be a problem with west side dog handlers. During focused searches at Eastern Oregon Correctional Institution and Two Rivers Correctional Institution, there was a perception the west side dog handler staff were not putting forth their best efforts. See page 2; page 1.

B. Certification failures of four dog-handler teams on the same day greatly magnified management scrutiny of the dog handler program.

6. Four dog handler teams failed certification testing in March 2014, which management regarded as a significant negative event for the program. Inspector 2 and his dog partially passed and were eligible to re-test one portion of the test within 30 days. See page 6,

page 3; page 3; testimony page 1.

7. In response, then Deputy Director Mitch Morrow2 took an active and visible role in the dog program beginning on March 18, 2014, requesting a full cost-benefit analysis of the canine program. See page 5; Williamson correspondence pages 35 – 36.

2 Mr. Morrow retired from DOC on January 31, 2015.

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Appendix G

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STET - Williamson


8. On March 17, 2014, Garrett Laney started as Deputy Inspector General to Mr. Williamson. He had no knowledge of any historic concerns with the dog program. He said he was in information overload when Mr. Morrow requested a full cost benefit analysis of the dog program the day after he had started as deputy. See Laney page 1, 2.

9. OIG staff compiled an eight page report containing three appendices in response to Mr. Morrow’s request for a cost-benefit analysis of the dog program. See pages 3 – 10; Williamson correspondence, pages 28 – 30; Morrow pages 18 - 19. Part of the information OIG staff gathered was that historically, dog handlers pass OPCA certifications only about half the time they attempt testing. The past pass/fail rate was not included as context in the report provided to Mr. Morrow. See Williamson correspondence pages 62 – 65.

10. In early to mid-April 2014, Leonard Williamson presented conclusions from the dog program report to Policy Group for evaluation. There are varying memories of his presentation, which occurred during the round table portion of the meeting. The Policy Group made no recommendation about the continuation of the dog program at this meeting. See Jeske page 1; Gower page 1; Williamson testimony pages 3, 5; Morrow page 19.

11. On April 14, 2014, Inspector 2 and his dog successfully completed certification testing and obtained a 1-year certification. Both Deputy Garrett Laney and Leonard Williamson acknowledged this, calling it a huge success and a good job. See pages 16 – 17; Williamson testimony page 6; Williamson correspondence page 38; Laney page 3. Within two weeks, Mr. Williamson forgot about this successful certification; see Williamson testimony page 12. At some point Mr. Laney forgot; see Laney page 2. The fact of successful certification being forgotten by Mr. Williamson and Deputy Laney played an important role several months later, at the end of September 2014.

C. Performance directives were issued and a 6-month trial period was set up for the program.

12. On April 17, 2014, Mr. Morrow, Mr. Gower, Mr. Williamson and Mr. Laney met with the dog handlers. Others in attendance were west side Administrator Brian Belleque, Inspector 3 Claude Schultz, then Inspector 3 Tye Stewart, Administrative Specialist Jacob Humphreys, Inspector 3 Inspector 3 Gloria Parra, and east side deputy Rebecca Krueger. Mr. Morrow began the meeting with a very strong tone which led to new management directives and signaled a significant change in the structure of the program. Among changes, Management offered handlers the option to modify their schedules to provide service on weekends and evenings, if they wanted to remain dog handlers. They were given a day to decide what they wanted to do. If they did not want to do dog handling under these terms, they could remain employed as regular Inspector 2s. See page 1, pages 2 – 3, page 3; page 3; Laney page 1; Gower pages 1, 2; Williamson testimony pages 1, 6.

13. On April 18, 2014, the involved represented staff spoke with each other and there were conversations between management and represented staff about what to do. See page 2;

pages 3 – 4; page 4; page 4; Gower pages 1, 2; Williamson testimony page 2.

14. The dog program was given 6 months to improve under Mr. Laney’s supervision. New work schedules providing rotating weekend and evening coverage were set up for May through October, 2014. See page 7, fifth and sixth listed items; Laney page 1; Williamson testimony page 1; page 4; Morrow page 19.

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15. On April 28, 2014, Mr. Williamson reminded staff that the lack of certification got Mr. Morrow’s attention. He offered this context as a way to encourage staff to remedy this concern during the 6-month improvement period. See Williamson correspondence page 10.

16. The dog handlers checked in with Mr. Laney for feedback as a group approximately monthly. They did not hear anything negative except for a misunderstanding at Coffee Creek Correctional Facility that was subsequently resolved. See pages 2, 12; page 4 and on page 7, the ninth listed item; page 4; Laney page 2.

17. On August 28, 2014, four months into the 6-month period, Mr. Williamson requested a dog program data snapshot. See Williamson correspondence page 13.

18. On September 5, 2014, Mr. Williamson noted the information gathered and noted the expectation of a report to Mr. Morrow and Mr. Gower in two months. The report would address progress and observations about the program during the last six months. See Williamson correspondence page 11.

D. Management approved dog handlers to attend September 2014 OPCA training conference.

19. The dog handlers requested and received management approval to attend the September 2014 Oregon Police Canine Association (OPCA) Conference in Newport, Oregon. They made their request of Mr. Laney who conferred with Mr. Williamson before granting permission. The conference involved two days of dog team scenario practice with one day of classroom study. Management did not communicate any expectation that uncertified dog handler teams would perform certification testing at the conference. See page 4; pages 8, 22; Laney page 2; Williamson testimony page 7; Williamson correspondence pages 41 - 44.

20. When the OPCA Conference training ended on September 24, 2014, the west side dog handlers drove home that afternoon; , an east side handler who had a much longer drive, stayed another night. On September 25, 2014, drove to Salem on his way to eastern Oregon so he could enter his work activity on a DOC computer and turn in a copy of his training and certification records. See page 4; Ventura pages 1 – 2; Benavidez page 1.

21. It was not standard procedure for dog handlers to submit their training records through their chain of command. Instead, they typically kept their own records. In bringing forward their complaint and during the course of this investigation, each of the west side dog handlers proved they also attended and fully participated in the dog team training. See pages 18 – 22, 25 - 26; packet from described on page 7 and held in investigation file; pages 10 – 17; packet from Brockamp held in investigation file described on page 2 above.

E. Certification was obtained by an east side handler at the conference; one west side handler was already certified; and two west side handlers elected not to certify.

22. Inspector 2 dog handler on the east side, , who was not certified, went to the OPCA conference on Sunday, September 21, to test. He successfully certified. See page 7; page 4.

23. West side handler was still 1-year certified from his April 14, 2014 successful testing and did not plan to test at the OPCA Conference. Mr. Williamson and Deputy Laney, at the

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time of the September conference, did not recall his previously certified status. See paragraph 11, above; Williamson testimony page 12.

24. Inspector 2s and , both west side handlers, did not intend to test at the OPCA Conference because they judged it was not a good venue for testing contraband dogs that are trained to detect cell phones and tobacco, which are otherwise legal outside the prison walls. Contraband testing is better arranged separately from testing for dogs trained specifically to detect only illegal substances and they had never before tested contraband dogs at an OPCA Conference. See , page 7; page 4; pages 8, 22.

F. None of the dog handlers brought spouses, significant others, or guests to the conference.

25. During this investigation, each dog handler answered my questions about wives or guests in their hotel rooms. It was the first time they had been asked these questions and the first time they knew their hotel invoices showed adult guests in their rooms. Each was startled to see the 2/0 beside the words “No. of Guests” and each insisted they brought nobody who stayed in their rooms. Each could not explain how their invoice would list 2 guests in their room and each said they never noticed it before I showed it to them. The weight of the evidence support a conclusion that no spouses or significant others attended the conference with the handlers. Per paragraph 21 above, all the handlers brought their dogs and fully trained in the practice scenarios with them. See pages 14 – 16; pages 15, 19 – 21, 23 – 24; 27 - 28; pages 10 – 13, 18 – 21.

G. Garrett Laney made assumptions, in error, about the certification status of specific handlers and whether guests attended with the handlers. He communicated his conclusions to Mr. Williamson.

26. By the end of September 29 or by early morning of September 30, 2014, Garrett Laney knew only dog team had certified at the OPCA Conference. He had forgotten

was already certified. He did not know or had never intended to certify. He was unhappy this certification opportunity had, from his perspective, been inexplicably neglected. At this point, Mr. Laney’s memory of events differs from the other witnesses who remember him discovering the hotel invoices of the west side dog handlers showed a second adult guest in each of their rooms; he remembers not noticing the “number of guests” detail when handling and processing the travel forms. These other witnesses also remember him communicating the “number of guests” detail with them. See Laney pages 2 – 3, 4; Ventura pages 2, 7 – 8; Williamson testimony page 10; Williamson correspondence pages 54 – 61; Benavidez pages 3, 21, 22.

27. The weight of the evidence supports that in the morning of September 30, 2014, Mr. Laney told Mr. Williamson what he believed was new information about the west side dog handlers: they had spouses or significant others with them at the OPCA Conference and none of the west side dog handlers certified with their dogs at the conference. See Laney page 3; Williamson testimony pages 2, 2 – 3, 4, 9, 13 – 16, 17, 30; Gower page 1; Ventura pages 8 - 9.

28. On September 30, 2014 at 8:38 AM, perhaps contemporaneous to Mr. Laney explaining what he believed to Mr. Williamson, Mr. Laney and Emily Benavidez received additional e-mail information from showing he attended the OPCA training and reminding them he was already certified. Ms. Benavidez incorrectly thought it was an outdated certification. See Williamson testimony pages 10 – 11; Laney page 3; Benavidez pages 2, 6 - 7.

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H. Mr. Williamson communicated the inaccurate information from Mr. Laney to other high-level staff and used the phrase ‘wives and not their dogs’ to describe the alleged conduct attributed to the handlers.

29. On September 30, 2014, Mr. Williamson communicated to Mitch Morrow the news he heard from Mr. Laney about the west side dog handlers bringing their spouses and not getting certified. Mr. Williamson states Mr. Morrow told him to present what he had to Policy Group that morning.3 “We need to talk about this at round table today. This has gone on long enough.” See Williamson testimony pages 9, 30; (Morrow page 19, Question 2, is not clear; clarification was sought and not received).

30. On September 30, 2014, before the 9:30 AM Policy Group meeting, Mr. Williamson explained what he understood of the dog handler situation to Assistant Director of Operations Mike Gower. This conversation is identified as the first time a witness heard Mr. Williamson say words to the effect that the dog handlers brought wives and not their dogs to the OPCA Conference. See Gower page 1.

31. On September 30 at 9:22 AM, Ms. Ventura received the new information showing was already certified. See Ventura pages 1 – 2.

32. The Policy Group agenda for September 30, 2014 showed the meeting scheduled to start at 9:30 AM and Mr. Williamson was not on the agenda to address the development he raised with Mitch Morrow. See Williamson correspondence page 24.

I. Mr. Williamson attempted to verify the information from Mr. Laney just prior to informing Policy Group of the alleged circumstances, did not receive any confirmation from Laney or staff, but presented the information anyway and without qualification.

33. Mr. Williamson’s September 30, 2014 Policy Group talking points were not based on a prepared report, as had been the case in April when he provided a 6-month status update on the dog program. He had not gathered any information directly from dog handler staff. The materials he relied upon for the briefing included six e-mails recounting a brief chronology of events, then three pages of items relating to the OPCA Conference, and then four hotel invoices indicating the west side dog handlers had two adults in their rooms, while had a dog-accommodating room and no additional guest. See Williamson testimony pages 19 – 29, 30, 31; Morrow pages 4 – 16.

34. Mr. Williamson, while attending the policy group meeting, continued to communicate with staff via mobile device to ascertain what had occurred at the OPCA training. Most notably, at 10:55 AM he asked, “Looking at these hotel receipts it looks like only had a pet friendly room and that the other three were not but had a human guest. Is that correct? Do we know for certain all 4 dogs went?” Mr. Williamson told me he never got an answer to this question and another similar one. There is no evidence he re-sought the answers at a later time. See Williamson testimony pages 13 – 18; Ventura page 3.

3Further detail on the role of then Deputy Director Mitch Morrow is available in the citations below. In addition, I sought direct information about his role, if any, bringing about the otherwise unplanned September 30, 2014 presentation by Mr. Williamson to Policy Group a month before the 6-month dog program trail period was scheduled to end. Mr. Morrow did not provide that clarification. See Peters page 1; Laney page 5; Gower page 2; page 8; Williamson testimony page 3, 9, 30, 35 – 37; Williamson correspondence pages 35 – 36; Morrow pages 18 - 22.

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35. The September 30, 2014 Policy Group meeting is the second reported instance witnesses recall hearing Mr. Williamson state words to the effect that dog handlers brought wives and not their dogs to the OPCA Conference. (The first was in conversation between Mr. Williamson and Mr. Gower just prior to the Policy Group meeting. See para. 30) Mr. Williamson does not recall saying those words; he recalls trying to explain the information. At this meeting, Mr. Williamson also informed the Policy Group, erroneously, that none of the west side dog handler teams were certified. The effect in this forum was strong. “I was shocked that, even though the handlers knew they were supposed to bring their dogs with them to the training, they choose to bring their wives instead.” “That comment about bringing their wives instead of their dogs had a very strong impact. It tipped the group.” “Why wouldn’t they bring their dogs?!” See Bergen pages 1 – 7; Jeske page 2; Gower page 2; Williamson testimony page 5, 9, 15, 16, 17, 29, 30, 31; Williamson correspondence pages 45 – 46.

36. Mr. Laney, Ms. Ventura and Ms. Benavidez did not know Mr. Williamson was providing information about what had occurred at the OPCA training to Policy Group on September 30, 2014 and did not know until sometime later, most likely during the last week of October, such a presentation had been made. See Laney pages 3, 4; Ventura pages 6 – 7; Benavidez pages 2 – 3; Williamson testimony page 31.

37. On October 1, 2014, Garrett Laney and Inspector 2 dog handler had a causal conversation during a break at an all-OIG staff gathering. Their memories of the conversation differ in some details, but agree Mr. Laney said to words to the effect, “You were certifying while they were going to the beach,” or, “You were certifying while they were going to the beach with their wives.” Mr. Laney also remembers saying, “Why couldn’t they do the certification also? There’s no excuse.” says he attempted to correct Mr. Laney’s seeming misunderstanding, wanting to tell him there were no wives present and everybody trained, but Mr. Laney didn’t want to hear what had to say. See page 5; Laney pages 3 – 4.

38. Mr. Laney said he was not present for Mr. Williamson’s harsh comments to many OIG staff on October 2, 2014 (see Addendum report) but he was aware of what happened and his working relationship with Mr. Williamson began to sour at this point. See Laney page 3.

J. Directive from then deputy director Morrow to Mr. Laney, in Mr. Williamson’s presence, to hold the handlers accountable for their alleged conduct at the conference.

39. Mr. Laney was directed by Mr. Morrow, in Mr. Williamson’s presence, to hold Inspectors , and accountable for not having their dogs certified; this directive was given

at an unspecified time after the OPCA conference. See Williamson testimony pages 3, 6 – 7, 14; Peters page 1.

40. On October 8, 2014, Mr. Laney had his final scheduled check-in meeting with the dog handlers for the six month evaluation period. He was not aware Policy Group had already voted to recommend the dog program be shut down. He asked his questions about why the west side dog handlers did not certify and only then understood none of them had done anything wrong when attending the OPCA training in September. See page 8 - they expect to complete their 6-month period through October; pages 27 – 29; page 22; Laney pages 3, 4.

K. The director is presented with inaccurate information regarding the alleged conduct of the handlers and acts to shut down the program based on it.

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41. Director Peters had two conversations with Mr. Morrow in October 2014 about the Policy Group recommendation to end the dog program. The first was an impromptu meeting in Mr. Morrow’s office which included Mr. Williamson and then a one-to-one conversation between her and Mr. Morrow at a later time. Director Peters remembers the strong impact when she heard words to the effect, “In addition to the poor return on investment, the dog handlers showed blatant disregard by bringing their wives and not their dogs to the OPCA Conference. For all we know, it was a party at the beach.” She stated this information tipped her thinking on continuation of the program and caused her to shut it down. This is the third reported occurrence of a witness hearing words to the effect, “wives and not dogs,” in connection with the dog handlers attending the OPCA Conference. See Peters page 1; Williamson testimony pages 31 – 32, 33; Morrow pages 19 – 20.

L. News of a decision to shut down the program surprised the handlers who were as yet unaware of the alleged conduct that had been attributed to them.

42. The weight of the evidence supports that during the last week of October, 2014, Mr. Laney’s Executive Management Team learned the dog program would be ending. They each heard differently the role of the Policy Group vote. Each of them thought the Policy Group vote had occurred near to the time they were hearing this news, causing some of them to infer it had been a decision made by the Policy Group. None of them heard the Director had decided to shut down the dog program. See Laney page 4; Ventura page 7; Benavidez page 3.

43. When Mr. Laney heard the dog program was ending he was surprised because he was under the impression that the 6-month evaluation period would be concluded before there was a decision. He described feeling resignation. “It is what it is. I’ve been through things like this before. The decision has already been made; Policy Group voted; just carry it out.” See Laney page 4.

44. On November 5, 2014, the dog handlers met with Mr. Laney in person except attended by phone. They were told the dog program had ended and were given letters explaining its termination. There was little discussion. The negative emotional impact on the dog handlers was profound; they had been doing their dream jobs and thought the 6-month trial period went well. See page 1; pages 2, 12; page 5; page 5.

M. A mid-level manager, concerned to hear the allegation of ‘wives and not dogs’, as used by Mr. Williamson, counseled dog handler and discovered the allegation was not true. To date, Mr. Williamson never pursued the answer to his September 30th question about the true status of wives and dogs at the OPCA Conference.

45. On November 12, 2014, at a Security Threat Management (STM) meeting at Two Rivers Correctional Institution, a fourth reported instance of witnesses hearing “wives and not dogs” occurred. Upon hearing Mr. Williamson use those words to explain how the dog program came to an end, the effect among listeners was described as shock and awe at how blatant the dog handler behavior had been; a belief there had been a plush get-away at the beach at State expense; and silence around the conference table. Mr. Williamson does not recall this conversation. See page 1; page 1; Laney page 4; Williamson testimony pages 32 – 33; page 1.

46. was among those who heard Mr. Williamson’s comments about the dog-handlers alleged behavior at the OPCA conference. On November 18, 2014, he counseled Inspector

with an objective that would understand how to better conduct himself in the

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future. was surprised to learn from the information in Mr. Williamson’s statements at the TRCI STM meeting was not true. In support of his position, provided a copy of his detailed dog scenario training records. See page 8; page 1 – 2; page 6.

47. Two days later, on November 20, spoke to Garrett Laney about what he learned from . asked Mr. Laney, “Why would Mr. Williamson say the nail in the coffin for

the K9 program was when they took their wives to the conference and didn’t take their dogs?” Mr. Laney responded he didn’t know why Mr. Williamson would say that. See page 2;

page 1; Laney page 4.

48. Mr. Laney, when asked about that conversation with stated, “I really didn’t know why Mr. Williamson said the ‘wives instead of dogs’ comment in that setting, but I didn’t want to say anything to about my thoughts because I was trying to protect my boss and keep stories from spreading or getting worse.”

49. On November 20, 2014, told what Mr. Laney said. This was the genesis of the dog handlers learning they had been inaccurately and negatively represented. They discussed their situation and initially did not know what to do. They did not believe they could complain up the chain of command while Mr. Morrow, though retired, was still temporarily in office. Late in 2014 or in January 2015 they went to AFSCME and spoke to Tim Woolery, who agreed it would be better if he represented them and if he approached upper management after Mr. Morrow left. See paragraph 47; pages 8, 12; page 8.

50. Sometime after November 20, 2014, was in Mr. Williamson’s office discussing dog handler data. remembers believing the data used to explain the dog handlers’ lack of productivity was flawed. At some point in the conversation, Mr. Williamson said, “ , what am I supposed to do when they take their wives instead of their dogs to the training?” This is the fifth reported occurrence of a witness hearing words to this effect. See page 4 – 5.

N. Events of 2015 leading to initiation of investigation.

51. Mitch Morrow’s last day was January 31, 2015. On February 2, AFSCME Representative Tim Woolery met with Kim Brockamp about the dog handlers’ complaint. He was told upper management would make contact with the dog handlers. In April, each was able to meet with Director Peters. See page 1; pages 8 – 9; page 6; Peters page 1; Tim Woolery e-mail communication in investigation file.

52. On or about March 18, 2015, Mr. Laney said to in the presence of , and Emily Benavidez, “At least I’m not an asshole,” referencing being in charge during

Mr. Williamson’s vacation absence. Mr. Laney told me he was disgruntled with Mr. Williamson’s people skills when he made that comment. This comment came several months after Mr. Laney’s belief that his relationship with Mr. Williamson had turned at the beginning of October 2014. See paragraph 38 above; page 13; Laney page 5.

O. Some seven months after first using the phrase ‘wives and not their dogs’ with various stakeholder groups and in the context of a complaint, Mr. Williamson quietly inquired about the hotel invoices showing ‘guest’ status and if the dog handlers had certified and trained with their dogs at the OPCA Conference.

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53. Following the specific complaint by the dog handlers in April 2015, Mr. Williamson was instructed by Director Peters to back away, “manage the OIG from 40,000 feet,” and allow Mr. Laney to run the daily operations while facts were being assessed. In May, Mr. Williamson sought to verify what he thought he knew about the OPCA Conference. On May 8 Emily Benavidez was unable to learn from the hotel if there were two guests in the rooms in question. Mr. Williamson then asked his west side deputy, Rebecca Krueger, to ask if there were any wives or significant others at the OPCA Conference. When told, “No!” he concluded the guest information on the invoices was apparently incorrect because was a firsthand witness and his word is much trusted. In the meantime, Marica Ventura sought the training and certification records from the OPCA who did not fully cooperate with her, replying on May 22, “I don’t release records to anyone arbitrarily when I don’t know them or unless they have a subpoena.” It appears that when Mr. Williamson knew an investigation was imminent, he sought the answers to the very questions he originally had on September 30, 2014, while he was awaiting his turn to speak to Policy Group. See Williamson testimony pages 7, 18, 34; page 9; Ventura pages 9 – 11; Benavidez page 4.

54. Only during our investigative conversation on August 6, 2015 did Mr. Williamson learn the dog handlers brought their dogs and performed practical training at the September 2014 OPCA Conference. See page 10; Williamson testimony pages 7, 17; Ventura pages 9 – 11; Benavidez page 4.

55. Only during the investigative conversation on August 6, 2015 did Mr. Williamson learn that detection dogs are not certified; rather, the team of the staff and the dog are certified. See Williamson testimony pages 3, 4, 6, 10 – 12, 16; Williamson correspondence page 53.

56. Mr. Williamson never held the dog handlers accountable for any wrongdoing he believed had occurred, despite his statements about them on at least five occasions, or follow up on the assignment given to Mr. Laney to hold the handlers accountable for their conduct. See Peters page 1; Williamson testimony pages 3, 6 – 7, 14; paragraph 39.

57. When Mr. Williamson was asked what he would do differently about the ending of the dog program if he could, he explained the following (see Williamson testimony page 34): “I think I would have vetted the hire of Mr. Laney a little better. This program was turned over to Deputy Laney to manage. The representations that you've heard about the facts came from Garrett Laney. Let's assume you are correct, and people's recollection of a statement of me at STM meeting was correct. Mr. Laney sat there, providing me that information, telling me about them taking their dogs or their spouses. He never once corrected any of those impressions. That's what he told me as truth. So in terms of reevaluating what I would or wouldn't do, and I said in my written statement people don't double check their deputy's work, I have no reason to. As you have described some of this stuff to me about what he knew in terms of e-mail traffic and stuff, I'm, I'm really shocked.” “The only other thing that I might have done different is maybe push back on Mr. Morrow the morning of the 30th and said hey, uh, we agreed to 6 months, let's put a written report together, or maybe insisted that Mr. Laney actually go through the discipline process with these guys. A lot of this stuff probably would have come out. The certification stuff would have come out I think, if he tried to discipline them.”

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“I mean, at the level of the agency that I'm at, I rely on people to provide me truthful, reliable information. And to the best of my recollection that's what I passed on.”

ANALYSIS:

The information that led to Mr. Williamson using the turn of phrase “wives and not dogs,” appears to be a conversation between himself and Garrett Laney the morning of September 30, 2014, which occurred prior to a Policy Group meeting that Mr. Williamson regularly attends. While Mr. Laney does not remember having this conversation, evidence indicates he told Mr. Williamson that the individual hotel invoices for the west side dog handlers, which included , , and

, who had attended an Oregon Police Canine Association (OPCA) Conference in Newport, Oregon, days earlier, showed “2/0” for “No. of Guests.” He also noted that the west side dog handlers

r, and ) did not certify with their dogs at the OPCA Conference. See paragraph 27. On five occasions explained below, Mr. Williamson was heard by DOC employees saying words to the effect that dog handlers brought their wives and not their dogs to the OPCA Conference. These words profoundly impacted the hearers, causing them to think negatively of the dog handler program and the handlers’ professional judgment. See paragraphs 29, 30, 35, 41, 45, 46, 47, 48, 50. After speaking with Mr. Laney on the morning of September 30, 2014, Mr. Williamson communicated that information to then Deputy Director Mitch Morrow, using words to the effect the west side dog handlers brought their spouses to the OPCA Conference and did not get certified. In response, Mr. Morrow told Mr. Williamson to present the information at a Policy Group meeting scheduled for that morning. See paragraph 29. The first reported use of the phrase “wives not dogs” came after Mr. Williamson spoke with Mr. Laney, but prior to his attending the Policy Group meeting that morning. Mr. Williamson spoke with Mike Gower, Assistant Director of Operations and the dog program’s primary customer, who recalled him saying words to the effect the west side dog handlers brought their “wives and not dogs” to the OPCA conference. See paragraph 30. Implicit in using this phrase, it appears Mr. Williamson had concluded: 1) that three of the hotel invoices, which showed “2/0” guests per room, were accurate; 2) that the additional guests were the handlers’ wives; and, 3) these handlers did not bring their dogs. Although unknown to Mr. Williamson at the time his used the phrase “wives and not dogs,” none of the conclusions that would support the phrase were accurate. To the contrary: 1) none of the dog handlers had guests staying in their rooms; 2) no spouses were present; and, 3) the handlers brought their dogs.

While attending the Policy Group meeting and prior to addressing the dog handlers topic, Mr. Williamson made his only attempt to verify the accuracy of the information. He communicated electronically with staff, to clarify what Mr. Laney told him earlier that morning. He inquired, “Looking at these hotel receipts it looks like only Troy had a pet friendly room and that the other three were not but had a human guest. Is that correct? Do we know for certain all 4 dogs went?” See paragraph 34. At the time of the requests, his staff were unaware he was intending to present at Policy Group that morning, on that very topic. See paragraph 36. Mr. Williamson did not receive a response from staff prior to his presenting to Policy Group and did not double back with them, at any time following the meeting, to determine the accuracy of the information on the hotel invoices. See paragraph 34.

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The September 30, 2014 Policy Group meeting is the second reported instance Mr. Williamson used words to the effect, wives and not their dogs. Mr. Williamson does not recall saying those words; he remembers trying to explain the information. At this meeting, Mr. Williamson also informed the Policy Group, erroneously, that none of the west side dog handler teams were certified.4 The statements had a forceful effect on Policy Group regarding the integrity of the handlers and struck at the core of the program.5 See paragraph 35. If on September 30, 2014, Mr. Williamson did his best to present, in light of urging from the deputy director, what he thought he knew to Policy Group, despite little preparation time and the uncertainty expressed in his e-mails to staff during that meeting, it is possible he chose to align his subsequent statements in other forums to that which he presented to Policy Group. This could explain why Mr. Williamson never sought to subsequently verify if the information about the handlers bringing their wives and not their dogs was accurate. Had he pursued responses to his questions immediately following that presentation, with limited inquiry, he would have learned the information he presented to Policy Group was not accurate. Following the Policy Group meeting, sometime in October 2014, director Peters had two conversations with then deputy director Mitch Morrow. One of them included Mr. Williamson. See paragraph 41. At the time of these exchanges, Mr. Williamson had not verified whether the handlers brought their wives or if they trained with their dogs. Director Peters remembers hearing words to the effect, “the dog handlers showed blatant disregard by bringing their wives and not their dogs to the OPCA Conference. For all we know, it was a party at the beach.” This is the third reported occurrence of a witness hearing words to the effect, wives and not their dogs. While it is possible Mr. Morrow made this particular statement instead of Mr. Williamson, and that some discussion on the subject may have occurred in a 1:1 discussion between Mr. Morrow and Ms. Peters, the source of this information tracks to Mr. Williamson’s representations on September 30, 2014 to Mr. Morrow directly and subsequently to the Policy Group. The inaccurate information had the same powerful impact on Ms. Peters as it had on Policy Group; it tipped her thinking on the value of the program and caused her to shut it down. See paragraph 41. Mr. Williamson addressed the discontinuation of the program at a November 12, 2014 Security Threat Management meeting at Two Rivers Correctional Institution. Witnesses heard Mr. Williamson refer to the dog handlers’ actions at the OPCA conference as the nail in the coffin of the dog program; why should I keep the dog program when they take their wives instead of their dogs; at least two didn’t take their dogs, but did take their wives and their dogs weren’t certified. See the citations supporting paragraph 45. This is the fourth reported occurrence of witnesses hearing word to the effect, wives and not their dogs.

On or after November 20, 2014, an Inspector 3, , was in Mr. Williamson’s office discussing dog handler data. remembers believing the data used to explain the dog handlers’ lack of productivity was flawed and was explaining this to Mr. Williamson. Sometime during the conversation, Mr. Williamson said, “ , what am I supposed to do when they take their wives instead of their dogs to the training?” This is the fifth reported occurrence of a witness 4 Of the west side teams, one of the teams had already certified earlier that year in April 2014. Mr. Williamson was part of an e-mail thread with that handler, where the handler reported close in time to the certification that he was successful. Mr. Williamson praised him in response, but had forgotten this information by September 2014. The other two west side teams, while they brought their dogs to train, did not attempt to certify because, in the judgment of the handlers, the venue was not the best forum for certifying contraband trained dogs. 5 Director Peters and then deputy director Morrow did not attend the Sept. 30, 2014 Policy Group.

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hearing words to this effect. See paragraph 50.

Mr. Williamson did not hold the dog handlers accountable for any wrongdoing he believed had occurred, despite his negative statements about them on at least five occasions, nor did he follow up on the assignment given to Mr. Laney to hold the handlers accountable for their conduct. See paragraph 56. Though Mr. Williamson’s division numbers approximately 55 employees, he never made it a priority to track the disposition of a review of an incident involving three employees whose alleged behavior caused hearers to be shocked with how blatant it had been. He never asked Mr. Laney, “What became of your corrective action with the former dog handlers?”

Mr. Williamson offered a perspective during the investigation about what he would do differently. See paragraph 57. In part, he placed blame on Mr. Laney for giving him inaccurate information and never correcting it. He appears to deflect individual responsibility as the Inspector General for what happens among staff that directly or indirectly report to him when he concludes, “I mean, at the level of the agency that I'm at, I rely on people to provide me truthful, reliable information. And to the best of my recollection that's what I passed on.” Yet, as he was about to pass the information about the alleged incident at the training to Policy Group, he urgently sought to clarify the basic facts he did not understand about wives and dogs, and then after the presentation, inexplicably never sought those answers until he knew he was to be investigated. See paragraph 53.

Mr. Williamson attributing fault to Mr. Laney for poor communication with him on the subject (see paragraph 57) is only partially accurate, based on the evidence assessed in this review. The evidence shows the responsibility for the lapse in communication was at least mutual in the following particulars: a) Mr. Williamson never told the employees who were gathering dog handler information that he was presenting at Policy Group on that very subject on September 30; b) Mr. Laney never answered Mr. Williamson’s e-mailed question about wives and dogs asked during the September 30 Policy Group meeting; c) Subsequent to the Policy Group meeting, Mr. Williamson never followed up with Mr. Laney to get an answer to his question about wives and dogs; d) Mr. Williamson never told his staff Policy Group voted to recommend closing the dog program until about a week before the closure letters were given to the dog handlers; e) Though by October 8, 2014, Mr. Laney understood there had been no wrongdoing by any of the dog handlers in how they conducted themselves at the OPCA Conference, there was never a conversation with Mr. Williamson about the status of the facts6; f) After Mr. Laney heard the dog program was being shut down, he did not communicate anything he knew which he may have been saving for a 6-month evaluation of the program because he felt resigned. “It is what it is. I’ve been through things like this before. The decision has already been made; Policy Group voted; just carry it out.” There is no evidence he knew the Policy Group decision was influenced by a reaction to “wives and not dogs” at the OPCA conference because he was not told about the Policy Group presentation event. Beyond his stated observations about Mr. Laney’s role in how the incident played out, Mr. Williamson offered this limited reflection on his own accountability (see paragraph 57): “The only other thing that I might have done different is maybe push back on Mr. Morrow the morning of the 30th and said hey, uh, we agreed to 6 months, let's put a written report together, or maybe insisted that Mr. Laney actually go through the discipline process with these guys. A lot of this stuff probably would have come out. The certification stuff would have come out I think, if he tried to discipline them.” I agree. 6 It is possible Mr. Laney deferred his communication with Mr. Williamson because he was waiting for the whole program to be evaluated at the end of October ; at the time, he was unaware Policy Group had already recommended closure of the program.

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ISSUE TWO, COMPLAINT: Initiation of Investigation…………………………... page 18

Context of Investigation and statement of allegation page 19

Summary…………………………………………….pages 19 - 20

Findings with citations to appendices……………….pages 20 - 28

Credibility.………….……………………………….pages 29 - 31

Conclusion…………………………………………..pages 31 - 32

testimony and follow up………………Appendix 1 Inspector 2, Dome testimony and follow up………...Appendix 2 Inspector 3, Coffee Creek Correctional Facility Jeanine Hohn correspondence………………………Appendix 3 Administrator, Professional Development Unit testimony and follow up...………………Appendix 4 Principal Executive Manager D, HR Operations

Colette Peters testimony…..………………………...Appendix 5 Director, Oregon Dept. of Corrections

Leonard Williamson testimony……….…………….Appendix 6 Inspector General, Dome Leonard Williamson correspondence………….……Appendix 7

Mitch Morrow correspondence……………………..Appendix 8 Former Deputy Director, Dept. of Corrections

INITIATION OF INVESTIGATION:

Following consultation with the Department of Justice, on June 12, 2015, DOC Deputy Director Kim Brockamp assigned me to investigate two allegations regarding the conduct of Inspector General Leonard Williamson. See page 3 above for further detail. On June 12, 2015, after our meeting, Ms. Brockamp sent an e-mail to explaining I was assigned to investigate her concern. It was copied to me, AFSCME Steward Janae Davis-Saunders, and Director Peters. At or around the same time, she also communicated this information to Leonard Williamson. Ms. Brockamp gave me some starting materials:

o E-mail dated April 15, 2015 from Leonard Williamson to Kim Brockamp, explaining a memo dated September 2, 2013 he prepared for Mitch Morrow about describing issues with truthfulness, following direction, failure to support Office of the Inspector General managers and failure to exercise good management judgment. (This item is displayed in the Williamson correspondence appendix.)

o E-mail dated August 22, 2013 from to Leonard Williamson, Subject DRAFT, Attachment Intel Office relationships.docx, with the 1-page attachment. (This item is displayed in the Williamson correspondence appendix.)

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o E-mail dated August 23, 2013 from Mitch Morrow to , Cc to Leonard Williamson and Jeanine Hohn, Subject FW:DRAFT, Attachment Intel Office relationships.docx. (This item is displayed in the Williamson correspondence appendix.)

o E-mail dated April 8, 2015 from to Kim Brockamp, Subject Document, Attachment Scanned from DO2SAX.pdf. (This item is displayed in the appendix.)

CONTEXT OF INVESTIGATION AND STATEMENT OF ALLEGATION TWO:

alleges Mr. Williamson was untruthful during an August 1, 2013 meeting when he

allegedly cited her as someone who had made complaints about and . She further claims on August 12, 2013, he apologized to her for doing this and explained he had done so to see if the information would leak back to him. She believed he was being truthful with her and his apology satisfied her. She proceeded to have a positive working relationship with him.

explained why she brought forward her complaint after the issue was seemingly resolved and so much time had passed:

“Mr. Williamson has a repeated pattern of poor behavior. The Office of the Inspector General should be run at a higher standard; we are like the police of the agency. I’m almost ashamed to be in our unit. There are instances of sworn officers losing their jobs and certification for engaging in the same type of unethical behavior and lying. I finally said, ‘Enough.’ The last straw was hearing what was said about the dog handlers after the program ended. My responsibility to come forward and report is greater than my responsibility to my chain of command, according to what the director put out about having no code of silence in DOC.”

believed if she did not come forward with her information, it would be as if she was

breaking the DOC Code of Ethics. She believed Mr. Williamson’s behavior should make him unsuitable to give courtroom witness testimony, citing the material she sent Ms. Brockamp April 8, 2015, referenced on page 2 above. See Appendix 1, pages 1, 13 - 16 for further context.

SUMMARY:

The investigation revealed Mr. Williamson held a meeting with and to highlight that some staff members they supervised were dissatisfied with their performance, and to protect the identities of those who actually complained about their performance. It is clear did not complain to Mr. Williamson about the performance of her supervisors. However, Mr. Williamson appears to have erred either by choosing to name as a specific complainant to see if the information would get back to him or by causing confusion with how he spoke such that

and heard that specifically complained about them. Mr. Williamson claims he never named a specific complainant but merely listed among many staff members who could have complained. In either event, the naming of elicited an emotional reaction from and and subsequently caused to believe Mr. Williamson had been untruthful to tell them she complained about them. Partially due to two year old memories and emotions of the first hand witnesses, the truth of what Mr. Williamson said to and in the corrective conversation is not certain, though available evidence favors version of events – that Mr. Williamson named her as a complainant and subsequently apologized to her for doing so. Her version more closely aligns with the

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available evidence than Mr. Williamson’s stated refutation. Regardless of whether Mr. Williamson named as a complaint or if he was misunderstood, his very method of approaching the presumed corrective opportunity caused deep employee relations problems with at least three staff. Therefore the findings in this report shed light on Mr. Williamson’s management style in one instance. It was beyond the scope of this assignment to ask Mr. Williamson why he did not take a different managerial approach to addressing complaints he heard from staff about and , such as having one on one coaching sessions or developing individual work plans to improve their performances. However, Mr. Williamson’s method of handling a discrete issue involving the alleged performance of the two supervisors resulted in consequences that, while they may have been unanticipated at the time to Mr. Williamson, when viewed in hindsight, raise concern with the management approach he applied. The approach perpetuated a trust and integrity concern in how they viewed Mr. Williamson and his leadership of the Inspector General’s office.

FINDINGS:

Explanation of format: See page 6 above. 1. Mr. Williamson convened a meeting on August 1, 2013 with two managers in his chain of command, and , to discuss the work environment and staff concerns. Background events leading to the meeting: On July 12, 2013, sent , copied to and Gloria Parra, a large-font thank you message. was her direct supervisor at the time. told me she sent it to encourage the three recipients during a time of struggle. See page 4. Mr. Williamson states during the third week of July 2013, sent him an e-mail expressing he felt disconnected from Mr. Williamson and work. Mr. Williamson replied and advised they would get caught up upon Mr. Williamson’s return from vacation. Mr. Williamson states during the fourth week of July 2013 he received complaints from two OIG staff about and

hiding out in their offices, being checked out, not engaged and not giving any direction to staff. Mr. Williamson decided to schedule a meeting with them. See Williamson testimony page 2.

On August 1, 2013, Jeanine Hohn, then Deputy Inspector General, sent Outlook invites to , Gloria Parra,7 and Leonard Williamson for a meeting in Mr. Williamson’s

office. Upon receiving the invitation remembered thinking, “This can’t be good,” because the meeting was mandatory and required changing other appointments. He had a good memory of how the participants were arranged in Mr. Williamson’s office and drew a diagram. See pages 1 – 2;

pages 1 – 2. Events at the August 1 meeting as recalled by :

remembered the first topic focused on Mr. Williamson stating he felt much disrespected because nobody acknowledged him when he walked in while a meeting was in progress recently. Mr.

7 Ms. Parra was unable to attend. The weight of evidence indicates Ms. Hohn was present at the beginning of the meeting for an initial topic but not for the second portion. She has no memory of the event. See pages 1 – 2; page 2; Hohn pages 1 – 2.

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remembered Mr. Williamson saying words to the effect, “I’ve never been so disrespected in my entire career. I was so disgusted, I left.” See page 2 for further detail.

remembers the second topic concerned staff who report to himself and being described as unhappy with them. He recalls Mr. Williamson saying words to the effect, “You’re not doing your jobs, staff aren’t happy, and even is complaining about you, .” felt dumbfounded when he heard this. He does not remember what Mr. Williamson said about the nature of the complaint, beyond simply identifying as having complained. The way Mr. Williamson used the word “staff” caused to believe more than one staff complained. He remembered hearing named as a specific complainant earlier in the conversation. See pages 2, 5, 6.

said Mr. Williamson cited as a source of the complaint without any prompting. “He just said it.” Upon second reflection, he was very certain he never asked Mr. Williamson who had complained and did not remember Mr. Williamson being asked who had complained, but said it was possible had asked who complained. See pages 3, 5, 6.

I asked if during the course of the conversation Mr. Williamson said something like, “It could have been any staff in this building – , , , ,

, , .” Did Mr. Williamson list off all the names of all the Inspector 2s? said, “No, he did not do that.” See page 5.

does not remember any admonishments by Mr. Williamson to himself and that they were not to discuss the complaint with , or keep the topic in the room; “Nothing like that.” See page 3. Events at the August 1 meeting as recalled by :

remembered the first part of the meeting was about Mr. Williamson feeling disrespected because he wasn’t acknowledged when he came into an earlier meeting. “We were working hard on a Power Point presentation right then; we didn’t mean any disrespect.” See

page 7. For the second topic, recalls with certainty that Mr. Williamson told himself and

that had made complaints about them. He did not remember what the complaints were but said he was “taken aback because is a go-to person; I had a good working relationship with her. I was shocked. I couldn’t believe it. I was speechless.” described feeling his head was spinning in reaction to the news; he had much emotion. See pages 2, 8. Reinforcing his surprise with the news and the timing of a complaint being attributed to her,

identified an e-mail exchange with just a few weeks earlier on July 12, 2013. It didn’t make sense to him that she would express sincere and kind sentiments but simultaneously complain to Mr. Williamson about his management style. He provided the investigator an e-mail from August 5 and two from August 6, 2013, both from , which also supported his conclusion that he believed he and had a good working relationship. See pages 3 - 5.

could not remember if they were told was the only person who complained or if more than one staff had complained and she was the only one named. I asked if ever during the course of the conversation Mr. Williamson said something like, “It could have been any

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staff in this building – , , , , , , .” Did he list off all the names of the Inspector 2s? said

he didn’t think so, but couldn’t say with certainty. See pages 7 - 8. When questioned whether he prompted Mr. Williamson to identify the name of a complainant,

initially had no memory of doing so. He said he believed such action would have been counter to how he handles himself, reasoning that if Mr. Williamson had not said who complained, he would not have asked, stating, “If I was him, I wouldn’t want to be asked my source if I didn’t want to reveal it.” When asked at a later time if he and/or asked Mr. Williamson who complained about them, his memory was different. “Yes, we asked that question because we were shocked to hear there had been a complaint about us.” See pages 5, 8.

said Mr. Williamson did not reveal name at that time but steered the conversation toward the complaint. He said she was named near the end of the conversation and then they were told not to talk to her. “ and I were frustrated and didn’t know what to think. Mr. Williamson told us to not go back and talk to .” See pages 5, 8.

said he obeyed. Mr. Williamson’s directive to not talk to stuck in his mind because he believed it reflected a technique Mr. Williamson had used in the past, which left a negative impression with . That technique involved providing information, citing a source, and then instructing the recipient not to say anything to the source. believed such technique was employed to bait staff into sidebar conversations among themselves so that Mr. Williamson could determine who among his staff was disseminating information, once the information circled back to him. See page 5. Events at the August 1 meeting as recalled by Mr. Williamson: Mr. Williamson stated he took no notes on the August 1, 2013 meeting, but has a general memory of what occurred, which he summarized in the following excerpt from his written statement. From Williamson testimony pages 2 – 3:

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2. Conversations following the August 1, 2013 meeting, referencing staff complaints about

and . On an unknown date, Mr. Williamson and Mitch Morrow discussed a ‘counseling session’ Mr. Williamson had with and about staff complaints: This was the first of two conversations Mr. Williamson had with Mr. Morrow about the August 1, 2013 counseling session. When Mr. Morrow was asked what he remembered about Mr. Williamson’s August 1 counseling of and , he wrote: “Not much. I understand there were staff complaints about their leadership of the unit. Mr. Williamson had counseled the two of them in hopes of re-directing their behavior. Mr. Williamson then briefed me, but I’m not remembering specifics.” See Williamson testimony pages 3, 4; Morrow pages 3, 5.

told she was identified by Mr. Williamson as a complainant: On August 1, 2013, within minutes of leaving the meeting, says he sought out and politely inquired if there was something going wrong or anything he needed to do differently. She appeared confused. He then explained that Mr. Williamson said she complained to Mr. Williamson about . told it was a lie. See page 3.

memory of the conversation is consistent with the recollection of . He asked if their working relationship was “alright.” She said it was and then learned from that Mr. Williamson told him and she was among several people who had complained that and were not communicating well with the Inspector 2s. told she never complained about him and described feeling upset this untrue statement had been attributed to her by Mr. Williamson. See page 1. On an unknown date, and spoke. In his testimony, after he explained Mr. Williamson told them not to talk to , he explained: “I know she heard about it. She was extremely upset, and for a long time. I don’t know who talked to her. I remember her saying, ‘He lied!’” explained she said he lied about her complaining to him about and

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; she insisted she made no complaint to Mr. Williamson about them. See page 5.

contacted Human Resources regarding her concern with Mr. Williamson’s representation about her. On August 6, 2013, sought guidance from Chris Popoff, Assistant Director of Human Resources, about her concern that Mr. Williamson had represented to and that she complained about them and that statement was not true. See pages 1 – 2; Popoff e-mail communication held in investigation file.

Within the next one to three days, on August 7, 8 or 9, 2013, was called to meet then deputy director Mitch Morrow in his office. reports Mr. Morrow said he heard from Mr. Williamson she had been complaining about poor work by Inspector 3s. She told him it was not true and it was not okay for Mr. Williamson to tell and she had complained about them. Mr. Morrow responded with words to the effect he didn’t think Mr. Williamson would lie about it and he encouraged her to speak with him directly. See pages 2, 9.

Mr. Morrow had limited recollection of the substance of his discussion with on the subject. See Morrow page 5. Mr. Williamson recalled Mr. Morrow briefing him after his conversation with . Mr. Morrow said that came to speak about the tone in the Inspector General’s office, staff had no faith in then deputy IG , and there were concerns about leadership. See Williamson testimony page 3. Mr. Williamson’s description of what Mr. Morrow told him occurred is contrary to recollection of the same conversation, in which she was a direct participant. 3. On August 12, 2013, spoke to Mr. Williamson about her concern that he misrepresented that she had complained about managers and . Meeting between and Mr. Williamson: According to she met Mr. Williamson in his office. Mr. Williamson agreed she had never made a complaint about and to him. He apologized to her for telling and that she had complained about them. Mr. Williamson explained he heard the Inspector 3s were sharing what was said in meetings with him with staff and he wanted to know if what he said to and in their August 1st meeting would get back to him. See

pages 2, 7 – 8. Mr. Williamson’s written statement explains his August 12, 2013 meeting with in some detail; the relevant content is excerpted below. See Williamson testimony page 3.

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Both Mr. Williamson and agree that she never complained to him about and and that he confirmed this for her in the August 12th meeting. Their accounts differ in that recalls a specific apology from Mr. Williamson for his having identified her as a complainant. Mr. Williamson similarly acknowledges an apology was extended by him, but for the behavior of and in confronting her, not because he identified her as a complainant.8

Conversations following the August 12, 2013 meeting between and Mr. Williamson: circled back to and following the meeting with Mr. Williamson.

She asked if Mr. Williamson had told him and not to talk about what was discussed in the August 1 meeting. He said no. In a separate conversation with , he recalls her explaining she had confronted Mr. Williamson about him citing her as a source of complaint. She told him Mr. Williamson said it had been a test to see if what he said to and would get back to him. See page 2; page 3.

On August 13, 2013, the day after her meeting with Mr. Williamson, e-mailed Mr. Morrow. She wrote, “I am closing the loop on our conversation and wanted to follow-up. Turns out the discussion I allegedly had with Leonard never happened. I’m glad to know that I’m not losing my mind.” See page 3.

Mr. Williamson met with Mr. Morrow after his meeting with . In his statement, he described a deliberate objective not to reveal the source of the complaints to and

. From Williamson testimony page 4:

8 The identities of actual complainants were not pursued as part of this investigation based on scope, which focused on whether was improperly identified as a complainant.

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In a written response submitted by Mitch Morrow, he recalled having a briefing with Mr. Williamson following Mr. Williamson’s August 12th meeting with . Mr. Morrow’s impression was that the conversation between them went well and they had ongoing interactions afterward. See Morrow page 5.

The day after submitting a written response for the investigation regarding his interactions with Mr. Williamson on the subject, Mr. Morrow followed up in writing, providing a much more detailed recollection of what Mr. Williamson had described to him about the approach used in the August 1st meeting with and . While Mr. Morrow does not identify when this described conversation occurred with Mr. Williamson, it likely followed Mr. Williamson’s August 12, 2014 conversation with because there would have been no apparent relevance in Mr. Williamson communicating such detailed information to Mr. Morrow about a technique he applied attempting to protect complainants’ identities, unless someone had complained:

“I do remember Mr. Williamson briefing me on part of his conversation with and , but only around a couple of points. The first I addressed in my previous answers too you (leadership concerns). The second point that I am remembering is his discussion around how (not recalling if he said the same about ) in the past had retaliated against staff who had raised concerns about his ( ) leadership, or lack thereof. He was worried that may happen again based on inquires during their meeting as to who had complained. Given the concern, Mr. Williamson informed me that in an attempt to protect the specific people who complained, he took a broad approach by indicating it was someone (indicating not all) on staff, then named all the staff (to protect those who did complain) and then instructed to not make any attempt to identify those who had specifically complained about him. He (Mr. Williamson) was clear to me that he did not name any one person as someone who had brought forward the complaints / concerns. In fact, I'm not even remembering who brought forward the complaint (although Mr. Williamson may have told me). I do recall telling Mr. Williamson that I had used that same technique (listing all names to protect the few) in the past as well. I understand that had confronted staff anyway, including , in an attempt to identify who had complained.” See Morrow pages 5, 6.

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4. Mr. Williamson’s reference to the August 1, 2013 meeting in a September 2, 2013 memo to then deputy director Mitch Morrow.

Mr. Williamson wrote a critical memo9 in response to a request from Mr. Morrow to provide examples of his working relationship with . The memo covers a range of matters not directly relevant to this inquiry. However, there is a paragraph on page 4 of 6 of the memo that describes the subject meeting on August 1, 2013 as follows (highlighting appearing in the original submitted by Mr. Williamson)10:

On its face, this statement appears to contradict Mr. Williamson’s position that he had not associated any specific staff with making complaints or offering feedback. I pointed this paragraph out to Mr. Williamson in my July 28, 2015 e-mail, along with other specifics, the day before our intended investigative conversation. I explained it comported with allegation that she had been identified as a complainant in the August 1, 2013 meeting with and . He requested and I granted an additional week to prepare. Mr. Williamson’s prepared statement given to me on August 6 did not address this “Example six” statement, despite it having been expressly identified by me in the manner described above. See Williamson correspondence pages 22 – 24. 5. Reemergence in April 2015 of concern with the August 1, 2013 meeting. Communication with the director: On April 2, 2015, decided to speak with Director Peters about her concerns with the Office of the Inspector General. Regarding the delay, she explained she would have acted sooner, but scheduling a time on the director’s calendar took many months and the appointment that was set concerned a different purpose. Additionally, she identified a last straw incident which prompted her to act was learning what was being said about the dog handlers after the program was ended. See page 5; Peters page 1. On April 16, 2015, had a second meeting with Director Peters. said she learned from Director Peters that Mr. Williamson, when questioned, told Ms. Peters, “I thought I had made this right with .” She recalls Ms. Peters summarizing her intervening discussion with Mr. Williamson, as follows: “She told me she asked Mr. Williamson about his conversation with and where I allegedly complained about them. He told her that while and pushed for names of the 9 The six page, single-spaced memo is dated September 2, 2013 and is included in the appendices to this report. For further context and to understand what the memo was used for, see Williamson correspondence pages 6 – 12. 10 Mr. Williamson did not explain the purpose of the highlighting, which appears over the subject text and in seven other locations in the memo. From an arm’s length perspective, it appears the highlighting tracks the most significant conclusions identified by Mr. Williamson where he wanted to focus the attention of the reader.

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people who made the complaint, he made a generalization that would lead someone to believe it was numerous Inspector 2s who had complained. Mr. Williamson told Ms. Peters he did not say my name during his meeting with and which is proven untrue by what I learned from in early August, 2013, and from Mr. Williamson’s admission and apology to me that he had indeed used my name during the meeting with and . I told Ms. Peters that Mr. Williamson’s recollection was not true – he had indeed given my name to and .” Director Colette Peters recalls initiating an informal conversation with Mr. Williamson about the

complaint on a date between April 2 and April 16, 2015, which aligns with the timeframe identified by . She recalled the substance of his explanation as follows: “In hindsight, it was a bad way to do it. I was trying to say all the Inspector 2s had complained to me; didn’t leave any of them out. and pressed me for names of who complained and I made a generalization that would lead someone to believe it was numerous Inspector 2s who had made complaints.” See Peters page 1. What Director Peters heard Mr. Williamson say in April 2015 is similar to what Mitch Morrow remembers hearing from Mr. Williamson after the August 12, 2013 conversation between Mr. Williamson and and it comports with Mr. Williamson’s written statement. 6. Additional information submitted by Mr. Williamson. On April 15, 2014, Mr. Williamson sent Kim Brockamp his 6-page memo written to Mitch Morrow, dated September 2, 2013, detailing work behavior problems with , categorized into the issues of truthfulness, following my direction, failure to support OIG mangers, failure to exercise good judgment, and other. Mr. Williamson marked 8 small sections in yellow. Mr. Williamson also sent it to me as part of my request of him for documents which related to investigation-relevant conversations from August 1 – 12, 2013. The document as a whole appears to impugn the general credibility of . See Williamson correspondence pages 6 – 12. On July 10, 2015, Mr. Williamson sent me an item from July 2, 2013 showing Mr. Morrow thought

was giving mixed messages in the context of an OIG mission statement and a complaint letter from to Colette Peters. It appears to question the motives of Mr.

. See Williamson correspondence pages 13 – 16. Mr. Williamson did not submit any material which would call into question the integrity, believability or motives of . Mr. Williamson’s prepared statement submitted August 6, 2015 explains how after the August 12, 2013 meeting with , she came to confide in him more and more. He listed 8 bullet point examples of positive, friendly, supportive, cooperative interactions, including three non-work-related. He also gave me e-mails as part of an attachment to a July 16, 2015 e-mail showing positive business interactions with . These appear to impugn sincerity. See Williamson testimony pages 4 – 5, 9 - 10; Williamson correspondence pages 17 - 20. Mr. Williamson’s prepared statement explains his reputation for truthfulness and veracity with 9 bullet point examples from his professional career. See Williamson testimony page 5; Williamson correspondence page 28.

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CREDIBILITY: During the investigation, I assessed the credibility of each of the witnesses pertaining to the incident at issue. Factors I considered included the consistency of their testimony with available documentary evidence, consistency in subsequent statements about the subject event, their ability to recall specific facts, responsiveness to my questions, and reasoning provided in answering my questions.

and . I find the accounts of both and credible in their recollection of the August 1, 2013 meeting in the following particulars. They testified consistently that: a) the initial portion of the meeting was about Mr. Williamson feeling disrespected when he was not acknowledged upon entering an earlier meeting which was already in progress; b) he named

as a specific complainant; c) the negative feedback from her came as a shock to both of them; and, d) they did not remember what the complaint about them was.

Where there are differences in the recollections of and about what occurred during the meeting, the distinctions comport with a context where both managers describe feeling strong emotions during the August 1 meeting, which may have impacted their perception of events. Among differences that could reflect either the influence of emotions on perception or the passage of time, remembers asking Mr. Williamson who complained; is sure he did not do so and does not remember hearing asking. says was named later in the meeting; says it was earlier. heard Mr. Williamson say to not speak to Jane

; did not hear that.

The actions and reactions of and following the meeting align with what they testified they believe they heard from Mr. Williamson at the meeting in the following particulars.

immediately approached to inquire whether something was wrong as he believed they had a good working relationship. His perception was correct as expressed confusion and dismay that she had been identified in that manner by Mr. Williamson. She told it was a lie.

produced e-mails from the period surrounding the Aug. 1, 2013 meeting that reflect a good working relationship with . The communications tend to support his reaction of being speechless at hearing news of critical feedback associated with her during the meeting with Mr. Williamson. Because he heard Mr. Williamson tell him during the August 1st meeting not to communicate with staff about the complaints being discussed, he did not approach following the meeting to address his reaction.

The recollections of and are credited that both agree that Mr. Williamson provided name as a specific complainant. As to the admonishment not to track down the source of information with staff, Mr. Williamson’s recollection is credited; that he directed both managers not to speak to staff. Based on hearing this admonishment, did not approach

after the meeting to discuss.

. statements are credible in the following particulars: a) she and have a similar recollection of their conversation immediately following the August 1 meeting; b) Mr. Williamson and agree she made no complaint to Mr. Williamson about and

in the timeframe before the August 1, 2013 meeting; c) and Ms. Popoff agree she came to HR to get counsel about being wrongly named as a complainant by Mr. Williamson; d) her memory of her conversation with Mr. Morrow implicates Mr. Williamson naming her as a

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complainant in his August 1st conversation with and ; e) she was satisfied with Mr. Williamson’s seemingly sincere apology for using her name to see if it would get back to him, evidenced by the message she gave to afterward and her subsequent increased positive interactions with Mr. Williamson, also noted by him and Mr. Morrow; f) her August 13, 2013 e-mail to Mr. Morrow, discussing her conversation with Mr. Williamson and stating “Turns out the discussion I allegedly had with Leonard never happened;” g) her reasons for waiting to come forward seem reasonable. Morrow. There is no evidence to conclude that Mr. Morrow’s recollection is other than straightforward, but it is noteworthy that: a) Mr. Williamson spoke with Mr. Morrow about his willingness to testify; b) Mr. Morrow declined an interview and only agreed to answer my questions in writing, via e-mail; 11 c) Mr. Morrow had a second memory of what he remembered hearing about the August 1, 2013 meeting - a very detailed one closely matching Mr. Williamson’s recently submitted prepared statement.

Williamson. Mr. Williamson’s account of the August 1, 2013 meeting is supported by his August 6, 2015 prepared statement that generally aligns with the memories of Mr. Morrow and Director Peters, who heard him explain the interaction in 2013 and 2015, respectively. His April 2015 conversation with Ms. Peters was impromptu yet it still aligned with the memory of Mitch Morrow, who, though known to have conversed with Mr. Williamson about being a witness in this investigation, states unequivocally that he was not coached in his answers to my questions.

Mr. Williamson’s prepared statement explains his reputation for truthfulness and veracity with nine bullet point examples from his professional career. See Williamson testimony page 5; Williamson correspondence page 28. I do not find it necessary to weigh this evidence in a manner differently than described in footnote number 5 below, based on the information he supplied.

Mr. Williamson’s version of the August 1 and August 12, 2013 conversations, while consistent with what he conveyed to Mr. Morrow and Ms. Peters, differs when compared to the statements credited to

, , and . For Mr. Williamson’s version of events to be accurate, to name possible scenarios, all three witnesses would need to have misunderstood his plain words, been in heightened emotional states when listening to him, or corroborated a story among them. I have no evidence to demonstrate that , , and corroborated their recounting of events, particularly when there is an e-mail sent by to Mr. Morrow, in proximity to the August 1st meeting, which tracks her understanding of events. It is a reach to believe each of them misunderstood Mr. Williamson so profoundly, despite the fact and admit to having strong emotions during the August 1st conversation and was said to be “upset” and “extremely upset for a long time” after hearing from and about the August 1st conversation. It appears that the credibility of Mr. Williamson’s version of events depends, in part, on these three employees misunderstanding critical aspects of their communications with him. Their heightened emotional state is among the few possible scenarios supporting a conclusion that all three misunderstood Mr. Williamson in key aspects of their conversations with him.

Mr. Williamson submitted a memo during the investigation he drafted for then deputy director Morrow concerning leadership. This memo was drafted approximately one month after the subject meeting. For purposes of this review, it appears Mr. Williamson submitted it to the investigator, in part, to question the veracity of any statements might offer during the 11 Recognizing that Mr. Morrow is retired, it is possible that he did not want to modify his personal schedule to meet with me.

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investigation.12

“Example six” on page 4 of 6 in the September 2, 2013 memo is the only document identified during this investigation reflecting Mr. Williamson’s recollection of what occurred at the subject meeting, close in time to the meeting itself.13 The September 2013 memo describes the subject meeting as follows (highlighting appeared in the original):

The plain reading of this paragraph, as identified earlier in the report, appears to at least partially discredit Mr. Williamson’s position that he had not identified to and a specific staff who provided critical feedback. The statement supports recollection from this time period that the apology offered to her by Mr. Williamson was because he had identified her as someone who offered critical feedback. When Mr. Williamson had the opportunity to address this paragraph in his statement or in the investigative conversation, he made no mention of it.

In addition, “Example six” appears to partially discredit Mr. Williamson’s general credibility because when he wrote the paragraph, he knew had gone to HR and Mr. Morrow to complain about being named as a complainant, not because she was confronted by managers. This is evidenced in his prepared statement which describes her complaint to him: “The first being a concern that I had attributed comments about and to her for which told me she did not say.”

An additional consideration weighing against Mr. Williamson’s general credibility is reflected in Mr. Williamson’s prepared statement, specifically what Mr. Williamson says about the conversation between and Mr. Morrow. “Morrow told me that Inspector had come to speak with him about the tone in the IG’s office. Morrow told me that had shared with him that people had no faith in and that additionally there were concerns about

leadership.” This is different than what is claimed in the plain reading of “Example six,” that went to Mr. Morrow because she was confronted by managers.

CONCLUSION: The weight of the evidence and consideration of the credibility factors assessed above support the following factual conclusions:

12 Investigating each of the alleged instances involving alleged conduct or propensity for truthfulness is beyond the scope of this review. Comparing witness statements and the documentary evidence surrounding the subject meeting, where there was another witness in attendance, is sufficient in this context to determine credibility and weigh the evidence.

13 I have no evidence this memo led to any disciplinary action against , but on December 13, 2013, Mr. Morrow had a sharply worded counseling discussion with and about perceived work behavior problems. The general content of this memo comports with memory of that meeting and with Mr. Williamson’s e-mail explanation of this memo. The memo, while written several months before the conversation, appears to be a source Mr. Morrow relied on to conduct the discussion. See pages 3 – 4; Williamson correspondence page 6.

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x In the timeframe in proximity to the August 1, 2013 meeting, did not make any

complaint or offer critical feedback about the performance of or to Leonard Williamson.

x and heard Mr. Williamson name as a specific complainant in their August 1, 2013 conversation with them.

x In the same meeting, Mr. Williamson may have intentionally used a technique to name multiple possible complainants in an effort to protect the identities of the actual complainants, indicating it may have been any of these staff who complained; or he may have intentionally named

to determine if the information channeled back to him through other staff. x and may have both misunderstood Mr. Williamson. x Hearing that complained about them elicited a strong emotional reaction from the

subject managers, leading to question immediately following the meeting, and triggering to complain to HR and the then deputy director about being wrongly named as a complainant.

x In subsequent conversation between Mr. Williamson and about the meeting, she says he apologized for naming her as a complainant. He says he apologized for her being confronted by managers.

x may have misunderstood Mr. Williamson. x On September 2, 2013, in a memo Mr. Williamson prepared for a different purpose, he briefly

describes the subject August 1, 2013 conversation and the immediate events following. This earlier written statement appears to contradict his position, as presented to this investigator, that he did not name as a specific complainant.

x This statement in Mr. Williamson’s September 2, 2013 memo, in conjunction with the other findings set out in this report, favors version of events, specifically that he named her as a complainant during the August 1st meeting and subsequently apologized to her for doing so. Her version more closely aligns with the available evidence than Mr. Williamson’s stated refutation.

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