Marco Island Police Department Memo Te: Chie Tracy Frazzana ‘From: Captain Baer Date 9 re: “Compatn Leak Investigation’ Closure Chief Frazzano, In July 2019, in my role of Acting Chief of Police, I was asked to close the “Comparini Leak Investigation” by City Manager McNees. By way of background, your predecessor, Al Scheitino, opened an investigative inquiry to determine whether Records Clerk Heather Comparini, improperly disclosed confidential information pertaining to an investigation of former City Manager Lee Niblock. City Manager McNees, aware that the matter was still pending, wanted to bring the matter to a close, which meant ascertaining whether sufficient ‘evidence existed to implicate or clear Ms. Comparini as the source of the confidential information “leak.” To provide context, I was not a party (ie, investigator, witness or subject) to former Chief Schettino’s investigative efforts before his departure, though I had anecdotal knowledge of the situation due to my position in the organization. However, I had not reviewed or been provided any documents or evidence associated with the investigation, During the week before Chief Schettino’s retirement, he briefed me on his office contents, including various files ~ I noted the investigative file, if any, conceming the leak was not in his office. I discussed this fact with Milton Collins, the City’s labor attomey. on or about July 22, and Operations Captain Rich Stoltenborg on the following day. Captain Stoltenborg indicated he had the investigative file and provided the following materials to Attorney Collins and me: 1. A two and one-quarter page (approx.) typed/unsigned investigative type summary prepared by former Chief Schettino. This summary has handwritten marks and notes on the second page. Captain Stoltenborg indicated he (Stoltenborg) had made the marks on the page because there was a grammatical error that impacted context (*to” versus “fiom”. 2. A photocopy ofa text message identified by the initials “NG,” dated Friday, February 9, 11:1] AM. 3. A memo to Chief Schettino from Lt. Clayton Smith dated April 9, 2019. 4, A memo to Chief Schettino from Sergeant Haueter dated February 9, 2018, 5. Page 9 of Collier County Sheriff's Office Supplemental Report 1800063808 with two paragraphs highlighted therein,On August 2, 2019, I sent an email to City Attomey Alan Gabriel. The purpose of the email ‘was to obtain any materials relevant to the investigation. Attomey Gabriel responded on Anugust 6, 2019 and stated (Italicized added): Captain Baer, ‘In response fo your inquire below, | am aware of the allegations against Heether Comparini that ‘she may have viewed and leaked to others a Confidential Report that former Chief Schettino was preparing involving an investigation into alleged misconduct by the former City Manager. As City Attorney, | have been apprised of the fact that the MIPD iniiated an investigation against ‘Ms. Comparini. Furthermore, | am in receipt of Public Records requests from Ms. Compannis attorney for the Comparin investigative file. During the investigation into former City Manager Niblock, the Colier County Sheriffs Office (°CCSO?), CCSO asked me to tum over all communications received or sent by me relating 0 this investigation, al of which materials were turned over to CCSO. | fully complied with this ‘request and responded to the Shenfs Office in a timely matter. Included in my response was the only communications that | received referencing ‘a report, which is already in your possession. This is @ text message dated February 9, 2019, 12:22 pm. | have reason to believe that the text was also sent fo Lee Niblock on the same date and time. I have no other records or materials in my possession that may pertain to the Confidential Report or the Police Department's internal investigation of Heather Comperin. Please contact me should you wish to discuss. Alen L. Gabriel! City Attomey Gabriel provided the same documents provided by Captain Stoltenborg enumerated above, as well as public records requests from Ms. Comparini’s attorney, On August 7, 2019, I requested a copy of Collier County Sheriff's Office (CCS) Report 1800063808, including all official reports, witness statements, photographs, a depiction of text ‘messages and other written documentation. I was provided a copy of the report (285 pages) and a USB drive. Significant findings from (CCSO) 1800063808: February 9, 2018 at 12:02 PM - Former City Manager Niblock texts message to "possibly Lamy Honig” asking for a copy of two texts February 9, 2018 at 12:22 PM — Councilor Honig sends two messages to Former Manager Niblock and City Attomey Alan Gabriel stating, “I accidentally came across a report that the CM made advances towards the principal Melissa Scott" and "The CM just resigned.” No attribution conceming the origination of these messages is contained in the text or by CCSO, which was unsurprising because such information was not the focus of its investigation (Chat #6 in CCSO Report). ‘The USB drive contained two folders: “2018-03-05.14-13-29" and “2018-03-05,16-53-26.” 2018-03-05.14-13-29 is described as an Apple Device Advanced Logical or Former City Manager Niblock’s iPhone 8 (239- 293-5370) containing sub-folders of chat sessions. Within the chat folder, there are 40 distinct chat threads. Below are excerpts from the chat threads relevant to this inquiry. Note that the referenced phone numbers pertain to the following individuals: © Page 2Former City Manager Niblock (239) 293-5370 (352) 342-3650 City Councilman Honig (239) 588-0080 City Attorney Gabriel (054) 295-1304 Chat 6 - porte razor emaarnures, nica seams ieezeorMUTe Chat 36 - Petre nov estosauuros) iSiry arszoecocserature) Fo Fo Lee, No Irmore saan source) Saucedo bisape zane iiciersossetn ene Frese cutie Boerne Fam eee Baie erietanacs a ‘ rey tae Tete HezeeeeaeeaMUTe Seah hee tao Foun siaaaeeso Teco Visca teoeseraures Site fp Messe "ETD © Page3resere iasore er ALTOS) Some Mase Foufon aac Tresoo. iste temsaruuros, Soe Nesom SD Sosa + 2st OTHE £2 Stillness acsnoateorarastM BIE fe asassroetcareat SC foeeten an oy Bish yon ray Faby srt rt en Crise ‘mere actseeocamaurcsy ‘Steele Mactpe “sansa ea © Paged‘mung igi eseae TCS) See keane Seas a Tresane tance rwaattcn, Sora henge saan ee Ergun + 22s5OattrersstFp argo se RR croy ‘Temsuyp deatieczaz rain Sieh see SES Feariesome omenav ey Fer teatro eevee tone em fe Mie ces wa tony Greloroa: ter Ferro zest Pietro dares) Bespin {Fimoareetas crac Bay Foon asso ‘Tnunp aaereea PuUTOS) ‘SEhente tsope a i guage street 72 eon Sacre fairer 1 Goons ERR etacrerSHMG, ate Be SiR thee isn Eee wero, Fee Ee mmrente ming Siti eaomeeretae ne 2 Saucer eaeemsecae nae Peter SER i tioommeennom rane ieee ee scarlet aptoreerenene mane He Retr ee emnenn azine 12 Soueat emeomacrete mae eet nig eimererssoM AI Fem ran ves Hae aes amauton ea {grat oenescms aren hate nae arcs ie ical er Sat inate Trung Sraartoeot0 PAUTCS) Sora kenge SRS Buy {Blnaae monty on ys koe eco IWant Na Soon ht Ip apr aston ede I reviewed the attachments indicated above and found that, while tangentially relevant, provided no detail concerning a “leak.” The iPad Pro contained no relevant information, © Page 5On August 14, 2019, I requested a copy of the complaint, filings, witness statements and dismissal of the Comparini EEOC investigations from Attomey Collins. The following day, I received an email from him containing six attachments. The attachments included ‘Comparini personnel file, which included pre-hire materials such as a copy of Comparini's driver's license, outside employment documents, a conditional offer letter and prior evaluations, none of which contained relevant evidence to the question at hand. Relevant documents included Comparini’s EEOC complaint, the City's response to Comparinis EEOC complaint, an earlier version (1 page + 1 sentence) of the typed/unsigned investigative type summary prepared by former Chief Schettino (without marks made by Captain Stoltenborg) , memoranda by Sgt. Haueter (2/9/18), page 9 of CCSO Supplemental report 1800063808 and a photocopy of a text message identified by the initials “NG” and dated Fri, February 9, 11:11 AM. In Comparini’s EEOC Complaint, itis alleged that former Marco Island Police Department (MIPD) Sergeant Neil Giansanti was standing in the immediate vicinity of the printer/copier that was used to print the confidential document, which is the physical focal point of this investigation. Further, Comparini alleges another former MIPD Police Officer, Karie Petit, came into the station looking for the document after reportedly being told by Giansanti of the contents of the report. In the EEOC summary document, an assertion was made that MIPD Administrative Assistant, James Deatherage, provided an affidavit which supported her position. On September 9, 2019, 1 obtained the Deatherage affidavit described above from Neil Snyder, Comparini’s employment attomey. I had asked Attorney Collins for the document approximately two weeks prior, however, he indicated the City did not possess it and suggested to ask Comparini for it. After a week or so, I called Attorney Snyder and requested the document. In the affidavit, Deatherage contends he was standing at the copier/printer when Comparini found the confidential document. Deatherage surmised the document was handled by others based on how it was lying on the counter next to the copier/printer and concurs that Sgt. Haueter was in the area at some point in time relative to obtaining the document. Deatherage disputes newspaper accounts of statements attributed to Former Chief Schettino and Sergeant Haueter, but his statement does not cite official reports or statements used in this document. Deatherage does not discuss Giansanti in any manner. Of note, Deatherage does not place Giansanti in the vicinity of the copier/printer. On September 9, 2019, while reviewing documents, I was advised by Sgt. Mark Haueter that he (and other MIPD staff) were interviewed in Chief Schettino’s office by Attorney Collins and a female colleague from his firm regarding the investigation. I sent Attorney Collins an email inquiring into the interviews and requested any documentation that resulted from the meetings. Attorney Collins responded the same day and stated (Italicized added): Good evening. That fact-finding exercise was for the EEOC position statement. You have the position statement, There may be some attorney notes, but everything was already summarized in the statement. Poges iThe City’s April 12, 2019 response to The U.S. Equal Employment Opportunity Commission, referenced in Attorney Collins” statement is attached. On September,16, 2019, I submitted a preliminary draft of this report and all relevant materials to Chief Frazzano. 1 asked the Chief to review my draft report and conclusions and suggested including an interview of City Councilman Honig for the purpose of clarification. Chief Frazzano approved the interview late in the afternoon of September 16, On September 17, 2019, I called Councilor Honig and requested a meeting, Councilor Honig arrived as scheduled at 11:00 AM and provided a statement. As relevant to this ‘matter, Councilor Honig provided the following (see sworn statement completed by Councilor Honig): + He has never texted, emailed or called Heather Comparini; all interactions with her have been in person on city property; * He did not tell City Attorney Gabriel the name of the person who texted him the information depicied in Chat #6; * The text message information associated with this investigation did not come from Heather Comparini. Councilor Honig stated he did not recognize the “NG” text message. Further, the elements contained therein in which he forwarded to the former City Manager and City Attorney were provided to him in a different order than depicted in the “NG” text message. This testimony matches the data depicted in the CCSO forensic reports, Councilor Honig, citing advice from an attorney, declined to identify the source of the original text message, In the light of Councilor Honig’s statement that he did not provide a name to the City Attomey, I requested clarification from City Attomey Gabriel immediately after my interview with Councilor Honig, On September 16, 2019 at 3:00 PM, I received the following email from City Attomey Alan Gabriel: Captain Baer, To my best recollection of the relevant events, I received a phone call from Councilor Honing who advised me of an incident regarding then City Manager Niblock, Councilor Honig did not offer his source but indicated the information came from someone in the Police Department, I have previously provided you with a copy of the text message that Councilor Honig sent to me, that text does not identify anyone other than the initials NG and I have no idea who that may or could be. Alan L. Gabriel Analysis © Page 7‘The analysis and conclusion made in this matter are based on the consideration of all the statements, evidentiary exhibits, as well as my observations concerning motives, biases and consistency. This matter largely involves determining whether any individuals other than Ms. Comparini either reviewed the confidential document on February 9, 2018 or had the opportunity to review it due to their physical proximity. By their admission, or by the statement of others, the following individuals either reviewed or had an opportunity to review the document Schettino, Haueter, Comparini, Deatherage, and Giansanti. The copier is in a central hallway and, given the time and day of the week, it is plausible that other unidentified employees could have had an opportunity to access and/or disseminate the information. The following chronology of events illustrates the extent of employee/official involvement, as well as the sinuous flow of information, * 9:30 AM (approximately) Lt, Smith indicates in a memo to the Chief, that he (Smith) and ‘Giansanti left the Island to attend a meeting at the Naples Airport. + 10:10 AM (approximately) Schettino and Haveter indicate Haucter retrieved a confidential document from the copier/printer for Schettino, * 10:40 AM (@pproximately) Schettino and Haueter indicate Haueter was walking past the copieriprinter when Comparini handed Haueter the same confidential document previously printed by Schettino and retrieved by Haucter. ‘+ 11:00 AM (approximately) Schettino states that Giansanti and Comparini were observed talking in Comparini's office. Schettino does not identify the source of this assertion in his report, ‘though it seems reasonable to believe the information was provided by Smith (See Smith memo). + 1:10 AM (approximately) Smith indicates he (Smith) and Giansanti retumed to MIPD, at Which time he dropped off Giansanti who entered the police facility and was subsequently ‘observed in Comparini’s office (by Smith). * 11:11 AM A text message, provided to Schettino by Snyder, with the recipient being identified by the initials “NG” is transmitted to and from unknown persons. The unknown phone owner says, “I accidentally came across a report that the CM made advances towards the principal Melissa Scott", the recipient stated “You shitting me, Damn Place is shit hole I guess”, the Phone owner then says, “The CM just resigned Or is about to”. The owner of the phone is ‘unknown. The inference that NG is Neil Giansanti, while convenient -is unsubstantiated * 12:22 PM Honig sends a text message to Niblock and Gabriel stating, “I accidentally came ‘cross a report that the CM made advances towards the principal Melissa Scott” and “The CM justresigned”. ‘+ 1:30 PM Schettino receives a phone call from Gabriel asking if the “Police Department” had sent out an email or text stating the City Manager was resigning. Schettino states that Gabriel ‘as told that Honig indicated a text message had originated from Comparini which contained © Pagesconfidential information. Schettino requested a copy of the text message from Gabriel - this text ‘message never manifests itself. Schettino’s summary document does not refer to any level of intial concem when Comparini found and tuned over a confidential document to Haueter. Based on the chronology of events, Schettino became concemed after he received a call from Gabriel. According to Schettino, Gabriel informed him that Councilor Honig was aware of a text message wherein Comparini disseminated confidential information. As stated previously, this text message has not been produced by anyone, nor found by any investigative unit or agency of which I am aware. Indeed, Gabriel's August 6, 2019 email to me states the only text message he received was dated February 9, 2019 ~ the one sent by Councilor Honig and shared with Lee Niblock (1 believe Gabriel mistakenly cited the year 2019, as the message is dated February 9, 2018 12:22 PM). On October 10", 2019, Chief Frazzano directed additional interviews. ‘On the following day (10/1 1/19) at approximately 10:00 AM I spoke to Records Clerk Heather ‘Comparini and asked if she would like to submit any documents with the investigation packet, she indicated she would discuss it with her attomey. On 10/11/19 at approximately 10:01 AM, I spoke with former MIPD Officer Neil Giansanti. I asked Neil ifhe would be available for an interview regarding this investigation. Neil indicated he would think about it, I told Neil I would call him back on the following Monday. At 10:04 AM, | left a voicemail for former MIPD Officer Kare Petit, asking her to call me regarding a potential interview. At approximately 130pm I retumed Attomey Neil Snyder's phone call and left a message. Finally, on the 11", I called Karie back at 1:55 PM, but the line was not answered. On the aftemoon of the 11®, Mr. Snyder returned my call and indicated he was disappointed the investigation had not be closed and that he would discuss our request with his client. On 10/14/19 at approximately 4:55 PM I left a voicemail for former MIPD. Officer Karie Petit, asking her to call me regarding a potential interview. At approximately 4:58 PM I called former MIPD Officer Neil Giansanti, who stated he did not send the materials, did not know ‘who sent the items as he only heard it discussed in rumors, and that he was trying to move on and did not want to send me a statement or come in for an interview, Mr. Snyder sent an email to Chief Frazzano, and others on 10/14/19, stating with respect to his Client “Regarding ‘Heather's statement, her claims and position have been well documented in her complaint and response in the EEOC case, Heather Comparini v. City of Marco Island, et al., EEOC Charge No.: 510-2019-01344 as well as in the litigation now pending, Heather Comparini v. The City of Marco Island, et al., Case # 19-CA-3704.” On 10/21/19 at approximately 8:00 AM I attempted to contact former Chief Schettino to request an interview. I was unsuccessful in reaching him immediately, so I left voicemail and sent text messages. Schettino did call back later in the moming and we agreed to meet on the following day. During the aftemoon of the 21%, I received a text message indicating he would have to reschedule, and he would let me know when, On the following day I sent additional text messages requesting a new appointment, On the 23°, Chief Frazzano advised me that ePageoformer Chief Schettino had contacted her and indicated he was declining to be interviewed based on the advice of counsel. Later in the day on October 21%, I interviewed Sgt. Haueter. Haueter agreed to complete a swom statement ~ attached. Haueter: * Affirmed his previous written statement; * Indicated former Chief Schettino had enlisted is help in printing a document because of an issue with the Chief"s printer, © Stated he (Haueter) was asked to assist Schettino to avoid asking IT for assistance based on the sensitive nature ofthe case; ‘* Did not see anyone at the copier / printer when he stood by the printer for a short period of time as the Chief sent the document to be printed; * Retrieved the document and gave it to Schettino directly * Related that he was given the same document as previously printed by the Chief by Comparini ‘approximately two hours later; ‘* Did not recall anyone near the area during the interaction with Comparini; ‘* Related that the leak investigation was launched by Schettino because Alan Gabriel told ‘Schettino Comparini was the source ofa leak; + _Isunaware of any evidence that would prove or disprove that Comparini was the source of the Teak, ‘On 10/22/19, | interviewed Leslie Sanford (City of Marco Island Human Resources). Leslie agreed to complete a swom statement - attached. In the statement, Sanford: Acknowledged being part ofa group interview conducted by former Chief Schettino; Was not aware of why Schettino had called the interview (not pre-briefed on reasons); Was there to represent the Human Resources Department; Affirmed Comparini denied being the source of the leak; Indicated there was no screaming or fist pounding; Stated Schettno raised his voice; Believed the meeting took five minutes or less; Is not aware of any evidence that would prove or disprove that Comparini was the source of the leak. interviewed Lt. Clayton Smith on October 22" as well. Smith agreed to complete a swom statement —attached. Smith: Affirmed his previous written statement; Indicated it was written atthe request of former Chief Schettino to document the incident; Found former Sergeant Giansanti’s behavior on the day in question suspicious Was told by Schettino the leak investigation was launched by Schettino because Alan Gabriel {old Schettino Comparini was the source; ‘+ Is unaware of any evidence that would prove or disprove that Comparini was the source of the leak On 10/23/19, | interviewed Administrative Assistant James Deatherage. James agreed to complete a swom statement ~ attached. In the statement James: © Page 10,Acknowledged he saw Heather give a document to Haueter & verbally interact with him; ‘Noted it was not uncommon for documents to be left in the area; Not out ofthe ordinary for Comparini to police the area of documents; Did not see Giansanti until the afternoon of the same day; Did not recall seeing Petit; Had no conversations with Comparini regarding the document until after she was interviewed by the former Chief, ‘+ Isunaware of any evidence that would prove or disprove that Comparini was the source of the leak, On 10/24/19, | interviewed Captain Stoltenborg: Indicated he did not perform any type of internal investigation; ‘Was not involved in the printing of the documents; Affirmed that Schettino was told by Gabriel that Comparini was the source of the leak; Repeated that Comparini denied being the source of the leak inthe interview with the Chief; Is unaware of any evidence that would prove or disprove that Comparini was the source of the leak, Until 10/24/19, it was unclear what report was printed and associated with the alleged leak. Tt ‘was then determined to be a three-page Schettino authored document dated 2/6/19. This document was a chronological summary of events starting on 2/6/18, with the last entry dated 29/18. * Its authenticity was verified by Sergeant Haueter, who was provided a copy of a document. Haueter verified it was the same report he picked up from the copier / printer for Chief Schettino as well as the report which was given to him by Heather ‘Comparini, + This document was provided to the Collier County Sheriff's Office and appears to have been used as the basis for their Niblock battery case report (1800063808), Schettino’s 2/6/18 summary report contained a MIPD incident report number: 18-0093. MIPD report 18-0093 was classified as an “information report”, the location of the incident was listed as 51 Bald Eagle Dr. (MIPD Headquarters) and the date of the incident was 2/9/18. 18- (0093 was passworded protected, preventing others from viewing the report. ‘The report was a non-criminal report which described a battery but did not list a suspect ot victim. The report stated MIPD had not received any written or recorded statements regarding the battery until 2/16/18 and provided those statements or documents to the Collier County Sheriff's Office on 2/19/18. The report contained three attachments: Schettino’s 2/6/18 summary, signed and dated on 2/19/18 (not notarized), a one and three-quarter page report from Sgt. Haueter dated 2/16/18, and a twenty-eight-page version of CCSO. Feport 1800063808. Conelusion — The singular purpose of this intemal investigation is to determine if sufficient evidence exists to substantiate the assertion that Marco Island Police Department Records Clerk Heather © Page tt‘Comparini leaked confidential information regarding the investigation of former Marco Island City Manager Niblock. ‘The investigative delay between Schettino’s initial launch and my assignment reduced access to witnesses, opportunities to collect evidence, the ability to interview witnesses with “fresh memories”, and finally creates opportunities for actual collusion or the perception thereof. Former Chief Schettino indicated in his 2/9/18 summary document, that he was acting on the information that Comparini was the source of the leak according to the City Attomey Alan Gabriel, as supported by City Councilman Honig. City Attomey Alan Gabriel stated to me on a September 17, 2019, in an aftemoon phone call that he did not tell former Chief Schettino the name of the person suspected of leaking the information. This position was further supported by City Attorney Gabriel's email on the same date which indicated Councilor Honig did not provide a source to him. Councilor Honig stated in a swom statement that he did not provide the name of the person who sent him a text; moreover, it was not Heather Comparini. Gabriel does not refute the claim he called Schettino, although he does deny identifying the source of the leak. Gabriel's denial is supported by Honig’ statements denying that he provided the ‘identity to Gabriel, moreover that Comparini was the source. Haueter, Smith and Stoltenborg were adamant about the genesis of the investigation as related by Schettino: Alan Gabriel’s statement to Schettino that Comparini was the source of a leak, although none of these individuals heard the information directly. ‘The “NG” text was never substantiated or vetted in any way. Multiple persons had access to the document as indicated above, and there is clear evidence that ‘more than one copy was printed to a printer in a common area. Based on the elapsed time, lam unable to review the records contained within the copier / printer. Petit's refusal to respond after numerous attempts to contact her direetly and through a family ‘member, Giansanti’s blanket, but unswom statement, Honig's refusal to identify the source of the text messages on advice of legal counsel, and Schettino's unsigned notes / investigative document, as well as his declination to participate on advice of legal counsel is noted, tis undisputed Heather Comparini had access to a document that is alleged to have contained ‘confidential information which was leaked. Sans Schettino’s assertion, Comparini’s access is the sole form of evidence potentially linking her to the allegation. Its also undisputed that ‘multiple other persons had access to the same document ~ thus the same inference could be made regarding those persons known, or unknown. Although Schettino’s 2/6/18 document was not marked confidential, private, secret or in any similar manner, it was entitled “Marco Island Police: Case #18-093". It seems reasonable to infer that this document was part of an open MIPD case and therefore, presumed to contain privileged, if not confidential information. One must contemplate the question of what was allegedly leaked. A specific subset of information contained in Schettino’s 2/6/18 report: “the CM just resigned or is about to”, in vague terms an accusation “advances”, and the identification of a victim's name “Ms, Scott”. © Page 12 “The same facts were known to members of City Council on 2/6/18 and by the City Attomey on 2/8/18. Schettino’s leak investigation did not commence until 2/9/19. Indeed, between January 24, 2018 (the date Niblock first met Scott) and February 16", 2018, no less than twenty individuals representing at least seven different organizations or families, had differing yet specific and detailed knowledge of the incident and/or the unfolding investigation - 1. Lee Niblock, former Marco Island City Manager 2. Melissa Scott, Principal of the Marco Island Academy 3. Al Schettino, former Marco Island Police Chief 4. Rich Stoltenborg, then Detective - current Mareo Island Police Captain 5. Nick Ojanovae, former Marco Island Police Captain 6. Mark Haueter, Marco Island Police Sergeant 7. Leslie Sanford, City of Marco Island Human Resources 8. Jane Watt, Marco Island Academy Chair 9. Damon Coiro, Direct of Student Affairs at the Marco Island Academy 10. Lary Honig, Marco Island City Couneil 11. Jered Grifoni, Marco Island City Council 12, Victor Rios, Marco Island City Council 13, Alan Gabriel, Marco Island City Attomey 14, Milton Collins, City of Mareo Island Associate City Attomey 15. Kevin Rambosk, Collier County Sheriff 16, Wade Williams, Collier County Sheriff's Office Deputy 17, Paul Roman, Collier County Sheriff's Office Sergeant 18. Chris Lombardo, Melisa Scott's personal attomey 19. Shawn Amold, Marco Island Academy's attomey 20. Michael Hook, Melissa Scott's Father When considering the totality of evidence, in accordance with MIPD General Order 303.2.5 Intemal A flairs - Types of Dispositions, insufficient evidence was found to prove or disprove the allegation Records Clerk Heather Comparini was a source of leaked confidential information pertaining to an investigation of former City Manager Niblock. As such, this inquiry is considered Not Sustained and therefore closed. Respectfully Subs Captain David 8, Baer © Page 13