TO:
The New Hampshire Department of Justice
Office of the Attorney General / Public Integrity Unit
33 Capitol Street, Concord, NH 03301
The Federal Bureau of Investigation (FBI)
Boston Field Office / Public Corruption & Civil Rights Programs
201 Maple Street, Chelsea, MA 02150
COMPLAINANT:
Jeffrey T. Clay
31481 Cannon Rush Drive, San Antonio, FL 33576
603-534-1963 | jeffreytclay@gmail.com
TARGETS OF COMPLAINT:
STATUTORY CHARGES ALLEGING A CONTINUING CRIMINAL ENTERPRISE:
This document is a formal demand for criminal intervention and does not seek administrative or civil remedies. While the targets have repeatedly attempted to shield their felony conduct behind the finality of closed municipal dockets, it is a foundational maxim of American jurisprudence that Fraud Upon the Court strips a tribunal of jurisdiction, carries no statute of limitations, and cannot be immunized by a tainted civil judgment.
Furthermore, this complaint documents a secondary conspiracy inside the New Hampshire Department of Justice. It outlines an illicit feedback loop where state prosecutors actively colluded with the targets of a public corruption complaint to prematurely kill an active inquiry, triggering mandatory federal jurisdictional review under the Color of Law statutes.
Target: Town Manager Stephen Fournier
Statutes Violated: NH RSA 641:3, RSA 641:4, RSA 638:1, RSA 642:1
Factual Matrix:
On August 28, 2023, after receiving explicit, written notice that federal and state civil rights litigation regarding Right-to-Know (RSA 91-A) violations was imminent, Town Manager Stephen Fournier issued a formal statutory denial letter. In this official government record, Fournier falsely asserted that:
This response was not an administrative error; it was a deliberate falsification of a governmental record intended to impair the availability of evidence in an impending tribunal. Fournier used his administrative office to create a fraudulent negative record to force the complainant into a litigation blind spot.
Target: Town Manager Stephen Fournier
Statutes Violated: NH RSA 641:2 (Class B Felony), RSA 641:4, RSA 638:1, RSA 641:6
Factual Matrix:
On September 26, 2023, Fournier executed a sworn affidavit under penalty of perjury and submitted it directly to the Rockingham County Superior Court. In this affidavit, Fournier swore under oath that no discussions, non-meetings, emails, or approval records existed among any quorum of the Town Council regarding the settlement agreement.
This sworn document directly influenced the court’s early staging of the case. It is flatly contradicted by subsequent admissions from his own corporate counsel (DTC), which revealed that a rolling quorum of the Town Council had explicitly debated and authorized the contract terms via private email dockets.
Target: Donahue, Tucker & Ciandella, PLLC (DTC)
Statutes Violated: NH RSA 641:4, RSA 638:1, RSA 642:1, RSA 641:6
Factual Matrix:
In its formal Answer filed before the New Hampshire Right-to-Know Ombudsman (Docket RKO 2023-024), the DTC law firm shifted the narrative to escape discovery. DTC explicitly admitted that: "The settlement decision of the Town Council was the product of the Town Council email responses to the Town legal counsel's email inquiry."
Despite this formal admission that public records existed and that an illegal email approval process occurred outside of a public meeting, DTC actively withheld the documents. They claimed the emails were completely immune from disclosure under attorney-client privilege. This directly contradicts Fournier’s sworn assertion that "no emails existed," proving that both records cannot simultaneously be true.
Targets: Attorney Briana L. Matuszko, Attorney William K. Warren
Statutes Violated: NH RSA 641:2, RSA 641:4, RSA 642:1, RSA 638:1
Factual Matrix:
On January 17, 2024, Attorneys Matuszko and Warren co-signed and filed a "Statement of Material Facts" in the Rockingham Superior Court (Docket No. 218-2023-CV-01356). Facing judicial scrutiny, DTC altered the narrative for a third time, stating under certification to a judge that: "The Town Council did not approve the Settlement Agreement."
This was a deliberate attempt to deceive the trial judge into believing the Town Council played zero operational role in the contract's formation, thereby directly undermining their own prior filings to the Ombudsman.
Target: Attorney Briana L. Matuszko
Statutes Violated: NH RSA 641:2 (Felony), RSA 641:4, RSA 638:1, RSA 641:6
Factual Matrix:
In the Town's Rule 7 Mandatory Appeal Response Brief filed before the New Hampshire Supreme Court (Docket No. 2024-0474), DTC escalated their fabrications to the highest level of appellate practice. Attorney Matuszko explicitly certified to the Supreme Court that:
This appellate submission represents a complete, fraudulent distortion of the record. It directly conflicts with the underlying municipal reality and earlier admissions made to the Ombudsman.
Targets: Attorneys Hawkins, Matuszko, Warren, and Ratigan
Statutes Violated: NH RSA 629:3, RSA 638:1, RSA 642:1, 18 U.S.C. § 1512
Factual Matrix:
The four named DTC attorneys operated a coordinated legal team that systematically mutated the factual record depending on the vulnerabilities of the forum:
Targets: Stephen Fournier, DTC Law Firm, Town Council
Statutes Violated: Common Law Fraud Doctrine (Inherent Power), NH RSA 641:6
Factual Matrix:
The targets successfully executed a multi-forum fraud scheme that polluted the fact-finding mechanisms of the Ombudsman, the Superior Court, and the Supreme Court. By presenting four irreconcilable, shifting realities across two years of litigation, the targets choked the judicial machinery, ensuring that no court could accurately evaluate the underlying structural violations of New Hampshire law.
Targets: Town Manager Stephen Fournier, Newmarket Town Council
Statutes Violated: NH RSA 643:1 (Class A Misdemeanor), RSA 626:8 (Accomplice Liability)
Factual Matrix:
Fournier and the collective members of the Town Council knowingly refrained from performing their mandatory statutory duties under RSA 91-A and RSA 41:6 (the preservation of public records and compilation of public minutes). They deployed their official municipal power to target the complainant, utilizing public funds to pay private lawyers to systematically strip a citizen of his state constitutional right to governmental transparency.
Targets: All Defendants
Statutes Violated: NH RSA 638:1, RSA 641:3, RSA 642:1
Factual Matrix:
This is a coordinated operational scheme where civil infractions were intentionally escalated into criminal concealments. The targets used false assertions of "attorney-client privilege" as a criminal pretext to hide the physical existence of documents. This perverted the administrative enforcement powers of the Right-to-Know Ombudsman.
Targets: Donahue, Tucker & Ciandella, PLLC, Attorney Christopher D. Hawkins
Statutes Violated: NH RSA 637:4 (Felony Theft), RSA 629:1 (Criminal Attempt), 18 U.S.C. § 1343
Factual Matrix:
This criminal enterprise directly targeted personal property. Having successfully obtained civil orders and fee awards through the submission of false affidavits and perjured appellate briefs, DTC and Attorney Hawkins filed a series of Writs of Execution and Exemplifications of Judgment totaling $29,197.07.
They attempted to leverage these fraudulently obtained orders to execute a seizure of personal funds and place a lien on the complainant’s real estate. This constitutes a distinct financial crime: attempting to convert a citizen's property by creating and reinforcing a false impression before a judge.
Targets: All DTC Counsel
Statutes Violated: NH RSA 638:1, RSA 642:1, Crime-Fraud Exception Doctrine
Factual Matrix:
DTC attorneys systematically deployed claims of statutory attorney-client privilege to shield an active cover-up. Because the privilege was explicitly used to hide an un-noticed rolling quorum vote from the public, the privilege was void ab initio under the Crime-Fraud Exception. Weaponizing a void privilege to block judicial discovery constitutes felony evidence tampering.
Target: Attorney Briana L. Matuszko
Statutes Violated: NH RSA 641:4, RSA 641:6
Factual Matrix:
The factual assertions presented in the Town's mandatory Rule 7 Brief—specifically denying the physical existence of structural email chains—were certified under penalty of procedural sanction. Presenting these certified falsehoods to the Supreme Court clerk directly caused appellate justices to issue rulings based on a fabricated factual universe.
Targets: Attorney Christopher D. Hawkins (DTC), Associate Attorney General Thomas P. Velardi (NH DOJ)
Statutes Violated: NH RSA 629:3, RSA 642:1, 18 U.S.C. § 241, 18 U.S.C. § 242
Factual Matrix:
On November 23, 2025, with the complainant’s Motion to Vacate for Fraud pending before the Rockingham Superior Court, Target Attorney Christopher Hawkins initiated direct, ex-parte communication with Associate Attorney General Thomas P. Velardi, Director of the Division of Public Protection. At the time of this call, Hawkins' firm was actively facing multi-layered allegations of felony public integrity violations.
Exactly one day later, on November 24, 2025, at 12:19 PM, AAG Velardi issued an absolute administrative declination letter completely shutting down any criminal review of Newmarket officials or DTC attorneys.
[CRIMINAL INTERFERENCE TIMELINE]
Nov 23, 2025: Target Atty Hawkins makes backchannel contact with NH DOJ.
Nov 24, 2025 (12:19 PM): AAG Velardi issues sweeping, un-investigated declination letter.
Nov 24, 2025 (4:35 PM): Hawkins uses Velardi letter to threaten Complainant.
Nov 25, 2025 (8:55 PM): DTC files Omnibus Objection using DOJ letter as Exhibit 2.
Velardi’s rapid turnaround letter (File: Verlardi Letter Declining (1) (2).pdf) features structural indicators of institutional collusion and bad faith:
Within four hours of Velardi issuing this email, Attorney Hawkins sent a threatening correspondence to the complainant, demanding that the court be notified of the DOJ declination. Within 30 hours, DTC filed a sweeping Omnibus Objection in the Superior Court, attaching Velardi's letter as Exhibit 2 to demand the immediate release of the $29,197.07 Writ of Execution.
This sequence of events demonstrates a coordinated, extrajudicial loop where state law enforcement power was deployed under color of law to defeat a public integrity complaint, protect prominent bar members, and facilitate the immediate financial extraction of funds from a pro se citizen.
Targets: All Named Co-Conspirators
Statutes Violated: 18 U.S.C. § 241, 18 U.S.C. § 242, NH RSA 643:1
Factual Matrix:
The cumulative actions detailed in this complaint do not represent a series of isolated administrative errors. They demonstrate a pervasive custom and custom-enforced custom of institutional insulation.
When a municipality can conduct secret electronic voting, fabricate records to hide the votes, present shifting narratives to multiple courts, and use top-tier state prosecutors to short-circuit criminal review, the rule of law has been systematically replaced by a protective cartel. This pattern and practice directly deprives a United States citizen of his First Amendment Right to petition the government for redress and his Fourteenth Amendment Right to Procedural Due Process.
I certify under penalty of perjury under the laws of the United States of America and the State of New Hampshire that the foregoing facts regarding the documents filed and statements made across these various dockets are true, accurate, and verifiable via the public record.
Dated: June 4, 2026
Respectfully submitted,
/s/ Jeffrey T. Clay
Jeffrey T. Clay, Pro Se Civics Advocate
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