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The Honorable Paul J.

Fishman
United States Attorney for the District of New Jersey
Dear Mr. Fishman:
My name is Bennett Barlyn. On October 11, 2013, the New York
Times published a front-page investigative piece (attached) about the
circumstances surrounding my termination as an assistant prosecutor
with the Hunterdon County Prosecutors Office by the Christie
Administration. At that time, I served as the Chief of Appeals, Drug
Court and Policy. As recounted in the news article, I was terminated
specifically because I objected to the Attorney Generals preemptive
dismissal of a 43-count indictment obtained by my office several
months earlier against then-Hunterdon County Sheriff Deborah Trout
and two subordinates, including Undersheriff Michael Russo.
Based on the events that I and others witnessed at that time, it
was apparent that the Attorney Generals Office improperly exercised
its broad supervisory power to briefly take over, or supersede, the
Hunterdon County Prosecutors Office as a deliberate pretext in order
to dismantle a viable criminal case that had been developed over a
two-year period. Notably, Sheriff Trout and a key witness were and
remain strong supporters and allies of Governor Christie and
Lieutenant Governor Guadagno. My allegations, both directly and
indirectly, implicate two key Christie Administration officials, namely,
former Attorney General Paula Dow and former Chief of Staff Richard
Bagger, who currently serves as a commissioner of the Port Authority
of New York and New Jersey.
Importantly, two former colleagues at the Hunterdon County
Prosecutors Office have directly and publicly corroborated my
allegations of official misconduct: William T. McGovern, who was then
Chief of Special Investigations, and our immediate supervisor at the
time, Charles Ouslander, the former First Assistant Prosecutor. Both Mr.
McGovern and Mr. Ouslander served with distinction as career
prosecutors for both state and county offices. Several weeks ago, Mr.
Ouslander and I submitted written requests (attached) to the New
Jersey Legislative Select Committee on Investigation asking that it
investigate the events in question. Recently, we received written
confirmation (attached) that the Committee, despite the urging of the
Star Ledger Editorial Board, will not investigate the events in
Hunterdon County. In short, we have no recourse left at the state level
to expose this administrations serious breach of the public trust.

Based on the above, I respectfully ask that your office open an


investigation to explore any potential violations of the federal criminal
code that may have occurred in connection with the Hunterdon matter.
I have the assurances of Mr. Ouslander and Mr. McGovern that both will
cooperate fully if asked to do by your office. Finally, please be aware
that we have amassed a substantial body of documentation that
corroborates the allegations of criminal wrongdoing by the State. Our
contact information is as follows:
Thank you very much for your consideration of my request.

Sincerely,
Bennett Barlyn, Esq.