AFFIDAVIT OF JAMES CATHCART

My name is JamesCathcart. I am over 2l years old and am duly competentto testifu to

the matters set forth herein. I voluntarily provide this statement. I have personal knowledge of

the matters stated in this affidavit, and if called upon to testiff under oath in this case, I would

stateas follows.

1. Between 2005 until September20l0, I was employed by defendant,Town of Cheverly as

a Police Officer.

2. During my employment, the Cheverly Police Department never posted any of the

required notices explaining employees' rights. The Cheverly Police Department never

postedthe Departmentof Labor or EEOC's notices on Equal Employment, FMLA, FLSA, or

required notices on Worker's Compensationrights.

3. I am currently employed as a Police Officer by the New Carrolton Police Department.

4. In December 2008, I attendedthe Police Department's Christmas Party. The Party was

held at the Legion Hall. Alcohol was served. Chief Robshaw becameseverally intoxicated

at the Christmas party.

5. I observed that Donna Schmidt, wife of Officer Schmidt, was playing pool. Chief

Robshaw walked up behind her with a pool cue. Chief Robshaw proceededto shove the pool

cue under her dressbetween her legs. Chief Robshaw then raised the pool cue so that it lifted

up Donna's dress and came in contact with her pelvic region. This causedDonna to jump

and to try to get away. After Donna removed the pool cue from between her legs, she walked

away with a look of disbelief on her face. Chief Robshaw then turned to me and said: "I

want to bend her over the pool table and fuck the hell out of her."
6. Chief Robshaw routinely made statementsduring staff meetings that clearly conveyed the

messagethat he would punish anyone who challenged him or attempted to exercise their

right to report unfair treatment or unlawful practices by him or the department.

7 . On more than one occasion, Chief Robshaw threatenedto fire any officer who ever made

an internal or external complaint against him or the department. Chief Robshaw made clear

that he is the one who appoints the Trial Boards and that any officer that challenges him

would never work in law enforcementagain.

8. I did not report Chief Robshaw's behavior at the ChristmasParty in 2008 becauseof fear

of retaliation.

9. During my employment, Chief Robshaw often boastedto me regarding his various extra-

marital affairs and his sexual exploits with numerouswomen.

I have read and understandthe above nine (9) paragraphs. Based on my personal knowledge,

every fact above is true and correct. I solemnly affirm under the penalties of perjury of the

State of Maryland and upon personal knowledge that the contents of the foregoing 9

paragraphsare true and correct.