ARREST WARRANT APPLICATION

STATE OF CONNECTICUT

SUPERIOR COURT

TO: A Judge of the Superior Court

The undersigned hereby applies for a warrant for the arrest of the above-named accused on the basis of the facts set forth in the affidavit below ...

The undersigned, being duly sworn, deposes and says:

1. That, I, David J. Shortt, am and have been a member of the New Milford Police Department for over the past thirteen years. This Officer is currently assigned to the Investigative Services Bureau in the position of Detective. At all pertinent times mentioned herein this officer was acting in my official capacity as a member of said Department.

2. That, on 4/l/97, the New Milford Police Department received a complaint from Craig Swan of the Department of Children and Families of possible sexual abuse between a teacher and a past student at Canterbury School in New Milford, CT.

3. That, Dispatcher Marla Scribner of the New Milford Police Department had received a report from Craig Swan, who stated that his agency received an oral report from Dr. Mark Kirschner who is a therapist located at 3018 Dixwell Avenue, Hamden, CT. Craig Swan reported that on 4/l/97 at 2:46 PM, Dr. Kirschner reported to DCF that a 19 year old male, who for the purposes of this affidavit shall be known as the Complainant, date of birth 9/2/77, disclosed to Dr. Kirschner that he was sexually abused by hockey coach, Joe King, while attending Canterbury School in New Milford, CT. The Complainant reported to Dr. Kirschner that he masturbated and had oral sex with Coach King, as well as, that King attempted anal sex several times but stopped because it was painful and that Coach King did not want to physically hurt the Complainant. The Complainant reported to Dr. Kirschner that Coach King gave the Complainant liquor and attempted to intoxicate him to engage him in sexual activity. The Complainant stated to Dr. Kirschner that the sexual incidents between Coach King and the Complainant occurred approximately one to two times a week from November 1995 to June/July 1996. The Complainant also reported to Dr. Kirschner that the reason he (the Complainant) disclosed this information was because a professional hockey player came out and stated that he was sexually abused by a hockey coach. The Complainant reported that since that time he had been receiving calls repeatedly from King. Dr. Kirschner reported to DCF that the Complainant was referred to him through the trainer of the hockey team at Yale University in New Haven, CT, after the Complainant disclosed this information to other teammates. The Complainant is currently enrolled as a student at Yale University.

4. That, on 4/7/97, this officer interviewed the Complainant at the New Milford Police Department. The Complainant's college hockey coach, Tim Taylor, was present during the interview at the Complainant's request. During the interview, the Complainant detailed his (the Complainant's) relationship with Coach King. Upon completion of the interview this officer took a written statement from the Complainant. At the time the Complainant did not wish to sign the statement. The Complainant stated that he wanted to read the statement over thoroughly and think about it prior to signing the statement. The Complainant left the Police Department with a copy of the statement.

5. That, on 4/18/97, the Complainant and Tim Taylor returned to the New Milford Police Department headquarters. The Complainant wished to make some changes to the original statement. Due to these changes a new statement was typed and eventually signed by the Complainant. In the statement the Complainant states, among other things, the following: "In September of 1995, I began attending the Canterbury School in New Milford, CT. I went to Canterbury as a post graduate student prior to going to college. While at Canterbury I played hockey on the school team. The coach on the team is a male named Joe King. Mr. King lives at the school and his house is connected to a dorm area. Mr. King assigned me my dorm room and it was room #1, which is right next to the Kings house. In June of 1995 coach King told me that I would be living in room #1. In May of 1996 coach King told me that he had fallen in love with me on that day of June of 1995. That is why the coach assigned me room #1 because he always wanted me nearby. The coach did not tell me about this until after our relationship had begun. Mr. King lived in his house with his wife, Johna, and their two children. I became the assistant captain on the hockey team and a dorm proctor. I grew very close to Mr. King and was like a member of his family. I was treated differently than the rest of the team. I was like friends with the coach. He still had a player/coach role over me. In other words, he had control over me from being coach-but he was still like a friend towards me. At this point in our relationship I would do anything for coach King, and I looked up to him. All the players on the team looked up to him and would do anything for him as well. The hockey season started around mid November of 1995, and around this time a sexual relationship began between myself and coach King. I cannot remember at all, the first time with the coach. It is like I blocked it out of memory. I do know that the relationship continued throughout the 1995/1996 hockey season. Late at night he would usually call me from the dorm area into his house. He would masturbate me and have me masturbate him. This occurred on an average of about twice a week. I did not want to do this with Coach King. I felt that it was disgusting and to this day when I think about it I want to throw up . I did it because I felt like I was compelled to and there was no way out of the situation. On a couple of occasions coach King performed fellatio on me. He also had me perform it on him. I did not want to do this but I was extremely pressed into it by the coach. I felt that I had the weight of the world on my shoulders and coach King controlled the weight. The sexual relationship between myself and the coach continued throughout the hockey season. After the hockey season ended the frequency of the sexual relationship lessened. This was because I was trying to avoid coach King and was busy with other school responsibilities. I would estimate that the masturbation took place on about 30 to 35 occasions. Most of the time the sexual relations occurred in the playroom of coach King's house. I would say that it occurred in the playroom about 90% of the time. It also occurred in my dorm room a couple of times. One time coach King made me sleep naked with him in his bedroom when his wife was not at home. The rest of the time it occurred in the living room of coach Kings house. One time we were in my dorm room and the lights were out. A kid named Greg Menchen tried to walk into the room and coach King slammed the door shut before Greg could see anything but he (Greg) was wondering what was going on. I knew I could not avoid sexual relations with coach King so I would try to get it over with as fast as possible. I would have trouble ejaculating when the coach masturbated me. To avoid this and get it over quicker I would sometimes look at dirty magazines before going to see the coach. I would also masturbate him so I could get it over with and get out of there. I would masturbate him so he would ejaculate quickly and this would enable me to get out of the situation as quickly as possible. I would also masturbate him so I could get it over with. One time we were playing an away game at Berkshire and we were beating the other team. We were joking around and coach King said if I made a shot from the blue line he would blow me. He said this so that the whole team could hear it. Everyone thought it was a joke. I made the shot from the blue line. The coach and I had never had oral sex before but that night when we got back to the dorm the coach performed fellatio on me. The whole team thought the coaches comment was a joke, including myself, but it turned out not to be. One time coach King was masturbating me in the playroom. The coach was wearing his wedding ring and it was hurting me. I told him this and he took it off. The next day I was in his office and he told me that his wife had found the ring and asked why it was laying on the floor. I graduated from Canterbury in May of 1996. Before I left school coach King was pressuring me into coming back to the school to see him. He wanted me to come back in two to three weeks. He then handed me a letter that said he knew someday we would be together again. The coach was continually saying that he loved me. During the summer of 1996, a couple of weeks after graduation, Coach King was calling me saying that I should come up to the school and see him. He had such a hold on me I had to go to the school to see him. I had to do what he told me, I went to see coach King during the summer and ended up in his playroom with the coach. The coach gave me some Rolling Rock beer and I think he was trying to get me drunk. I knew the coach wanted to have sex. I wanted to avoid sex so I pretended that I was passing out from the alcohol. The coach was kissing me and touching me. He then tried to have anal sex with me by bending me over the couch in the playroom. This was the first time the coach really tried to have anal sex with me. I clenched my buttocks together to stop him from entering me. The coach was trying to force himself into me. He was saying, "I want to fuck you." I was almost in tears telling him not to and that it hurt. The coach eventually gave up and did not enter me. A professional hockey player named Sheldon Kennedy came out and disclosed that he had been molested by his coach while growing up. After hearing this I decided to tell what had happened to me. I found out about Kennedy on 1/3/97. The first person I told was my best friend, Jill Dillon. I told her about what had occurred between the coach and me. Eventually I told my college hockey coach that I was leaving the team. I told my college coach that I was leaving the team because of past sexual abuse by a coach. At this time I did not tell the college coach who had abused me. Subsequently my college coach spoke to coach King and informed him that I had left my college team. After this coach King started calling me numerous times. Coach was asking me to protect his family. I took this to mean that I should not come out with our sexual relationship. Coach King went as far as to go to where I go to school at Yale University and tried to talk to me. I tried to avoid the coach when he went to the school. During the times I would have sexual relations with coach King at Canterbury School he would occasionally give me alcohol before we had sex. He would give me Rolling Rock beer and mudslides. He kept the alcohol in a liquor cabinet in the kitchen of his house. He kept the beer in the refrigerator or on the porch. He gave me alcohol on about five occasions. During our relationship coach King would often get jealous of my involvement with females. On one occasion the Canterbury hockey team was playing at a tournament in Massachusetts. We lost in the semi-finals. We were staving in a hotel in Massachusetts. The hockey team decided to have a party. At the party I ended up taking a girl to another room. Coach King caught me in the room with the girl, The coach went ape over this. The coach told me I would never play hockey again. He said this in front of the entire team. He was yelling at me. The other players on the team thought he was just mad about the party and the girl in the room. I knew, however, that he was jealous that I was caught in the room with the female. Around early November, 1996, coach King called me at Yale. The coach told me that he had heard I had a relationship with another female from Canterbury while at Yale. The coach was extremely upset about my past relationship with this girl. He was almost at the point of tears. The coach was mad and talked to me like I had "cheated" on him. I just blew him off. The coach was very jealous. Many of the other players on the Canterbury Hockey team knew that my relationship with coach King was kind of odd. I do not think any of them thought it was of a sexual nature. They knew, however, that I was the coach's favorite and could get away with things that the other players could not get away with. One time a fellow teammate, Ron Mongeau, kind of hinted around that there may be a sexual relationship between me and the coach. I denied this to Ron at the time. I wish to press criminal charges against Joseph King for what he did to me. I did not want to take part in the sexual relationship with coach Joseph King."

6. That, on 4/11/97, this officer received a fax from Bob Murphy of the Department of Children and Families. Said fax was a letter written by Joseph King and addressed to the Complainant around the time of the Complainants graduation from Canterbury School. The Department of Children and Families received the copy of the letter from the Complainant's family. The letter states the followin-- "(Complainant), This note is impossible to write-as I say good-bye to my seniors, I find it hard to imagine my day-to-day life without you. Yea, we've been through a lot, but you want to know something everything that has happened between us will only make us the best. This friendship was destined for success from day one-you have this great way about yourself that makes you easy to be friends with yet an even greater side that allows one to be the best of friends with. I only wish that more could see the "total" (Complainant) and not just the cocky one! This reminds me so much of me at your age. As for leaving today-realize that Canterbury has helped you grow-you've been a leader and have experienced friendships that are meaningful. Sadness? Certainly a little but you should also know that it is only that way if it really meant something to you.(Complainant), you know that you are very special to me-I realize how lucky we are to have this friendship-I will treasure it and give it my all to not let this end-I respect admire and honor your time here-be the best at Yale and always lead-set the standards and expectations for being the best. My heart is sad today, but in time I have to trust that we'll be back together, better than ever my boy-remember everything, I love you, I'll never forget you!  Loyalty forever! Love, Coach King"

7. That, During subsequent interview Coach King acknowledged that he did write the letter to the Complainant. Coach King stated that it was a letter written to a graduating student and it merely expressed how the Coach cared for his players. The Coach stated that the letter was not meant to be a love letter and should not be perceived in that manner. Coach King stated that he wrote similar letters to many of his graduating seniors. During subsequent interviews with other players the players stated that Coach King commonly wrote letters to his graduating seniors stating how much the Coach cared for the players. The players were unable to locate any of these letters. During subsequent interview, the Complainant stated that other players may have gotten letters from the Coach but the other letters would not have been as personal.

8. That, on 4/29/97, Joseph King came from his residence in New Hampshire to the New Milford Police Department to be interviewed by Sgt. Edward Golden and this officer. Accompanying Coach King were his attorneys Carmine DiAdamo from Massachusetts and Peter DiBiase from Rhode Island. Prior to the interview Coach King was advised of his Constitutional Rights by this officer. Coach King stated that he understood his Rights and agreed to be interviewed. Coach King was interviewed concerning his involvement with the Complainant. During the interview, this officer as well as Attorney DiBiase took notes. After the interview was completed it was agreed that this officer would type the handwritten notes into a statement form. This statement would then be submitted to Coach King and his lawyers for changes. When the statement was agreeable to Coach King and his lawyers it would be signed.

9. That, the written statement of Joseph King was typed and submitted to Coach King's attorneys. Coach King and his attorneys made changes to the statement and a completed statement was agreed upon. On 6/17/97, Sgt. Edward Golden and this officer drove to Lawrence, MA, and met with Coach King at the office of his attorney, Carmine DiAdamo. At that time, Coach King agreed that the written statement was acceptable and the statement was signed. In the statement Coach King states, among other things, the following: "I am presently employed as the Athletic Director, Varsity Hockey Coach, and History Teacher by the Canterbury School, Aspetuck Avenue, New Milford, CT. I have been employed by the School for approximately the past four years. As hockey coach I have some players who are post graduate students. A post graduate student is a player that has graduated from high school however for whatever reason it has been determined that the player needs another year of high school hockey before going to college. A post graduate student would then enroll in Canterbury and play hockey on the team. In 1994, 1 heard from the coach of the Cornell University hockey team about a player named (the Complainant) who was from Long Island, NY. (The Complainant) had been a junior hockey player and the coach of Cornell University stated that (the Complainant) was a promising player who may be a good candidate for a post graduate position at Canterbury. I first met (the Complainant) in December of 1994, and this was a very brief meeting. The next time I met (the Complainant) was in June of 1995, at a summer hockey camp at Hockey Night in Boston in Darien, CT. (The Complainant) decided to attend Canterbury School as a post graduate student. In September of 1995, (the Complainant) began attending classes at Canterbury School. In my position at Canterbury School I live on campus in housing furnished by the School. I live in the housing with my wife Johna and two young children. I live in Havemeyer House which is a staff apartment attached to a male dorm area. The dorm area contains hockey players, however there are some students in the dorm who are not hockey players. Hockey players comprised 30% to 40% of the dorm. My residence is a two story home which has a direct access to the dorm area. There is a door in my living room area which opens into a hallway and the dorm rooms are located along this hallway. (The Complainant) was assigned to room number one in the dorm area. If you leave the living room of my residence and go through the door into the dorm area, room number one is the first dorm room on the right. Therefore, (the Complainant) was assigned to a dorm room that was closest to my residence. (The Complainant) was assigned to this room by the Dean of Students. I would give the Dean of Students advise on which rooms students are assigned to and therefore would have advised the Dean to assign (the Complainant) to room number one. (The Complainant) was assigned a single room meaning he (the Complainant) is the only student assigned to the room. Two other hockey players, Jeff Brow and Eric Quinlan, shared the dorm room directly across from (the Complainant)'s room. I found (the Complainant) to be a personable and cocky kid who did have talent for playing hockey. (The Complainant) was a defenseman on the hockey team. I intended for (the Complainant) to be one of the plavers that would lead the hockey team. I projected (the Complainant) to be the best of my new players on the team. (The Complainant) is also a very outgoing person and I liked him instantaneously. Jeff Brow was the Captain on the team. Jeff was a returning plaver from the previous year. At the beginning of the school year, there was some animosity between Jeff Brow and (the Complainant). I believe this animosity stemmed from the fact that (the Complainant) was kind of cocky. Brow and his teammates were upset with (the Complainant) "kissing up to the coach." Jeff Brow seemed to have some problems with (the Complainant) at the start of the year. For the good of the entire team it was up to me to bring (the Complainant) into the team and have him accepted by the other plavers. I needed the team to be a cohesive unit working together in order to succeed and win. I needed all of the plavers to buy into the hockey program and think alike as a unit. I worked to have (the Complainant) accepted by the other members of the team. Eventually, I was successful and the team seemed to accept (the Complainant). During this time I became friendly with (the Complainant) as I try to become friendly with all my team members. (The Complainant) was not a peer of mine I was simply friendly with him. My general relationship with all hockey players was to be stern during formal hockey activities and very accessible during off times. (The Complainant) also grew very close to my wife Johna and my children. (The Complainant) would confide in Johna and would discuss day to day problems with her. (The Complainant) was made Assistant Captain on the team along with another player named Greg Menchen. In November of 1995, the hockey season began with (the Complainant) playing on the team. (The Complainant) became very close to another hockey player named Eric Quinlan, (The Complainant) was commonly staying in Eric Quinlan's dorm room, sleeping on the floor. On the first day of hockey tryouts, Eric Quinlan left School. Quinlan was reportedly suffering from some type of depression and had threatened suicide. I was concerned that the stress from the hockey program could have caused Quinlan to have this problem. I put alot of pressure on the players to succeed and I have been concerned that this pressure may be too much for the players to handle. While Eric Quinlan was away from school, (the Complainant) periodically stayed in Quinlan's dorm room. In January of 1996, Eric Quinlan returned to School after receiving treatment for his problem. In February of 1996,Quinlan came back onto the hockey team, Quinlan was not a top player due to the year off, but did practice and dress for some games. Living so close to the dorm area my house was open to the students. The students would constantly be going in and out of my residence, watching television, socializing, and eating food from my refrigerator. My residence became the meet spot for individuals from the dorm. I would stay up to different times during the night depending on my duties. I usually would go to sleep kind of early, however some times I would have dorm duty in which I had to stay up later and make sure everything was okay with the students in the dorm. When I went upstairs to sleep the students would leave my residence for the night. My wife Johna would go to sleep at different times, sometimes she would go to sleep before me and sometimes after me. When the students were at my house there would commonly be a group of students. Occasionally, I would have one on one conversations with a student if they had a problem or just wanted to talk. During these conversations it would be common for other students to be walking in and out of my house while the conversations were taking place. In November of 1995, (the Complainant) was accepted at Yale University under the early acceptance program. After being accepted (the Complainant)'s attitude seemed to change. He had been given what he wanted, acceptance at Yale, and it was like he did not need the Canterbury program any longer. (The Complainant) did not seem to play as hard as he should have been. (The Complainant) did not work to improve. He was basically wasting his time. After the last game of the regular season I had a party at my house for the parents of the players. I have this party after every season. During the party the players went back to their dorm, The last person to leave the party was, I believe, the Brows, and they left about 1 or 2 in the morning. This party occurred on a Saturday night. I believe the following Monday I got a call from the Dean of Students. The Dean told me that she heard the players had a party in their dorm on Saturday night. The Dean said she heard that alcohol was used at this party. I told the Dean I was not aware of a party but I would check. I contacted my Captains, Jeff Brow and (the Complainant), and asked them if there was a party. Both Brow and (the Complainant) denied that there was a party. They said they would go and talk to the Dean themselves to straighten out the matter. Jeff Brow and (the Complainant) went to the Dean and swore to her that there was not a party. The issue was then basically dropped by the Dean. The following Thursday, the members of the team were all together joking around. (The Complainant) let something slip and said something about one of the other players drinking alcohol. I asked (the Complainant) about this and he eventually told me that there was indeed a party with alcohol. Besides being reprimanded no punitive action was taken against the players for this party. I did not actually know who was involved. Therefore, I could not prove who was involved or to what extent. A few days after this party incident, in March of 1996, the team was playing against Andover in a tournament game in Massachusetts. The team lost in this game and was out of the tournament. We stayed at a hotel in Massachusetts anyway because I had not expected to lose and had the rooms booked for an additional night. The players were given the option of going home with their parents who had attended the game or staying at the hotel. Approximately one quarter of the team went home with their parents and the rest stayed at the hotel. I had a meeting with the team and asked them not to have a party. This meeting was very emotional and included a number of subjects. The students get three weeks off for Spring break and this break started the day before, Friday. Therefore the team had lost and their hockey season was over and they had a long vacation coming up. The members of the team agreed not to have a party. During the night I was checking the rooms to keep track of the players. Some students from Canterbury who are not members of the team had gone up to Massachusetts to watch the game. These students were staying at the same hotel that the team was staying at. Late at night, I caught (the Complainant) in his hotel room with Greg Whipple and a female student from Canterbury named Jill Dillon. The other students were having a party. I never saw a hockey player drinking alcohol. I was extremely angry and called the entire team together. I was yelling at the team. I told them how I had done so much for them and they repay me by going directly against my rules. I was screaming at the team. I was not just angry at (the Complainant), I was angry at all the players. I directed some of my anger at the Captains because they were supposed to lead the team and set the example. (The Complainant) was one of these Captains. I talked to (the Complainant) once on the telephone during the spring break. The conversation with (the Complainant) was cordial but not really close. The relationship between (the Complainant) and I had changed since the beginning of the school year. At the beginning of the school year we had grown close. Because of the problems we encountered throughout the year our relationship changed and we kind of grew apart. In mid-April, 1996, my infant daughter Claire became gravely ill. She eventually went to Boston for treatment. We were not sure if she would live. The entire team knew what my family was going through with Claire's illness. My wife and I went to Boston to be with our child. While we were away our house at Canterbury was empty. When Claire's condition improved my wife came back to Canterbury. I had to go to Bowdoin College in Maine for a hockey commitment. While back at Canterbury, my wife learned that our house had been broken into while we were gone. The people who broke in ripped off a window screen to get inside. They apparently drank our alcohol and had a party while inside the house. My wife found out that (the Complainant) was one of the kids who broke into my house. My wife called me and told me what she found out. Johna was extremely angry and hurt that someone would do this to us while we were trying to take care of our sick child. I was away and could not deal with the situation. I had alot of stresses on me at the time, including the illness to Claire. The incident was discussed with the Headmaster. We also discussed the options of how to deal with the matter. It was decided that each of us would deal with it in his own way. I later talked to (the Complainant) and told him that he took advantage of me bv breaking into my house. There was no real discipline taken against the kids for the break in because the Schools Headmaster's daughter was one of the kids with (the Complainant) during the break in. (The Complainant) later told me that there was sexual activity while inside my house. I was only aware of sexual activity and do not know who engaged in it. My wife, Johna, was extremely angry with (the Complainant) about the break in. Johna had been very close to (the Complainant) and felt betrayed by the break in. She was especially angry that they would break in while we were away taking care of our small child while the child was possibly dying. Johna basically wrote (the Complainant) off and had no more to do with him. She never really talked to him again. I was distant from (theComplainant) for a period of time after the burglary. The School was telling me that I still was an educator and had to deal with (the Complainant) because he was a student. Eventually I started talking to (the Complainant) again but our relationship was never the same. Eric Quinlan again left School in May of 1996, and (the Complainant) basically moved into Eric's room. (The Complainant) was not spending much time with the team or with me, he was in a play and was always at rehearsal. I heard that (the Complainant) was smoking marijuana, He seemed to have changed a great deal from the kid I first met at the start of the school year. He did not seem to care anymore. I did not know how to reach (the Complainant).(The Complainant) graduated from Canterbury in May of 1996. Towards the end of the school year I was talking to (the Complainant) and trying to find out what was wrong with him. (The Complainant) said something that disturbed me immensely.(The Complainent) told me that he was similar to the way Eric Quinlan had felt. (The Complainant) said something along the lines that he understood how Quinlan felt. Eric Quinlan was the individual who had a problem with depression and was reportedly contemplating suicide. I was worried that (the Complainant) was considering suicide. I was concerned that all the stress and problems we had been through during the year had taken their toll on (the Complainant). I did not want to be responsible for (the Complainant) hurting himself. I knew that (the Complainant) had been close to Johna and was hurt when she cut him off because of the break in. During the summer months, after (the Complainant's) graduation, I would hear from him occasionally. I was working at a hockey camp up at Bowdoin College and (the Complainant) had talked about coming up with a friend to visit. I told Johna and she said she did not want (the Complainant) at her house. I had to tell them not to come. I would occasionally hear from (the Complainant), like I hear from most of my ex-players. In January of 1997, I talked to Tim Taylor the coach of the Yale hockey team. I learned that (the Complainant) had taken a leave of absence from the Yale team. Tim Taylor said that he did not know what was wrong with (the Complainant). I asked if I could help and he said yes. I tried to contact (the Complainant) on numerous occasions. I was concerned for him in light of what he had said about Quinlan. I left messages on his voice mail and messages with his roommates. I would sit in my office during the day and call him four or five times. I had trouble reaching (the Complainant). I left messages on his voice mail, telling (the Complainant) that I needed to know what was going on and that I had to protect my family. By saying this, I meant that I wanted to know what was wrong with him because I was concerned for (the Complainant). I also meant that I was concerned what it would do to my family if something happened to (the Complainant). That my family and I would somehow be responsible. I eventually made contact with (the Complainant) and he said that he would come up to Canterbury and see me. (The Complainant) came up to Canterbury on Super Bowl Sunday. (The Complainant) did not look like the same person. He looked like he had problems. (The Complainant) and I agreed that I would go to Yale and we would go out to dinner on a particular evening. At that time we would discuss what was goingon. I went to New Haven to have dinner with (the Complainant), however he did not show up to meet me. I never had any type of a sexual encounter or relationship with (the Complainant). I have never had any contact in a sexual manner with any of my students at Canterbury. I never gave alcoholic type beverages to any of my students at Canterbury. I have had students who graduated from Canterbury and then returned to visit me and I had a beer with these students. In the Fall of 1996, (the Complainant) and Jeff Brow visited me at Canterbury. I gave them a drink at my residence. We drank beer together. It was a situation with returning friends coming to visit and we had a drink. I commonly had alcoholic beverages in the refrigerator at my house or on the back porch. I was asked by the Police if I was ever alone late at night in my residence with (the Complainant). I may have been alone with (the Complainant) on occasions, discussing issues in his life, but there was nothing sexual taking place. There is not enough privacy in my residence to carry on a sexual relationship. There is always someone walking in and out of the residence. I was asked by the Police if I was ever alone in (the Complainant's) dorm room with the door closed when Greg Menchen tried to enter the room. I do not specifically remember this incident but it could have happened. I could have been in the dorm room having a personal conversation with (the Complainant) about a problem he was facing. The Police showed me a letter that I wrote to (the Complainant) in which I say that I love him and personal comments. I write letters like this to all my players at the end of their Canterbury career. It is also common for me to hug my players and tell them that I love them. I do love the players that have played for me. The Police asked me if I ever called Yale looking for (the Complainant) and mistakenly talked to his roommate thinking it was (the Complainant). I do seem to remember this happening, it was when I was trying to find out what was wrong with (the Complainant). I talked to his roommate and briefly mistook him for (the Complainant). The Police asked if I ever spoke to (the Complainant) around November of 1996, and asked him if he had a past relationship with a female at Canterbury. I did have a conversation with (the Complainant) in which he told me that he had a past relationship with a girl named Laura Alamo. I was not in anyway jealous or upset by the news of this relationship. (The Complainant) just told me about it like two friends talking. The Police asked me whether I ever made a comment to (the Complainant) that if he made a goal from the blue line I would blow him. I do not specifically recall making this comment, however I may have said something like that. I would occasionally joke around with the players in this way. The hockey team often would make sexual comments but the comments never had a sexual connotation. Obviously, many team members in many sports engage in this kind of banter during athletic activities and practices."

10. That, on 4/29/97, Johna King, the wife of Joseph King, accompanied her husband to Police Headquarters to be interviewed. Johna King was interviewed by Sgt.Golden and this officer with Attorney DiBiase and Attorney DiAdamo present. Handwritten notes were taken of the interview by Attorney DiBiase and this officer. This officer subsequently compiled a written statement based on the notes of the Johna King interview. The statement was then submitted to the King's attorney's for changes. The requested changes were made and the statement resubmitted to the Attorney's. On 6/17/97, Sgt. Golden and this officer met with Johna King at Attorney Carmine DiAdamo's office in Lawrence, MA. At that time, Johna King read over her statement, agreed with the contents, and signed the statement form. In the statement Johna King states, among other things, the following: "I am married to Joseph King, who is employed by Canterbury School in New Milford, CT. Joseph is employed at the School as a History Teacher, Athletic Director, and Varsity Hockey Coach. Joseph and I lived on the School campus in housing provided by the School. We lived in Havemeyer House with our two small children. Havemeyer House is a dorm with our residence at one end of the building. Our residence is a two story house with bedrooms on the second floor. There is a livingroom and playroom on the first floor of the residence. Off of the livingroom is a door which leads directly to a main hallway that the dorm rooms are located off of. When you leave my livingroom and enter the dorm hallway the first room on the right is room number one. A student named (the Complainant) was assigned to dorm room number one the year before last. (The Complainant) was assigned room number one by the Dean of Students. (The Complainant) was a post graduate student playing on the hockey team.Some of the students in the dorm were members of the hockey team. I would have daily contact with students from the dorm. I was friendly with (The Complainant) as I am with most of the players. (The Complainant) and I had a good relationship in which he would confide in me. (The Complainant) also was friendly with my husband, which is not surprising, because Joe becomes friendly with all his players. (The Complainant) became a proctor in the dorm, meaning he was responsible for making sure the other students did what they were supposed to. (The Complainant) was also made Assistant Captain on the hockey team. The students from the dorm, mainly the hockey players, would commonly congregate in my residence. They would watch television in the living room and socialize. There were always students coming and going from my residence. When Joe and I went upstairs to go to sleep the students would leave the house for the night. Most of the time Joe and I went upstairs to sleep around the same time. Occasionally he would stay up a little later and on other occasions I would stay up later. Because the dorms were located right next to our house and the students would be coming and going from the house it was difficult to have privacy. If you tried to have a private one on one conversation with a student there were always interruptions with other students walking into the residence. In February of 1996, after the hockey teams last home game Joe and I had a party at our house for the parents of the players. The players stayed in their dorms during the party. The party was on a Saturday night. The following Monday Joe was contacted by the Dean of Students. The Dean said that she had heard the players had a party in their dorm on Saturday night and alcohol was served. Joe asked some of the players, (the Complainant) included, if this was true. The players all adamantly denied that there was a party with alcohol. The players went to the Dean and told her that there was not a party. The following Thursday, (the Complainant) said something jokingly to another player in front of Joe about the player drinking alcohol. At that point Joe realized that there had been a party and questioned (the Complainant) further. (The Complainant) eventually admitted that there had been a party and that he lied when initially questioned about it. I know most of the information about this incident from being told about it from my husband. The hockey team then played in a tournament in Massachusetts. The team lost in the tournament and after the loss stayed over at a hotel. There were students from Canterbury also staying at the same hotel. The students were just about to go on a three week spring break. Joe asked his players not to have a party at the hotel. The players agreed not to have a party. Joe was doing rounds at night checking the rooms of his players. Joe caught (the Complainant) in a room with a female named Jill Dillon. Some of the other players were having a party. Joe was extremely upset and mad at (the Complainant) about this situation. Joe told me that he screamed at him over this situation. Joe was angry that the players had this party after he specifically asked them not to have a party. I was not staying at the hotel and did not observe the incident take place. I was told about the incident by my husband. After the incident in Massachusetts the student went on their three week spring break. When they came back to school, I did not see as much of (the Complainant) because he was a member of the spring musical. (The Complainant) was often at rehearsal for the play. During the 1995-1996 hockey season there was a great deal of stress on my family. I was pregnant at the time with our third child. It was a very difficult pregnancy and I was sick quite often. I eventually miscarried. During the Spring of 1996, one of our other children, Claire, became ill. We did not know if she was going to survive. We had to bring Claire to Boston for treatment. When we went to Boston we left the house at Canterbury empty. When I returned to the house at Canterbury I eventually discovered that the house had been broken into while we were away. The persons who broke in had torn off a window screen in order to gain entry. One of the students told me about the break in, but did not tell me the names of the persons involved. I then spoke to (the Complainant) and he told me the names of four students who had broken into my house. (The Complainant's) name was not included in these four names. I went to one of the students named and asked the student about the break in. That student told me that (the Complainant) was also involved in the break in. I could not believe that these students would break into our home while we were away taking care of our sick child. I especially could not believe that (the Complainant) would break in after we had treated him like a family member. I learned that the students broke in and were drinking the alcoholic beverages we had in the house. I learned that the students involved were (the Complainant), Andrew Santonelli, Justin Webber, Molly Sheehy, and Caroline Foley. After the break in I wanted nothing more to do with (the Complainant). Originally, I did not speak to (the Complainant) but eventually I was cordial and civil to him. I had no interest in maintaining a ftiendship with (the Complainant). Joe did not have as close a relationship with (the Complainant) after the break in as he had previously. After the break in Joe did not speak to (the Complainant) for awhile. Joe was reminded by the School that he was an educator and he had to get along with the students. Joe and (the Complainant) eventually began to speak again. (The Complainant) eventually graduated from Canterbury in May of 1996. In August 1996, Joe and I were at our summer home. Joe still had some contact with (the Complainant) however they were not as close as they had been at the beginning of the 1995 school year. (The Complainant) was talking to Joe about coming up and visiting us at our summer home. I told Joe that I did not want (the Complainant) at our house. I did this because of the break in and because the summer months is our time to be away from the students and spend time together. In the Fall of 1996, (the Complainant) came to our house at Canterbury for a visit. I did not ignore him but was not overly attentive to him. I do not believe the allegations made by (the Complainant) against my husband. Joe is not the type of person to be involved in something like what is being alleged. I do not know why (the Complainant) is making these allegations. Because of the constant flow of people through our house at Canterbury I do not think that what (the Complainant) is saying could be true without someone seeing."

11. That, on 4/18/97, Sgt. Golden and this officer interviewed James Newton at New Mlford Police Headquarters. James Newton is presently a roommate of the Complainant at Yale University and heard many of the calls from Coach King. A sworn written statement was taken from James Newton in which he states, among other things, the following: "I am presently a freshman at Yale University in New Haven, Connecticut. I live in a dorm room on the university campus, I live in the dorm room with three other Yale students. The dorm is basically like a suite with two bedrooms and then a common living area. One of the males in my dorm room is named (the Complainant). (The Complainant) is also a freshman at Yale University and is a member of the Yale ice hockey team. Around January of 1997 (the Complainant) told me that he was thinking about quitting the ice hockey team. He said he was thinking about quitting because of personal reasons and because he was not able to concentrate on the game of hockey. A period of time went by, I believe it was at least a week, and (the Complainant) did in fact quit the ice hockey team. The dorm I share with (the Complainant) and the other two guys has a common telephone which is also hooked up to a voice mail system. Around February of 1997 (the Complainant) started getting telephone calls from a person who identified himself as Coach King. (The Complainant) told me that Coach King was his (the Complainant's) hockey coach at Canterbury school. There were a number of these telephone calls from Coach King. (The Complainant) did not seem to want to talk to the coach and asked us to take messages. To the best of my knowledge, I must have taken at least 10 messages from Coach King. At the time I felt Coach King was calling because he was concerned that (the Complainant) had quit the ice hockey team. I am on the Yale swim team and if I abruptly quit the team I would probably be called by my high school coach also. The calls from Coach King continued. At one point I was sitting on the couch in my dorm and the phone rang. I answered the call and it was Coach King. The coach mistook me for being (the Complainant) and started talking to me thinking I was (the Complainant). The coach started saying to me that he missed having me in his life and that he needed me. At the beginning of the telephone conversation the caller wouldn't tell me who he was, he just kept saying that I knew who it was. I thought the call was a prank call and I just decided to play along with it. The way the caller spoke to me, made me feel uncomfortable. Eventually I told the caller I had to go to swim practice, and at that point he said "oh, this isn't (the Complainant)?" I said that it wasn't and he told me to have (the Complainant) call Coach King. The telephone call was then completed. The calls from Coach King to our dorm, looking for (the Complainant) continued, throughout all hours of the day and night. One evening around 6:30 pm I was alone and the phone rang. I answered it and it was Coach King. The coach said that he wanted to know where (the Complainant) was. I told him I didn't know where (the Complainant) was. The coach said he was downstairs in his car. The coach said that he was supposed to go out to dinner with (the Complainant). I said I didn't know where (the Complainant) was and the coach said he was going to hang around New Haven for a little while waiting for (the Complainant). The telephone conversation then ended. A little while later (the Complainant) showed up at the dorm. I told (the Complainant) about the phone call from Coach King and he stated that he was not going out to dinner with Coach King. (The Complainant) then left the dorm. About an hour later, coach called again and I told him I hadn't seen (the Complainant) and didn't know where he was. The phone conversation then ended. Later that night (the Complainant) came back to the dorm and (the Complainant) and me went out to Subway to get something to eat. We brought the food back to the dorm and while eating we had a conversation. I pointed out to (the Complainant) that he had stood Coach King up for dinner. He also had not returned any of the coaches numerous telephone calls. I was concerned for (the Complainant) because he seemed scared and anxious. I was asking him what was going on in the hopes that I could help him. (The Complainant) said that Coach King was in love with him (the Complainant)and that Coach King had abused him while at Canterbury. I didn't ask for more detail, I just told him that I would be there for him. (The Complainant) said that it was difficult because Coach King had controlled his entire life. After this, the calls from Coach King continued but occurred less frequently. (The Complainant) continued to evade the calls. The calls had lessened to about one every other day. During the peak time, to the best of my knowledge Coach King had been calling between 3-5 times a day. The coach also left messages on (the Complainant)'s voice mail. At one point, (the Complainant) came home and was listening to his voice mail messages. (The Complainant) abruptly slammed down the phone and said he could not listen to them any longer. The call was from Coach King and he couldn't stand to hear it. (The Complainant) then asked me to listen to the voice mail calls and tell him (the Complainant) what the coach said. I listened to the calls and the coach said "I really need to talk to you (the Complainant), you and I know what I'm talking about." Coach King said I'm worried, I haven't slept for days and you know I have a wife and kids to think about. You have to tell me everything is going to be O.K. Coach King said basically you have to tell me everything's O.K. because this could ruin my family. The coach said I understand how you feel, it must be hard for you, you don't have to talk to me you can just leave a message at my office when I'm not there. Just please tell me everything is going to be O.K. During the voice mail message, the caller did identify himself as Coach King. This was the last telephone call we have received from Coach King."

12. That, on 5/7/97, Sgt. Golden and this officer interviewed Vincent Clevenger who is a student and hockey player at Canterbury School. Vincent Clevenger was on the hockey team when the Complainant was a member. A sworn written statement was taken in which Mr. Clevenger states, among other things, the following "I heard that (the Complainant), a former player at Canterbury, has made allegations of sexual misconduct against our hockey coach Mr. Joseph King. (The Complainant) was a post graduate at Canterbury last year and neither he or I had played hockey for Canterbury before. We got along pretty well but we went our separate ways, with different friends and interests. (The Complainant) was a assistant Captain with the team. (The Complainant) got along well with Coach King, they were good friends. (The Complainant) was treated the same way as other players by Coach King. If there was any favoritism it was because (the Complainant) was Assistant Captain. I lived in the same dorm as (the Complainant) and Coach King. We had study hall from 7:30 to 9:30 PM. But after 9:30PM we could visit each other but had to be in our rooms by 11 PM. Very rarely would we be up after 11:00 PM, maybe to watch a hockey game until 11:15 or 11:30 at Coach King's house. Coach King let all the students and players come in, relax, watch TV, or talk. I don't remember if (the Complainant) would be in Coach King's house late at night, everyone would usually go back to their rooms by 11:00 or 11:15 PM. If students had a problem they could always talk to Coach King. I was always in my room by 11:00 PM because I wanted to follow the rules and not lose my position and status for my following year. When I heard about these allegations (the Complainant) was making against Coach King, I was shocked. I could not understand the timing of it either. I was never approached inappropriately by Coach King in a sexual way. I never knew anyone else who was either, off of last years team, that is why I have a hard time believing it. Coach King is good friends with all his players. We as a team would joke around all the time with locker room type jokes. One time after a game in Massachusetts I heard from another player that Coach King had jokingly said that if (the Complainant) had made a goal from the blue line he would blow him. We commonly joked about things like this. I never knew or thought it was serious at the time. I never heard it at the time only after the game. There was some partying going on but I never participate in it, I had my own agenda. I never saw Coach King give alcohol or offer alcohol to any of the players on the hockey team. I knew Coach King to commonly have alcohol at his house. I never saw it out in the open. (The Complainant) sometimes got into trouble. I heard (the Complainant) and a group of 7 or 8 kids broke into Coach King's house when he was away. Mrs. King was very mad because she was caring for a sick child when this happened. Coach King seemed to forgive (the Complainant) for this but Mrs. King was still angry. The sexual allegations that (the Complainant) is making against the Coach, I'm not sure I believe them. I never heard of any other sexual type relationships between any other player and Coach King last year. I need to say that this year I heard from a fellow player, Brian Bufkin, who confided in me about a week ago about an incident he had with Coach King around mid-February. Brian Bufkin told me that he and a few players were at Coach King's house on a Saturday night just hanging out. The players all left Coach's house but Brian and Coach King were still there alone. Brian told me that Coach told him he was happy that Brian bought into the program. I heard that Coach King was drinking alcohol that night because other players told me and so did Brian. Brian told me that the Coach sat on top of him while they were on Coach King's sofa. Brian said that Coach King had the room really dark with only a candle lit and some music on. Brian said that while Coach King was sitting on him, the Coach hugged Brian and then kissed him, placing his tongue in Brian's mouth a short time. Brian confided in me and I believe what Brian had said. Brian didn't tell me if anything else had happened. This incident with Brian happened in mid-February 1997."

13. That, on 5/8/97, Sgt. Golden and this officer interviewed Bryan Bufkin at Police Headquarters. Subsequently a sworn written statement was taken from Bryan Bufkin in which he states, among other things, the following; "I heard recently that (the Complainant) had made an accusation that Coach King had made improper sexual advances towards (the Complainant), I heard that there was an allegation of a sexual relationship between Coach King and (the Complainant). I had heard rumors about this relationship recently and about two weeks ago I was approached by my Captains who confirmed that the allegation was made. I was not shocked by the allegation. I was not shocked because in February of 1997, a bunch of the players were hanging out at Coach King's residence. It was around Valentines Day, because we had a Valentines Day dance around that time. The room was kind of dark and Coach King had a candle burning. I was with some of the players and the Coach. We were looking at a picture of a past hockey team at Canterbury. Coach King was drinking wine, but the other players were not. The other players started to leave and Coach King asked me if I wanted to stay and hang out with him. I said yes, and stayed while the other players left. Coach King was talking about our relationship. He began to play with my hair. He said that he loved me. He said that the burning candle kind of signified our relationship. I felt uncomfortable and did not know what to do. I was scared and did not know how to get out of the situation. Coach King kind of got on top of me and kissed me on the mouth. I did not know how to stop him. He said that he loved me. He stuck his tongue down my throat as he was kissing me. I knew I had to get out of there. I told him I had to go to sleep. I got up and went to leave. Coach King hugged me and kissed me on the mouth. He said he loved me. I went back to my dorm room. I stayed up all night because I could not sleep. I got back to my room around midnight. I was upset about what happened with Coach King. I was scared and confused. The next day I saw Coach King at a brunch. I could not even look at Coach King. I was very confused. Coach King did not say anything about what had happened. I decided to never get into a situation like that with the Coach again. I always avoided being alone with Coach King. Coach King has done a lot for me. I did not want to see the Coach get into trouble. Coach King always seemed to care for me, he did everything for me, and he was there when I needed him. I have known him for four years and I think he is a great guy. I think the Coach knew how I felt about him and he took advantage of it. I wished I had not put myself in that position of being alone with the Coach. I feel it may have been my fault that this happened with the Coach. If I had not been alone with the Coach it would not have happened. The Captains I told about this incident were Ron Mongeau, Vince Clevinger, and Graham Morrell. During the year (the Complainant) was on the team I lived off campus with mv family. Therefore I did not have alot of knowledge about what happened between Coach King and (the Complainant). During that year I also got sick and was not around alot. I do not know alot about Coach King and (the Complainant) because of not being there. I do not know of Coach King giving alcohol to any players. I was not around that much. I would like to say that the incident between Coach King and I was not mutual. I did not want it to happen. At this time I do not wish to make a complaint against Coach King. I just told this information in response to questions about (the Complainant's) allegation. I have not heard from (the Complainant) since the early winter, 1996. (The Complainant) has in no way pressured me into disclosing what occurred between Coach King and I. The incident with Coach King occurred in the study area in his residence."

14. That, on 5/8/97, Sgt. Golden and this officer interviewed and took a sworn written statement from Ron Mongeau. In the statement Mr. Mongeau states, among other things, the following; "I heard about these allegations that (the Complainant) is making against Coach King over Spring break in March of 1997. I first heard about this from my girlfriend, Lisa Ficks, who told me what (the Complainant) had said. Lisa and (the Complainant) are friends and (the Complainant) confided in her about these sexual allegations sometime around January or February of 1997. Lisa did not tell me about this until after the hockey season was over. Lisa told me that (the Complainant's) problems were from Coach King and his sexual advances toward (the Complainant). Lisa told me that (the Complainant) was going to talk to an NHL player named Sheldon Kennedy about these sexual advances since the same thing happened to Sheldon Kennedy when he was playing junior hockey somewhere. I was really shocked by what Lisa was telling me. I spoke to (the Complainant) on the phone later that day and asked him about what he had told Lisa. (The Complainant) told me that he and Coach King had a physical sexual relationship. We talked about what happened a little bit and (the Complainant) told me that he and Coach King did alot of touching each other back and forth. (The Complainant) told me about how he and Coach would touch each others penises. We also talked about Sheldon Kennedy and how he came out about past sexual abuse. (The Complainant) said Sheldon Kennedy told him that he should come forward with this situation. I didn't talk with (the Complainant) again until Easter time 1997 when Lisa and I went to Yale and had lunch with (the Complainant). (The Complainant) then disclosed more details about his and Coach King's sexual relationship. (The Complainant) told both Lisa and I that there was more than touching going on between him and Coach King. (The Complainant) said that there was oral sex between both of them. (The Complainant) said that he blew Coach and that Coach would blow him. (The Complainant) also told us that one time Coach King bent (the Complainant) over a couch in coach's house and tried to have anal sex with (the Complainant). (The Complainant) said that he told Coach no and Coach King then stopped. (The Complainant) never told me how many times the oral sex took place or the masturbation. Sometime around April 9th 1997, I was contacted by Mr. Bob Murphy from DCF (Dept. of Children and Families) State of Connecticut. Mr. Murphy asked me if (the Complainant) had talked to me about this situation and I told him yes. I then told Mr. Murphy everything I knew about the incident. I also talked to my roommate, Vince Clevenger, about this. I know that Coach King and (the Complainant) were very close but I never suspected a sexual relationship, only a friendship. I was really unsure about these allegations at this time. About a week ago a fellow teammate, Bfian Bufkin, talked to myself and Vince Clevenger and told us about an incident which occurred between he and Coach King. Brian said that one Saturday night after a game he and other players (myself included) were at Coach's house looking at a plaque and team picture. Coach had the room dark with only a candle lit. Coach King talked about the candlelight's reflection and the reflection of teams before and the present team. I remember that night and Coach King doing this with some of the hockey players. We all left around 12:30 AM and went back to our dorm rooms. Brian was still at Coach King's house alone. Brian said that he was sitting in a rocking chair across from Coach King, who was sitting on a love seat in the study. Coach King then asked Brian to come and sit next to him on the love seat, Brian said. Brian also said that Coach King told him that they had a special relationship, more so than Coach had with any other player on the team. Brian said that Coach King had his arm around him while he was speaking to him. Brian said that Coach then got on top of Brian and was sitting on him. Brian said that Coach King then kissed him and stuck his tongue down his throat. Brian said that this kiss lasted a few seconds and then Coach King told him that he loved him. Brian then said he got up off of the love seat and went to leave Coach's house. Brian said that Coach King then hugged him again and told him that he loved him. Brian said that Coach King then kissed him on the lips again before Brian left and went back to his dorm room. Brian said that this incident with Coach King took place sometime around mid-February 1997. After Brian told me about this incident with Coach and began to believe what (the Complainant) had been saying about Coach King. I believe Brian to be really credible so if Brian said this happened between Coach King and him then I think it is the truth. Brian would not lie about this and Brian told me and Vince about this because he thought that some of us may have had the same experiences. Coach King has never made any sexual advances towards me and I don't know of any other students/players who have experienced that. One time during a game in Massachusetts last year we were beating Berkshire pretty badly and the team lightened up. Coach King told Jeff Brow that if he scored during the next shift he would blow him. Jeff had an empty net but did not score. (The Complainant) then said to Coach, "If I score will you blow me?" Coach King told (the Complainant) that if he scored from the blue line he would blow him, and (the Complainant) scored a goal. Comments like that happened on the team."

15. That, on 5/9/97, Sgt. Golden and this officer interviewed and took a sworn written statement from Graham Morrell in which he states, among other things, the following: "I was not on the team at the time (the Complainant) was at Canterbury. I came to the School after (the Complainant) had graduated. I have met (the Complainant) when hevisited Canterbury from college. I also visited Yale when I was looking at colleges and I met with (the Complainant) and Jeff Brow who were Yale students. I have heard rumors about (the Complainant) doing drugs. I also heard that (the Complainant) could be kind of weird, joking around sexually. I never personally had any problems with (the Complainant), I only heard about him through rumors. When I first heard about the allegations against Coach King I did not believe them. I just thought (the Complainant) was some messed up kid telling lies. I have (the Complainant's) old room and I am in mainly the same position (the Complainant) was the previous year. Coach King never tried anything sexual with me. I have since changed my opinion because I have since spoken to another kid named Bryan Bufkin. Bryan told me that Coach King tried something sexual with him. I believe what Bryan told me, Bryan does not lie. Brian also loves Coach King and it was very difficult for him to tell me what happened. Bufkin does not want to bring Coach down but he does not want to see anyone else hurt. I also remember the night Bufkin was talking about. We were in Coach King's study room. The lights were off and a candle was burning. Coach Kin was drinking wine and it seemed like it was getting to him. It was a Saturday night. We were just hanging out at Coach King's. Bryan Bufkin was sitting there next to Coach King's and Coach had his arm around him. Around 1:00 am, all the other kids went to bed. I was still there with Coach King and Bryan Bufkin. I left and went back to the dorm area for about 15 minutes. I then returned to Coach King's and his dorm was still open. Coach King was still sitting there with Bryan Bufkin. I sat there with them for about 5 minutes and then said good night and went to bed. I went back to my dorm room for about 5 to 10 minutes. I then left my room and went to visit another kids room. When I did I saw that Coach's dorm was closed. I knew this meant Coach had gone to bed and no more visitors. This past Monday, I knew something was bothering Bryan Bufkin by the way he was acting. I thought it was because Coach King was away from the School. I told Bryan that he could talk to me. We were alone in my room. Bryan said, "I do not want to do this to you." I knew that Bryan had a more serious problem with Coach King. Bryan started crying. He did not want to hurt Coach King he loved him. Bryan told me that the night of the Valentines Day dance, he (Bryan) was at Coach King's house late at night alone. The candle was burning and Coach King was talking about how it related to their relationship. Coach was saying to Bryan how he (Coach) was pleased that Bryan had bought into the program. Bryan said that Coach King then started touching his (Bryan's) hair. Coach then got on top of Bryan and kissed him. Bryan said that Coach tried to stick his tongue down Bryan's throat. Bryan said that he got out of there and stayed away from Coach since. I knew Bryan was telling me the truth about this incident. Bryan Bufkin does not lie. Bryan Bufkin cannot sleep since this problem came out. When Bryan eats he just throws it back up. I have never been given alcohol by Coach King. I do not know of Coach King giving alcohol to any other student. I wish to point out that when Bryan was telling me about the incident with Coach King, Bryan told me that when he pushed Coach King off of him and went to leave, Coach King hugged and kissed Bryan as Bryan was leaving."

16. That, on 5/5/97, Doug Chernovetz the Head Football Coach, History Teacher, and Director of Student Activities at Canterbury School came to the New Mlford Police Department wishing to speak on behalf of Coach King. Coach Chernovetz stated that he believed the charges made against Coach King are false and the Coach is a fantastic guy, trusting, and a mentor to Coach Chernovetz. Chernovetz stated that he shares an office with Coach King and socializes with the Coach and his wife at the King's house about 5 to 6 nights a week. Coach Chernovetz stated that Coach King had an open door policy with the students and would have 6 or 7 kids in his (King's) home all the time, allowing them to come and go as they pleased, Coach Chernovetz stated that he never witnessed any inappropriate behavior by Coach King with any of the Canterbury students. There was never any hint of a sexual relationship with a player. Coach King is described as a person who loved his players and was loyal and extremely devoted to his players. Coach Chernovetz was not at Canterbury when the Complainant was a student and therefore did not know the Complainant. Coach Chernovetz stated that he heard the Complainant had experimented with drugs, was not considered a team player, and was only concerned for himself. Coach Chernovetz stated that he heard the Complainant had dropped out of the hockey program at Yale University and he was well known for his drug use while at Yale.

17. That, on 5/5/97, this officer interviewed Jan Flaska who is the Assistant Athletic Director, Assistant Hockey Coach, and Math Teacher at Canterbury School. Jan Flaska stated that he came to the Police Department to speak to this Officer in support of Coach King. Coach Flaska stated that he has known Coach King since he (Flaska) was a freshman on the Bowdoin College hockey team and Coach King was the Assistant Coach on the team. Coach King later went to Canterbury School as hockey coach. When Coach King's Assistant Coach at Canterbury School, Greg Carvel, left for another School Jan Flaska was hired at Canterbury. Jan Flaska began working at Canterbury in the Fall of 1996, and was not present when the Complainant was a student. Jan Flaska stated that he met the Complainant last year and the Complainant seemed to be a very loud kid who craved attention. Jan Flaska stated that he does not believe the allegations made against Coach King for one moment. Coach Flaska stated that a normal evening in Havemeyer Dorm consisted of the following: 7:30-9:30 PM the students have study hall, 8:00-8:30 PM the King children go to bed, 9:30 PM Johna King would commonly go to bed, 10:15 PM the students must be in the dorm, 11:OO PM lights out in the dorm however the students sometimes stay up later on weekends, and 11:15-11:30 PM Coach King would commonly go to sleep however sometimes he would go to sleep earlier. Jan Flaska stated that the door between Coach King's house and the dorm is never locked and the students constantly come and go from Coach King's house up until the Coach goes to sleep. The students do not commonly knock when they go into the Coach's house.

18. That, on 5/24/97, Sgt. Golden and this officer again interviewed Jan Flaska. A sworn written statement was taken from Jan Flaska in which he states, among other things, the following: "Recently Coach King has been accused of some type of sexual misconduct with a player named (the Complainant). After hearing about the allegation I did not believe it could be true. I did not think Coach King could do what he is accused of. I decided to go to the Police and tell them my feelings about Coach King. I went to the police station with the Canterbury football coach. We told the police about our feelings for Coach King and our belief that Coach King was not the type of person to have done what he is being accused of. While at the police station I spoke to Det. Shortt and told him that I did not believe Coach King was guilty. I spoke to the police about them interviewing the other hockey players about their contacts with Coach King. I then left the police department and returned to Canterbury. When I got back to the School one of the first persons I saw was a hockey player named Bryan Bufkin. I told Bryan that the Police would want to interview him as well as the other players. A couple of days later I saw Bryan Bufkin again. I mentioned to Bryan again that he would be going to the Police Department to be interviewed. At that point Bryan asked if he could talk to me. Bryan then told me about an incident that took place between him and Coach King. Bryan said that one night around February of 1997, Bryan was at Coach King's house late at night with some other hockey players. There was a candle burning in the room. The other players gradually left the house and Bryan was the only one remaining with the Coach. Coach was sitting next to Bryan. The room was dark except for the candle. Coach King said something about the candle burning and somehow equated the candle to Bryan. During this time, Bryan said that the Coach was playing with Bryan's hair. Bryan said that Coach King then somehow sat on top of Bryan and kissed him. Bryan said that after the kiss Bryan got up and left the room. I was shocked by what Bryan Bufkin said to me. I am very close to Bryan and know him to be very honest and straight forward. I know Bryan would not tell a lie and that what he said about Coach King is the truth. Bryan was visibly upset when he told me about the incident with Coach King. He was not crying or shaking when he told me but I could tell it was not easy for Bryan to tell the story. From the story I was told by Bryan Bufkin I believe Coach King tried something with Bryan Bufkin and when the Coach realized Bryan was not comfortable with the situation the Coach stopped. I do not know what to think of the (Complainant's) complaint in light of the disclosure from Bryan Bufkin. I think Bryan is the kind of person who would never have made the disclosure about the incident with Coach King if he did not have to go and be interviewed by the Police because of the (Complainant's) complaint. Bryan was close to Coach King and would not want to hurt the Coach. I think Bryan would not have said anything about the incident, but Bryan knew he could not go to the Police and lie. Bryan knew he had to tell the Police about the incident with Coach King. The disclosure by Bryan Bufkin has kind of changed my opinion about the allegations made against Coach King. I believe Bryan totally and know he is telling the truth. I still care about Coach King and hope that it all works out for the Coach."

19. That, on 6/6/97, Sgt. Golden and this officer again interviewed Jan Flaska at Police Headquarters. During the interview Jan Flaska stated that he had recently visited Coach King at the Coach's residence in New Hampshire. Jan Flaska went to the Coach's residence in order to bring the King family some personal items from their residence at Canterbury School. Jan Flaska stated that while at the residence Coach King asked him (Flaska) how Bryan Bufkin was doing. Jan Flaska stated that the Coach was the person who brought up Bryan Bufkin's name and it was not brought up based on a statement from Flaska. Jan Flaska stated that he informed the Coach that Bryan Bufkin was upset but was dealing with the situation. Coach King told Jan Flaska that he (King) did kiss Bryan Bufkin but the kiss was merely a sign of affection and was in no way sexual. Coach King told Jan Flaska that Bryan Bufkin must have misunderstood the incident. The Coach said that if he (King) could speak to Bryan Bufkin, he (King) could make Bufkin understand that the incident was in no way sexual. These officers pointed out to Jan Flaska that the incident reported by Bryan Bufkin involved the two individuals sitting together, late at night, in a darkened room, with candlelight, on a loveseat, music playing, Coach King drinking wine, Coach King sitting on Bryan Bufkin, the Coach playing with Brian's hair, the Coach telling Bryan that he loved him, the Coach kissing Bryan and sticking his tongue down Bryan's throat. During a further interview with Jan Flaska, he (Flaska) informed these officers that Coach King had kissed another male while at Canterbury. Jan Flaska stated that he (Flaska) recently had a conversation with the Head Football Coach Doug Chernovetz. At that time Doug Chernovetz told Jan Flaska that at one of Coach King's parties Coach Chernovetz and Coach King had been drinking a great deal of alcohol and were rather intoxicated. Towards the end of the evening they were sitting around talking about how they cared for each other and then Coach Chemovetz and Coach King kissed each other on the lips.

20. That, on 6/17/97, Sgt. Golden and this officer traveled to Lawrence, MA., and met with Johna King and the King's attorney, Carmine DiAdamo. The purpose of the meeting was to have Mrs. King review and sign her original statement, as well as, discuss some follow up questions these Officers had concerning the investigation. These Officers met with Johna King and attempted to interview her concerning the Bryan Bufkin incident. At the time this officer mentioned the Bufkin name I was stopped by Attorney DiAdamo. Attorney DiAdamo then requested that I go into another room to speak with him. In the other room Attorney DiAdamo advised me that Johna King was unaware of the Bryan Bufkin allegation. Attorney DiAdamo also advised me that Canterbury School had decided not to renew Coach King's contract for future employment. Attorney DiAdamo stated that Johna King was unaware of both of these situations and requested that we not speak to her about them due to her fragile mental state. Johna King was therefore not re-interviewed.

21. That, on 6/17/97, Sgt. Golden and this officer interviewed Joseph King with his attorney, Carmine DiAdamo, present. Said interview took place in Carmine DiAdamo's law office in Lawrence, MA. Prior to the interview Joseph King was advised of his Constitutional Right. Coach King stated that he understood his Rights and agreed to be interviewed. These officers then questioned Coach King concerning the Bryan Bufkin allegation. Coach King stated that he remembered an incident with Bryan Bufkin sometime around the first playoff victory or the start of the playoffs. Coach King stated that they were sitting around listening to Frank Sinatra and that it was a very emotional night. Coach King stated that he had a long history with Bryan Bufkin overcoming obstacles together. Coach King stated that he and Bryan were discussing the great experiences they had together and felt that it was a very emotional time going into the playoffs. Coach King stated that the candle light was to whip the team into a frenzy, to get them prepared for the playoffs. Coach King stated that he remembered the incident with Bryan but it did not totally happen the way Bryan described it. Coach King stated that the attorney for Canterbury School had previously interviewed him (King) and told him the allegation made by Bryan Bufkin. The Coach told these officers that he did kiss Bryan on the mouth but he did not recall sticking his tongue in Bryan's mouth. Coach King again stated that it was an emotional time between he and Bryan and that it was not intended to be sexual. Sgt. Golden then advised Coach King that Bryan had described the incident as sexual and very uncomfortable stating that he and Coach King were on a loveseat together, Coach King was playing with his hair, the room was dark with music playing, Coach had told him (Bufkin) that he loved him, and then kissed him placing his tongue in his mouth. Coach King stated that he did not expect us to understand his relationships with his players, but it was an emotional night and he did not recall placing his tongue in Bryan's mouth. Coach King stated that Bryan must have been confused and misinterpreted the situation. Coach King stated that he would like an opportunity to speak with Bryan and his family so he could explain it to them. These officers then asked Coach King about an incident between King and the Canterbury Football Coach, Doug Chernovetz, after a party. These officers had learned during the investigation that Coach King and Mr. Chernovetz had kissed. Coach King stated that he recalled the incident we were talking about. Coach King stated that he had a party at his residence for other staff members at Canterbury School. Coach King stated that near the end of the evening, he and Mr. Chernovetz did kiss each other on the lips. Coach King stated that they had been drinking alcohol throughout the night and that he and Mr. Chernovetz have a mutual friendship and admiration for one another. Coach King stated that there was nothing sexual about his kissing Mr. Chernovetz or Bryan Bufkin. Coach King continued to deny having an ongoing sexual relationship with the Complainant. Coach King also denied having homosexual or bisexual tendencies. In conclusion to the interview these Officers then offered a polygraph test to Coach King concerning this investigation. Attorney DiAdamo stated that Coach King would not be taking a polygraph test based on Attorney DiAdamo's personal beliefs and past experiences with lie detector tests.

22. That, Sgt. Golden and this officer interviewed a number of the Canterbury hockey players. Written statements were taken from these players. The majority of the players were very supportive of Coach King stating that they did not believe the allegations made by the Complainant. Most of the players do not recall observing the Complainant coming and going from Coach King's house late at night. Some players remember hearing Coach King make the blue line comment but state that it was common to make these kinds of jokes on the team. Numerous plavers recall the party at the hotel in Massachusetts in which Coach King yelled at the team. A number of the players do not feel the Coach singled out any one player, but rather he yelled at the entire team. Most students stated that early in the School year the Complainant and Coach King were very close but as the year went by certain incidents put a strain on Coach King's relationship with (the Complainant). For example, (the Complainant) broke into the Coaches house and took alcohol. On Senior Night, (the Complainant) and other students drove to New York State and got beer. They brought the beer back to the dorm and had a party. Coach King later found out and was angry. The Coach was extremely angry over the whole situation with the entire team. Even with these problems Coach King and (the Complainant) still talked. Near the end of the school year (the Complainant) sent Coach King a letter saying that he did not want to be the Coaches friend anymore because of problems at home. The Coach wrote back saying that if he felt that way good luck and maybe they could be friends again in the future. Many of the players describe the Complainant as a cocky person who seemed to believe he was better than everyone else. Some of the players stated that the Complainant would sometimes joke around about homosexual type issues. Some of the players state that they recently heard that the Complainant was messing with drugs and not interested in playing hockey. The players state that they never saw anything sexual between the Complainant and Coach King. The students in Havemeyer dorm have to be in bed by 11:oo PM and the proctors stay up to monitor the students. The activity around Coach King's house quiets down around 11:00 to 11:30 PM, therefore people no longer walk in and out of the Coach's house. The Coach usually stays up later than his wife, Johna. The majority of the players describe Coach King as a very affectionate person who commonly hugged and kissed his players. One of the players, Christopher Yurco described an incident in which Christopher was leaving Coach King's house and gave the Coach a hug. Coach King stated that he loved Christopher and gave him a kiss on the lips. Christopher just left and did not think anything else about the incident. Christopher describes the kiss as just something between friends and was not an open mouth kiss. Christopher states that one time on a bus trip Coach King played a pornographic tape on the television that was on the bus. The Coach seemed to sense that Christopher was not the type of person who liked to be touched. The Coach would joke around with Christopher that Christopher was not a cuddler. Another one of the players, Greg Menchen, stated that he does not recall the incident in which he reportedly tried to walk into the Complainant's dorm room and Coach King slammed the door shut. According to Menchen, Coach King never gave Menchen alcohol while he (Menchen) was a student. In June, 1996, after Menchen graduated he went back and visited Coach King. They hung out and Coach King gave Greg Menchen a Rolling Rock beer. This occurred at Coach King's house at Canterbury School. Greg Menchen's date of birth is 6/22/77, and at the time he was given the alcohol by Coach King he was under the age of 21. Another of the players, Andrew Santonelli, stated that Coach King never gave alcohol to Andrew. According to Andrew, the Coach did give alcohol to Sean Sullivan who was a postgraduate student in the Spring of 1996. Around 1:00 to 2:00 AM Sean Sullivan came into Andrew's room and told Andrew that he (Sullivan) had been drinking at the Coaches house. During interview Sean Sullivan stated that he was never given alcohol by Coach King while a student at Canterbury. After graduation Sean visited Coach King at his house in Rye, New Hampshire and they had a couple of beers together. This was around August of 1996, and was the only time Sean drank with Coach King. While a student at Canterbury, Sean would occasionally drink alcohol on campus but never with Coach King. Sean does not remember another student asking him (Sean) about drinking. Another ex-player, Jason Charella, states that after he (Jason) graduated from Canterbury he returned to the School to visit and would drink alcohol with Coach King. They had a beer together and this occurred the summer after Jason graduated from Canterbury. At the time, Jason Charella was 20 years old. Michael DiBiase, another ex-player, stated that after graduation if Michael went back to Canterbury for a visit he may have a beer with the Coach.

23. That, on 5/8/97, this officer took a sworn written statement from Greg Carvel who was the Assistant Hockey Coach at Canterbury at the time the Complainant was a member of the team. In the statement Greg Carvel states, among other things, the following: "I lived in an apartment on the second floor on the opposite end of the dorm from Joseph King's house. I would commonly go to Joseph King's house at night to socialize with Joe and the other players on the team, Joe's house was a gathering place for the team members. I would normally stay at Joe's house until 10:00 PM. I would normally watch television in Joe's livingroom. Joe's wife Johna would normally go to bed a little earlier than us, probably around 9:30PM on a normal night. Joe would normally go to bed around 1O:OO PM. When Joe was awake there were constantly kids coming in and out of his house. One of the hockey players was a kid named (the Complainant). (The Complainant) was a post graduate who was brought in to play one year. (The Complainant) was assigned the first dorm room right outside Joe King's residence. (The Complainant) was assigned this room by Joe King. It was not uncommon for the Coach to assign the post graduate players to the room closest to the Coach. These players were expected to be major contributors on the team. Coach King worked to get (the Complainant) accepted by the other players. This was not an easy task because (the Complainant) could be arrogant, cocky, and deceitful. Eventually the other players accepted (the Complainant). Coach King and (the Complainant) became friends. (The Complainant) seemed to enjoy this close relationship with the Coach. Eventually (the Complainant) was made Assistant Captain of the team by Coach King. During the season Coach King and (the Complainant) had a couple of problems. One time (the Complainant) and some other players had a party in the dorm on campus. Apparently at the party they were drinking alcohol. A couple of days later Coach King found out about this party. Another time we were playing in a tournament in Massachusetts. We lost in the tournament, but we were still staying at a hotel in Massachusetts. Joe had a team meeting and told all the players that he did not want any parties and did not want any girls, who were also staying at the hotel, in any of the rooms. Some players, including (the Complainant), violated these requests by Joe King. Coach King was extremely upset that the players had a party, with girls in the rooms, against his (King's) wishes. Another time Joe King's baby daughter was gravely ill. The family had to leave campus for treatment out of state. While they were away (the Complainant) and some other kids broke into Joe's house. I understand that they drank alcohol while in the house. There were apparently girls present and there may have been some sexual involvement but I am not sure. I do not know of the students being punished for these incidences. I believe they were just reprimanded for their actions. I did not see a major change in the relationship between Coach King and (the Complainant) over these incidences. Coach King may have reassessed how loyal he believed (the Complainant) was, but their relationship did not seem to change greatly. Joe King's wife, Johna, was more angry at (the Complainant) over the break-in and their relationship seemed to cool greatly. I never had any suspicions of anything sexual occurring between Coach King and (the Complainant). I never had any suspicion about anything sexual between Coach King and any player. Coach King is an emotional type of coach and would occasionally hug and kiss players during emotional moments. These incidents never seemed sexual. I never knew of any players to go to the Coaches house late at night, 11:00-11:30 PM, Coach King did not stay up that late. I never knew Coach King to give alcohol to any of the players at Canterbury. If a graduated player who was in college came back he may have a beer with them, but never with a current player. I never had a player voice a concern about Joe King to me. (The Complainant) would commonly joke around in a sexual mwmer. (The Complainant) would joke around about male/female issues as well as male/male type locker room humor. (The Complainant) would also joke around with a kid named Craig Whipple, where they would put their arms around each other. Coach King would participate in the locker room type humor. This was one of the ways for Coach King to be a friend with the kids. Coach King put pressure on his players to perform. One player, Eric Quinlan, had a problem before the beginning of hockey season. Joe King kind of questioned whether the pressure from hockey contributed to Quinlan's problem. The Coach knew, however, that Quinlan's problems stemmed from other issues and were not related to hockey. Quinlan's problem came about prior to the beginning of the hockey season. I have had conversations with Coach King and I know that Joe King is aware that Eric Quinlan's problems did not stem from hockey or the pressure put on by the hockey program. I absolutely believe Joe King to be innocent of these allegations."



24. That, Sgt. Golden contacted Eric Quinlan via telephone in order to set up an interview. Eric Quinlan stated that he did not wish to be interviewed until he talked to his father who is a lawyer. On 6/12/97, Sgt. Golden spoke to Lou Quinlan, Eric's father, who stated that in his opinion Eric would not have anything substantial to say and it would only be hearsay information. Lou Quinlan stated that Eric feared the Police would focus their questions on his psychological nervous breakdown while attending Canterbury School. Lou Quinlan stated that Eric has recovered from the breakdown and did not wish to rehash everything about it. Lou Quinlan stated that Eric is close friends with the Complainant and he (Lou Quinlan) has spoken to both Eric and (the Complainant) about the allegation. Lou Quinlan stated that when he first heard of the allegation he was concerned that the same thing may have happened to Eric in order to cause the breakdown. Lou Quinlan stated that he has since had lengthy conversations with his son and is confident that nothing sexual occurred between his son and Coach King. Lou Quinlan has also asked Eric's counselor if Eric ever disclosed any sexual molestation. The counselor stated that nothing was disclosed by Eric. The Complainant once told Lou Quinlan about Coach King listening at the dorm window while (the Complainant) was discussing a sensitive issue with another player. Lou Quinlan also stated that during "hockey night" Eric Quinlan's coach could not make it to the game so Coach King was their coach for that night. This was the first time that Eric had ever met Coach King. Eric told his father after the game that Coach King had said some unusual things to the team. Eric said during a huddle before the game that Coach King asked all the players if they would give a blow job for $500,000.00. The players all said no, then Coach King said would you do it for a million, and they said no. Coach King then asked what about 10 million and some said yes they would for that money. Lou Quinlan stated that Eric described Coach King as "weird" after that game.

25. That, on 6/12/97, this officer interviewed Jill Dillon at Police Headquarters. A written statement was taken from Jill Dillon in which she states,among other things,the following; She graduated from Canterbury in 1996, and while attending the School was pretty good friends with the Complainant. Around April of 1996, the Complainant started to act a little odd. The Complainant would start to say something about Coach King and then would stop. He would say that something was going on between Coach King and himself, but he would then say that he could not say anything else. The Complainant would say that Coach King was kind of like stalking the Complainant. Jill did not understand what the Complainant was trying to tell her. In December, 1996, Jill had a couple of telephone conversations with the Complainant. During the call the Complainant was in school at Yale and Jill was at Skidmore College. During the other phone conversation Jill was at her mother's house in Florida. During these conversations, the Complainant disclosed to Jill that Coach King and the Complainant had an ongoing sexual relationship. The Complainant said the relationship involved masturbation and occurred mainly in the living room of Coach King's house. It also occurred in the Complainant's dorm room. The Complainant said that one time Greg Menchen tried to walk in the Complainant's dorm room while the Complainant and the Coach were involved in a sexual act. The Coach slammed the door shut. Jill Dillon does not believe Coach King is the type of person to force the Complainant to do something he does not want to do. Jill does not know if something consensual could have taken place. Jill states that during the incident at the hotel in Massachusetts she (Dillon) got intoxicated and ended up in the Complainant's room. Coach King caught her in the room and was extremely angry. Jill Dillon's impression was that Coach King was angry that his players were having a party after their loss. Jill Dillon does not believe Coach King was in anyway jealous of her relationship with the Complainant. Coach King did not seem to like Jill Dillon. The Coach was nice to her face but she heard from the hockey players that he did not like her or any of the girls at Canterbury. In the couple of years that Jill Dillon has known the Complainant he has tended to exaggerate stories to a drastic and misleading level. The Complainant almost seems to misunderstand conversations. Jill Dillon feels the allegations against Coach King might have a little truth to it in other words there could have been one incident of consensual sexual behavior but not to the extent that the Complainant is saying.

26. That, during this investigation this officer was contacted by a number of people who stated that they wished to be character witnesses for Coach King. These individuals stated that they have no suspicions about the Coach being involved with a player in a sexual way and they do not believe that would occur. None of the individuals have direct knowledge of the Coaches relationship with the Complainant.

27. That, on 6/18/97, Sgt. Golden and this officer processed the King residence at Havemeyer Hall on the campus of Canterbury School. Joseph King had signed a Consent to Search for the residence. Sgt. Golden took 35 mm photographs of the residence. This officer videotaped the residence. Sgt. Golden drew a sketch of the first and second floor interior of the residence. While in the home, Sgt. Golden went to the master bedroom on the second floor of the residence. This would have been where Johna King stayed during many of the alleged incidents. This officer went to the livingroom and study area on the first floor of the residence. While in these areas I spoke in a normal to loud voice. Sgt. Golden reported that he could not hear anything I had said.

28. That, this officer executed a search and seizure warrant on the Southern New England Telephone Company in New Haven, CT. Said search warrant was issued in order to seize telephone toll records for calls coming from Canterbury School telephone lines and Coach King's telephone lines going to the Complainant's dorm room at Yale. The records were from the time period when the Complainant states the Coach was calling him (the Complainant) trying to persuade the Complainant not to reveal their relationship. The records show that during the months of January, February, and March of 1997, there were thirty four telephone calls made from these telephone lines to the Complainant's dorm. The majority of the calls are for one minute.

29. That, on 8/13/97, this officer met with the Complainant at his attorney's office in New Haven, CT. I asked the Complainant if he could be more specific as to the dates when the alleged sexual assaults took place. The Complainant stated that he could not recall the specific dates but by using a schedule showing Canterbury's hockey games for the 1995-1996 season he may be able to relate the sexual assaults to when specific hockey games were played. Using the hockey schedule, the Complainant was able to give more specific dates when incidences occurred between the Complainant and Coach King. A sworn written statement was taken from the Complainant in which he relates a number of these incidences, including the following: "On 2/24/96, we played a home game against Gunnery and it was senior night. After the game a group of us went to New York and bought beer. We brought the beer back to the dorm and had a party in the dorm. The next day 2/25/96, Coach King heard about the party and asked us about it. We told him that there was no party. Later I was joking around with Don Richardson and accidentally let it slip about the party. Coach King heard me and was extremely mad. Coach King even threatened to pull Canterbury out of the upcoming tournament. I was pleading with the Coach to let us play. He said he would only let us play in order to give me my chance to win a championship. He was sitting in a rocking chair in his house. He told me to go around the dorm and tell all the other players that I had convinced Coach King that no party had occurred, That the Coach did not know about a party. I did this and went around the dorm. I then went back to Coach King's house. We were in the play room and he was sitting in the rocking chair. Coach King then performed fellatio on me. This occurred late at night, probably around midnight, and the Coaches wife was upstairs in bed."

30. That, on 9/17/97, this officer interviewed Lee Williamson of the State of Connecticut, Department of Education, Legal Affairs Division. I asked Mr. Williamson for his agencies definition of the term secondary school. Mr. Williamson stated that the Department of Education considers a school with grades 9 through 12 to be a secondary school. Therefore according to Lee Williamson, Canterbury School is considered by the Department of Education to be a secondary school. This officer contacted J.P. Mandler who is the Dean of Canterbury School. Mr. Mandler stated that Canterbury School is an accredited high school through the New England Association of Schools & Colleges and the State of Connecticut, Department of Education.



31. That, with the consent of the complainant this officer received from Canterbury School a copy of the complainant's school transcripts. Said transcripts show the complainant took the following courses and received the following grades; Shakespeare B-, Vietnam B-, Calculus A-, Pascal A+, World Religion B, Biotechnology B-, Art History D, Theater Workshop B, Chaucer B-, Calculus A-, Computer Literacy C+, World Religions B-. The records indicate that the complainant had one unexcused absence in one course during the year. The complainant earned 5.50 credits during the year which according to J.P. Mandler, Dean of Students, is average.

32. That, on 3/24/98, this officer interviewed the complainant concerning his schooling at Canterbury School. A written statement was taken from the complainant in which he states, among other things, the following: "I graduated from a private Catholic high school in Long Island in 1995. I went to Canterbury as a post graduate in order to help me get into an Ivy League school for college. I needed to prepare and take the SAT II. I was not sure my grades were good enough coming out of high school to get into an Ivy Leaoue school. I went to Canterbury to improve my grades and play hockey. I attended classes at Canterbury just like any other high school student. I was serious about my classes during the first semester. I then got accepted into Yale and in my second semester I did not do as well but I still passed. In the first semester I was about a B student. In the second semester I was about a C student. I took some difficult courses and did not take remedial courses at Canterbury. I earned the required number of credits while a student at Canterbury. I did not miss a great deal of classes due to absenteeism. Coach King was never a teacher in any of my classes. He only coached me in hockey and was my academic advisor. In this position he would go over my grades and advise me on my school work. My schooling at Canterbury helped me take the SAT II and eventually helped me in getting into Yale."

33. That, this officer received a copy of Joseph King's personnel file from Canterbury School. Joseph King had signed a consent for the release of the file. The file states that Joseph King was employed by the School as Director of Athletics, Varsity Hockey Coach, and History teacher.

34. That, on 10/22/97, the New Milford Police Department received ftom the Canterbury School a copy of a letter dated 10/9/97 written by Attorney John Shearman of Danbury, CT. In the letter, Attorney Shearman states that he represents the family of Phillip vonHollander who was a hockey player for Canterbury School. Attorney Shearman states that while at Canterbury, Phillip vonHollander observed that Coach King encouraged behavior among team members which was immoral and deviant. According to the letter this behavior included the Coach showing sexually explicit films and encouraging or condoning masturbation by some members of the team as they watched the movies. According to the letter, the Coach also gave his favorite team members the key to his office for meetings with girls, encouraging sexual behavior. The letter states that Phillip vonHollander believes his failure to participate in these activities resulted in his being passed over by the Coach for playing time. The letter by Attorney Shearman was reportedly written to Canterbury School in response to the School demanding payment on an overdue tuition balance.

35. That, on 10/31/97, Sgt. Golden and this officer interviewed and took a sworn written statement from Phillip vonHollander. In the statement vonHollander states, among other things, the following; "Soon after I began playing for Coach King I began noticing some inappropriate behavior from both Coach King and the players. There was alot of sexual joking around between Coach and the players. Coach King would grab the groins of the players as they walked by or he would attempt to grab at them. One time during my sophomore year, we played a tournament up in Buffalo, New York. On the bus ride back ftom Buffalo Coach King put in a porno tape into the VCR/TV on the bus. It was about 1:00 AM and all the players and Coach King watched this porno movie. There was no other adult/faculty on the bus, with the exception of the bus driver. The porno movie showed men and women having sex and alot of the hockey players were masturbating during the movie. There were 5 kids masturbating right around the seats next to me and I know of at least 3 other kids who were masturbating on the bus. Coach King knew about all the players masturbating because it was common knowledge and the players were talking about it and hooting and yelling. It was very obvious that he (Coach King) knew that the masturbating was going on and he did not try to stop it. Coach King was even commenting about the movie, and saying crude things about what was happening while the movie was playing. I saw many of the players around me who were masturbating ejaculate. Also during my sophomore year at Canterbury I knew Coach King would give his office key out so that players could take girlfriends in and have sex with them. One of these incidents I remember was with a player named Jason Cherella and his girlfriend Kate Daily. I saw them in the hallway out in front of Coach King's office. Jason showed me the key and told me that Coach gave it to him so he could go in the office with Kate. Jason was asking me to leave so he could have privacy with Kate. During my Junior year, Sept. 1995, things like this seemed to be getting a little worse. The livingroom atmosphere really became perverted. Alot of the sexual joking was going on and Coach and players were grabbing at each others groins. Coach King would grab his groin and tell his players to 'suck his dick.' Coach King would also grab himself in the groin area. One time, back up at the Buffalo tournament, a player named Justin Webber said that if we won he was going to jerk off. We did win the tournament and when we got back into the lockerroom Justin Webber began to masturbate. Coach King just stood there and watched him masturbate. Justin was really masturbating and not just kidding around. His penis got hard and he was excited and Coach just watched and made some type of comments to him. Coach King allowed alot of sexual inappropriateness around him and never tried to stop it, even encouraging it. I left Canterbury School halfway through my Junior year because I was not getting the hockey playing time that I was promised. I felt Canterbury was not holding up to there agreement with me. I kind of kept to myself while I was at Canterbury and did not belong to Coach King's inner circle of players. Because of this I did not get the hockey playing time that all of the other kids got who were close to him. Another factor in leaving was because of Coach King's attitude toward this sexual behavior. Coach King also gave alcohol to underage students who had left Canterbury and returned to visit. I remember one time a former player, Mike DiBiase, came back for a visit and stayed with Coach King. Mike DiBiase was given Rolling Rock beer by Coach King and Mike was underage."

36. That, this officer interviewed a number of the hockey players concerning what took place on the bus trips. The players all acknowledged that pornographic movies were played on the bus trips. According to the players, these movies were played while Coach King was on the bus and he knew they were being played. Some of the players stated that other players were masturbating while watching these movies. All of the players interviewed denied that they themselves were masturbating. The players could not say if Coach King knew about the masturbating but some players stated that he (King) had to know because it was not hidden and the players joked about it afterwards. Some of the players interviewed stated that Coach King would occasionally joke around in a sexual manner with the students. This joking around involved grabbing each other in the groin area or sitting on each others lap acting as a gay couple.

37. That, Sgt. Golden and this officer went to the Kelley Transportation Company in Torrington, CT., which supplied the buses to the Canterbury Hockey team. These officers observed that the buses were equipped with a VCR and television screens. It was observed that from any seat on the bus, except the drivers, the television screens could be observed.

38. That, on 2/17/98, this officer took a written statement from Herbert Kranepuhl who was a bus driver for the Kelley Transportation Company and often drove the Canterbury Hockey team. In the statement Mr. Kranepuhl states, among other things, the following; "I never wanted the students to put the videotapes into the VCR. I did not want the VCR to get broken so I felt it would be best if only the coaches touched the VCR. Many times the Canterbury hockey team would play X-rated videotapes while on the bus. I believe most of the time the assistant coach would put the X-rated video into the VCR. Sometimes the kids would touch the VCR and put the X-rated tapes into the VCR. I know they were X-rated videotapes because I could hear them playing. Coach King would just sit there in his seat while the videos were playing. He did not stop the videotapes. I do not know what the kids were doing while the tapes played. The X-rated tapes were mainly only played on the long bus trips."

39. That, this officer respectfully request that an arrest warrant be issued for Joseph King, date of birth 10/23/63, for the charges of Sexual Assault in the Second Degree Three Counts committed on or about 2/25/96, between thedates of 1/96 to 6/96, and between the dates of 11/95 to 12/95 and Delivery of Alcohol to a Minor Two Counts committed between the dates of 11/95 to 12/95 and between the dates of 1/96 to 6/96 in violation of Connecticut General Statutes 53a-71, and 30-86, in New Milford, CT.


DATE &

SIGNATURE

JURAT



FINDING

The foregoing Application for an arrest warrant, and affidavit(s) attached to said Application, having been submitted to and considered by the undersigned, the undersigned finds from said affidavit(s) that there is probable cause to believe that an offense has been committed and that the accused committed it and, therefore, that probable cause exists for the issuance of a warrant for the arrest of the above-named accused.

DATE & SIGNATURE





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