From a complaint filed in March by a North Bergen, New Jersey, lieutenant against the department’s chief.

On multiple occasions, the chief has exited the bathroom in his office and exposed himself to others in the room, making inappropriate comments such as, “Hey, look, it’s bigger than you thought, right?” The chief has pulled his pants down and defecated on the floor in front of his entire staff. During a cleanup of his former office, the chief defecated in a trash can. Only after persistent urging did the chief eventually agree to clean it up days later. He also deliberately damaged officers’ personal property by breaking pens and smearing ink on uniforms, vehicle door handles, and office equipment, leaving officers with ruined clothes and ink-stained faces. He has placed spray-paint cans under officers’ vehicles, causing paint explosions when driven over. The chief has gone into rages where he smashes items in the office. These outbursts include ripping a television off the wall and smashing it on the ground, throwing staplers across the room, smashing picture frames on the walls, and breaking glass that scatters across the office. On several occasions, he has thrown eggs. The chief also has a habit of placing hot peppers in officers’ food and heating them in the microwave. The chief also tampered with office coffee by adding prescription medications such as Adderall and Viagra, causing staff to experience the effects without their consent. In one incident, he poisoned a corporal’s fish, causing all of them to die.