FOR IMMEDIATE RELEASE
False RICO Allegations Against Whistleblower Retired Lieutenant Quathisha Epps Accused of Weaponizing the Courts to Intimidate, Retaliate, and Distract from NYPD Command-Level Misconduct She Helped Expose
New York, NY – July 18, 2025 – Attorney Eric Sanders of The Sanders Firm, P.C., denounces what he describes as knowingly false and retaliatory allegations leveled against Retired Lieutenant Quathisha Epps in the federal RICO complaint filed by Thomas Donlon. While court filings are privileged and do not constitute defamation under New York law, Sanders asserts that the complaint’s references to Epps—including the fabricated claim that the FBI raided her home—represent a grave abuse of the judicial process. He contends that these allegations were made without an evidentiary basis and appear designed to intimidate a known whistleblower who previously exposed misconduct by former NYPD Chief of Department Jeffrey B. Maddrey, including unlawful personnel movements and a pattern of quid pro quo favoritism.
In the federal civil RICO complaint Thomas G. Donlon v. City of New York, et al., Plaintiff Thomas Donlon makes several references to Epps that warrant serious scrutiny, not only for their lack of factual foundation but for their potential violation of Federal Rule of Civil Procedure 11. These references—particularly Paragraphs 998, 999, 1262, and 1263—are neither incidental nor accidental. They reflect a calculated effort to weaponize the judicial process. They are targeted. They are retaliatory. And they are being leveraged to manufacture an illusion of widespread criminality around a decorated whistleblower who did nothing more than tell the truth.
The allegations assert that on January 2, 2025, federal agents executed a search warrant at Epps’s residence in connection with an overtime fraud scheme allegedly orchestrated under Maddrey. The suggestion is plain: Epps is under criminal investigation, her time records are fraudulent, and her service to the department was part of a larger conspiracy. None of this is true.
There was no FBI search of Epps’s home. There is no criminal investigation involving her. She has never been the subject of any law enforcement inquiry. Epps previously filed a formal EEOC complaint in December 2024 detailing the pattern of sexual coercion, favoritism, and retaliation by Maddrey and his allies—allegations now twisted and repurposed in Donlon’s lawsuit to distract from their original gravity. These are not contested facts; they are public realities. Yet the complaint treats them as credible allegations, weaponizing the imprimatur of federal court filings to elevate conjecture into headlines. This is not a pleading defect—it is a calculated distortion.
Federal Rule of Civil Procedure 11(b)(3) requires that factual contentions in a pleading must have evidentiary support, or at the very least, must be likely to have support after a reasonable investigation. The inclusion of the false search warrant claim, without corroboration, violates that rule. Either Donlon and his counsel conducted no investigation, or they proceeded with reckless indifference to the truth. In either case, the result is the same: the courts are being used as a platform for reputational damage rather than as a means of legal redress.
Worse still, Paragraphs 998 and 999 illustrate a broader pattern of mischaracterization. The complaint claims that Epps and others “extensively” claimed overtime under Maddrey’s direction, insinuating that this labor was unjustified or criminal. The reality is far more damning—for the NYPD, not for Epps. She was repeatedly ordered, often on short notice, to perform sensitive operational work: reassigning officers without process, responding to crises of Maddrey and his minions’ own making, cleaning up after retaliatory transfers, and managing personnel placements that served no legitimate departmental interest. These tasks were not glamorous. They were not optional. They were not invented.
They were part of a coercive power structure in which Epps’s labor was misused—not for her benefit, but for the benefit of senior leadership. These were quid pro quo demands masquerading as orders, and the record reflects that her service was coerced, not volunteered. Her time was not inflated; it was exploited.
In wage-and-hour law, the burden of maintaining accurate payroll records rests squarely with the employer, not the employee. Federal law under the Fair Labor Standards Act (FLSA), 29 U.S.C. § 211(c), and New York Labor Law § 195(4) make this duty explicit. Employers must “make, keep, and preserve” detailed records of hours worked and wages paid. When they fail to do so, the law authorizes employees to reconstruct their hours using reasonable approximations of their actual hours worked. Courts have repeatedly affirmed that this is not only permissible but also a legal safeguard to prevent employers from profiting from their noncompliance.
Recreated records are not inherently suspicious and do not constitute fraud. They are legally recognized substitutes where employer records are deficient. In Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946), the Supreme Court held that once an employee presents a just and reasonable inference of work performed, the burden shifts to the employer to disprove it. The Second Circuit reaffirmed this principle in Grochowski v. Phoenix Construction, 318 F.3d 80 (2d Cir. 2003), emphasizing that employees are not required to prove their hours “with mathematical precision,” and that courts may credit estimates and memory where employer records are absent or incomplete.
New York courts have fully embraced this doctrine. In Matter of Mid Hudson Pam Corp. v. Hartnett, 156 A.D.2d 818 (3d Dep’t 1989), the Appellate Division held that “[a]ny inexactitude in the computation of wages due should be resolved against the employer whose failure to keep adequate records made the problem possible.” Treating an employee’s reconstructed records as presumptively fraudulent—especially when such records were prepared at a supervisor’s direction or under longstanding agency practice—reverses the legal burden and undermines fundamental fairness.
In public-sector workplaces, such as police departments, hospitals, and schools, payroll practices are often informal, delayed, or paper-based. Supervisors routinely instruct employees to fill out missing slips, recreate schedules, or rely on calendar notations. These practices, when tolerated or directed by management, cannot later serve as the basis for fraud accusations simply because political or disciplinary incentives change. Obedience to institutional practice is not, in itself, criminal conduct—it is often evidence of systemic dysfunction.
Finally, when employers use recreated records to retaliate against an employee who engages in protected conduct—such as whistleblowing or filing an EEO complaint—they risk liability under retaliation and civil rights statutes. Fraud requires specific intent to deceive for personal gain, not retrospective compliance under flawed systems. The law protects employees who reconstruct time in good faith. What it does not tolerate is employers exploiting their failure to maintain records to retaliate against those they wish to silence.
Donlon’s pleading flips this jurisprudence on its head. He treats the reconstruction of time as proof of fraud, without ever addressing who created the conditions for reconstruction in the first place. In the NYPD, where timekeeping is decentralized, opaque, and susceptible to manipulation, internal payroll systems often serve both political and administrative functions. It is unsurprising—indeed, it is expected—that employees like Epps would be forced to fill the gaps left by negligent or complicit management. That’s not fraud. That’s the labor reality of a retaliatory command.
The danger here is not just factual. It is structural. By misusing civil RICO pleading to cast a whistleblower as a criminal, Donlon’s complaint risks transforming civil litigation into a tool of reprisal. This is not the first time such tactics have been deployed. But the inclusion of known falsehoods—particularly the fabricated search warrant—marks an escalation. It signals a willingness to cross ethical lines, mislead the court, and harm individuals in furtherance of a broader narrative strategy. In doing so, the complaint raises questions about its legitimacy.
This is not just about one whistleblower. It is about whether the civil justice system will function as a safeguard for truth-telling public servants or as a weapon to punish them. Suppose falsehoods can be embedded in pleadings without consequence, and whistleblowers dragged into manufactured conspiracies for daring to expose institutional misconduct. In that case, the entire integrity of anti-retaliation law is at risk.
Litigation of this kind undermines the public’s faith in the process. It substitutes spectacle for specificity and innuendo for investigation. And it imperils the rights of those who, like Epps, have already risked everything to expose the truth.
What Donlon characterizes as a RICO scheme is, at bottom, a story about labor exploitation—how institutional power misuses its employees, and how those employees are discarded when they refuse to stay silent. If the courts are to serve their intended function, they must not allow these tactics to stand.
Donlon’s allegations against Epps are not just wrong. They are retaliatory. They are unsupported. And if they do not yet violate the letter of Rule 11, they certainly offend its spirit. If left unchallenged, they send a dangerous message: that speaking up will be punished, and that the truth is irrelevant if the fiction is salacious enough.
Epps is not the criminal. She is the witness. And no matter how many pages are filed, that truth remains.
“It is both disgraceful and legally irresponsible for former Commissioner Donlon to invoke Retired Lieutenant Quathisha Epps—an acknowledged whistleblower and victim of retaliation—as a scapegoat in his self-serving lawsuit. The use of her name in connection with alleged payroll fraud is not only false, disgraceful, and retaliatory in spirit, but it also blatantly ignores the settled legal principle that recreated time records—especially when directed by superiors—are a protected response to employer failures, not a crime. The NYPD didn’t protect her. Now, Donlon tries to exploit her,” says Eric Sanders, Esq.
If courts tolerate these tactics, they risk silencing future whistleblowers before they ever come forward.
At bottom, this is not a case about overtime—it’s a case about power, retaliation, and the systems that enable both.
About The Sanders Firm, P.C.
Fighting for Justice and Reform to Promote Equal Opportunity
Led by Eric Sanders, Esq., The Sanders Firm, P.C. has a proven track record in civil rights litigation, representing clients in complex cases involving law enforcement misconduct and employment discrimination. Mr. Sanders, a former police officer, leverages deep insight into systemic issues facing law enforcement agencies. The firm has successfully recovered millions in damages and remains committed to promoting fairness, integrity, and meaningful reform within public institutions.
Contact: Eric Sanders, Esq.
President and Owner, The Sanders Firm, P.C.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: (212) 652-2782
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Read the Federal Complaint
Read the EEOC Charge of Discrimination