KAREN M. ST.

HILAIRE
St. Lawrence County
County Administrator
48 Court Street, Court House
Canton, New York 13617-1169
(315) 379-2276
FAX (315) 379-2463

Attorney General Eric Schniederman

Office of the Attorney General
The Capitol
Albany, NY 12224-0341
July 8, 2014
Dear Attorney General Schniederman:
I am requesting that your office initiate a review of the possible misuse of public office by the St.
Lawrence County District Attorney Mary Rain.
I have been St. Lawrence County Administrator since July, 2007 and have worked with many
public officials during that time. Prior to my tenure here, I have held numerous positions of
responsibility throughout the County and have always acted with integrity and honesty in
conducting my duties, whether it was as a news reporter for radio, wire services or newspapers,
spokesperson and Director of Communications for Clarkson University, or CEO of the St.
Lawrence County Chamber of Commerce representing 800 businesses.
I believe I am currently the subject of a campaign to destroy my credibility and ruin my
reputation by the District Attorney, Mary Rain, and I believe this is a result of actions taken
against her when she was previously employed as a Department Head under my tenure here at
St. Lawrence County.
Below are the facts that support this request for an official review:
1.

Mary Rain was hired as Public Defender for St. Lawrence County on June 29, 2009.

2.

On March 7, 2011 the St. Lawrence County Board of Legislators passed a resolution

reassigning the operational duties within the St. Lawrence County Public Defenders Office to

the Chief Assistant Public Defender upon the recommendation of the County Administrator after
numerous counseling sessions with Ms. Rain. (Exhibit A)
3.

On September 15, 2011, Ms. Rain was notified that she was being placed on

Administrative leave with pay and would be terminated from County service. She was presented
with a list of charges explaining this action. (One of those charges involved an employee who
had to be relocated because of alleged harassment by Ms. Rain.) At the time of this notification,
Ms. Rain was also given the option to enter into a separation agreement. (Exhibit B)
4.

On September 16, 2011, Ms. Rain sent an email with attached letter requesting that the

County enter into separation agreement negotiations with her and referenced a news article
referring to her being on administrative leave. (Exhibits C&D)
5.

On October 19, 2011, the County entered into and agreed to a severance agreement with

Ms. Rain. (Exhibit E)

6.

The agreement, at Ms. Rains request, was to remain confidential. Yet, during her

campaign for district attorney in 2013, Ms. Rain, herself, violated that agreement by saying she
was obviously right in her dispute with the County because she was given a settlement. In
spite of numerous requests from the media to see the agreement, the County refrained from
releasing it.
7.

In November 2013, Ms. Rain was elected District Attorney for St. Lawrence County and

took office in January of this year.

8.

Since taking office, Ms. Rain has requested new expanded office space for herself and

her staff. There have been several meetings on this subject and six options have been proposed.
She has pushed for most expensive option which causes relocation of five other departments.
There has been much vocal opposition to this option by myself, some legislators, and affected
department heads.
9.

On June 30th, the Administrative Assistant for Ms. Rain delivered to my office a letter

alleging possible criminal acts on my part and stating that Ms. Rain was intending to convene a
grand jury to investigate these acts. Specifically, she alleges misappropriation of funds for

purchase of new sound system for the Board of Legislators Chambers which is also used
regularly as a courtroom. This sound system was purchased in 2013, prior to her becoming DA,
with prosecutors funds approved by former DA Nicole Duve.
Ms. Rain also alleges that there was criminal nonfeasance on my part for not applying for
funds for her department for a victims advocates program although neither I nor my office has
ever been involved in this process nor are we made aware of when these grant funds are
available. (Her letter is attached as Exhibit F.)
My response drafted by our legal counsel is also provided. (Exhibit G)
10.

In numerous news articles (attached as Exhibits H 1-9), Ms. Rain, in violation of the

secrecy of the grand jury process, has publicly stated that I am her target of her investigation and
discusses how she believes I am guilty of these charges. She has also disclosed to a news reporter
that I, County Treasurer Kevin Felt and the County Sheriff Kevin Wells are targets.
11.

Ms. Rains letter, advising that she is convening a grand jury also states: Preliminary

review has uncovered additional acts constituting closer scrutiny under CPL 190.05 of other
department heads and will be the target of thorough and vigorous investigations.
12.

On July 7, 2014 Ms. Rain served me, several County Department Heads, and staff with

subpoenas. (Exhibit I)
13.

It has been reported to my office by members of the Democratic caucus that Ms. Rain

met with the caucus on June 30th after having lunch with the County Democratic Party Chair,
Mark Bellardini, to discuss strategy and that she implied to the caucus that I ordered county
employees not to apply for these grant funds for her. In particular, her allegation is that I
conspired not to apply for these funds with the previously mentioned employee who had been
transferred from her office. (see item #3.)
14.

It was also reported to my office that when Ms. Rain met with the democratic caucus on

Tuesday, June 30th to discuss convening a grand jury investigation and that I was her target, the
possibility of dropping the investigation for a favorable vote on her choice of new space was
also discussed.

Given the above, I am asking for an official review into this matter by your offices Public
Integrity Bureau to determine if Ms. Rain is misusing her position as District Attorney and
misusing the justice system for a personal vendetta, because of her earlier employment
termination. I am also asking that a review be made as to her threats of action against unnamed
department heads for additional acts to determine if this is because of their opposition to her
proposed relocation plans.
Sincerely,

Karen St. Hilaire,

County Administrator