POLICE CRIMINAL COMPLAINT COMMONWEALTH OF PENNSYLVANIA 3 CGMMONVEALTH OF PENNSYLVANIA’ COUNTY. OF: BRADFORD 3 _ vs. TaystriOwrailimer 73.00 oerewoant ui BORE Ine nn Topo care CHAD wine sa SAN soa ZoMAINet —_ oa ra od Tae = TOREMDA EA (0088 1395 GRAND VIEW LN. rors snzsesosr PPALUSING PA 833 a "NCIC EXTRADITION CODE TYPE Felony For Dereon, Pome DC itetomaanar Sumouaing States Distance: Frere Hirsi Foa'taatiminen Hoanannnarstawten [53s mtn ae acer Besse roses [5 eFetony no et De wssemesno tae C1 pAisdemeanorPardna xin Os, a SEFENOURT WERTCATON FORUATON Same i ried —PYNUksonombe Fnac Wabi [RGR SORT 13/21 PAZ019-1645949 ves Ono GENDER | 008 [row [Aas 008 " [60 Detonsantis) LT eae aie Rae ast Nome: ‘Gan. IC)reaie | AKA RACE Bune Osan Desee Tneweeanencon Cloner ETHNICHY Clove DY Non Haase Tuntrcer FHAIREOLOR [] omy (Gray) Treo ered sAvta) —)80v (8mm) L]siucane Dre Curie) By BRO roway C8tk ick) Cows (Orange) Dwenrcwates — Clrcoccum. rai C1 cra (Green) CC] Pn cPiak Flan stny : EVECOLOR Cate (oteay CU Se) Berton Oa (Gnm Drtaz (seer) Duan estas) Orns erin) Dhar emtticoinrey L L [Weigh fies [Baw [Fives xo [OWA Location 1180 [FolNumoor [ARO HomborT FL Hex i 5 [earn castes — — DEFENDANT VEHICLE INFORMATION net |S [Rosati arr] Comet ¥ah ind] Sogo a B sn vin Year [Make ~~ Yitodet Style ‘Color ae Dat _ a TST I Fae Seat e Meet ean ann eg ome ; DANIEL J. DYE Bee ccc arm AGO NO " a[ajeor. cogrengero% |, 0Pt, BRYAN FEDOR 10195 sylvenie State Police, Tropa P, Tunkhannock do horoby state: (check approprists bor) 1. | accuse the above named defendant we livos at the address sot forth above Ct | ecouse the defendant wnose nama ig unknown to ma but who Is described ws 1D J accuse the defendent whose name and popular designation or nickname is unknown to me and whom | have thorslors designated 38, John Doe oF Jane Doe 42 PARK ST. TOWANDA ROROUGH Een acer SE NA with violating the penal lawe of the Commanssaith of Pennsylvania at a of in, SRADEORD County 08 (on or about. 99/01/2017-12723120 A VARIOUS TIMES eotycnt) Ps yeae POLICE CRIMINAL COMPLAINT [osekct number | Date Filed: | OTN/LiveScan Numbsr Compiaintincidant Number | 2 goat PAz019-1645040 First Migave [urnantnone |S Thies | The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if ‘appropriate. When there is more than one offense, each offense should be numbered chronologically. Feo e rate a omtose tse seas be edulis fw ene res Afr nba ee) wage vale, AN mer, etait ns eave, youu to he ke Seda) an eubswaa fe Veo) or rere) sop YO chaste amt a oo cain aise A innaie ce ‘Numbar of Vietims Age 80 or Oider: 0 og tee |_| si24 wtma [Tile 18,PACHmesCode [3 _|F2 Chios ¢ Seeo__—Svbecten Pa sane ee ‘Gens Gods NGO Orerac ose UCRNIIRE Cage PennOOT as Tazaow T wapokcaie) ante Donerstace Dist Zone were zene “Sialute Description (include the name of statute or ordinance}: Sexual Assault _ "Acts of the accused associated with this Offense: IN THAT, on or about said date, THE DEFENDANT, did engage in sexual intercoursedeviste sexual intorcourse ith a complainant without the complainant's consent, To Wit: the defendant did have sexual intercourse with ‘atime, Ld, AM, and LW, without their consent in violation af Section $124.1 of the PA Crimes Code. 4 isos Ty seater FY comemncy ee woe we | Narnberaf its Age 80 o¢ Ole @ 5 _ Ser 2_|o0se [roxy | atu [ite 18, Pacemes code 3 [Fe ossre0z Oman Senor” Suenete Paszae We) caw NOE RE Coe __VERNIORS Btn FemboT Oa maa + ‘Stalute Oescriation (include the name of statute or ordinance): Intimidation of Witnesses or Victims, ‘Acts of the accused associated with this Offense: IN THAT, on or about said date, THE DEFENDANT, with Intent to or with Anowledge that his conduct would struct, impede, impair, prevent or interfere with the administration of criminal justice, did intimidate or attempt to} Intimidate any witness or victim, namely, victime L.J., A.M., and L.W., to refrain from informing or reporting to any law enfarcement officer, prosecuting official or judge concerning any information, document or thing relating to the| lcommission of a crime, in violation of Section 4952(a)(1) of the PA Crimes Code. AOPC 412A —Rev. 718 Page of.as POLICE CRIMINAL COMPLAINT Docket Number: | Date Filed: | OTN/LiveScan Number Complaintineldent Number | g2vearet Pagg191645049 t s _ ua Firat [mca sat [Defendant Name | cHap [MicHage SALSMAN ‘The acts committed by the accused are described balow with each Acl of Assembly of statute allegedly violated, if appropriate. When there is more than one offense, each offerise should be numbered chronologically. FeO oO ate yn Sac nica tose be ental nale aoe) o99e8 aes hs a) pe vs weh no, ate m4 fare san oom oe ee co) duce ie Sas] or arc) aay Yo eee 7 : - eT ci eae eee Statute Deseription (include the name of statute or ordinance). Intimidation of Witnesses or Vietlms ‘Acts of the accused associated with this Offense: IN THAT, on or about said date, THE DEFENDANT, with intent to or with knowledge that his conduct would lobstruct, Impede, impair, pravent or interfere with the administration of criminal justicg, did intimidate or attempt to Intimidate any witness or victim, namely, victims LJ., A.M., and LW,, 10 withhold any testimony, information, Jocument oF thing relating to the commission of a crime from any law enforcement officer, prosecuting oficial or 1udge, In violation af Section 4952(a)(3) of the PA Crimes Code. 2 fmt PS soot Pl mew Pea | (anna vmineagetnwoeer 9 ram2n 14903 | cote | Ttto 18, PA Gémes Cove +_.|rs 1 eunia_ Grass NEVE OfonsaCove__UCRIRAS Cate {Gree sete zone Cw ane Statute Description (include the name of statute or ordinance}: Promoting Prostitution ‘Acts of the accused associated with this Offense: IN THAT, on of about said date, THE DEFENDANT, did knowingly promate prostitution of another by sneouraging, Inducing, or otherwise Intentionally causing another to become or remain a prostitute. TO WIT; tha jofendant did exchange attorney fees for sexual intercourse involving victim, N.A., in violation of Section 3902(b)(3) of the PA Crimes Code. AOPC 412A - Rev. 78 Page __of__is POLICE CRIMINAL COMPLAINT a en The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. Rear ete see eta necent sta aoranti de tee whan oves hetuania ust napty won oan erleear 8 famine you mes he ro etn ans UDHEA) ne Sana ores) easy ate a Saver 5_[s902 }ox8) | orme | THe 18, PA Comas Code 1 |e L _ eee __Soeton Sots Pa sate (he) Guin Grade NOG Ofanw Code UCRNIBRS Code FonOT Data soda ( apptesbie) Nanoee Clie Dee Zone Dorn zone Statute Deseription (include the name of statute or ordinance): Promoting Prostitution — _ ‘Acts of the accused associated with this Offense: IN THAT. on or about said date, THE DEFENDANT, did knowingly promote prostitution of another by soltleting, Irecsiving, or agreeing to receive any benefit for doing or agreeing to do anything forbidden. TO WIT; the defendant did solitct victim, N.A., to have sexual intercourse with the defendant for exchange of altomey fees, In jglation 6902(b\8) of the PA Crimes Code. : _ fee see, semen FTES | [rcmewavarngneroaeo B l — Cade 6 |s101 crime [Tile 18, PAGrimes Codo [2 __ Mz 1 Ofeorey Seton Suanecion PA Sine (The) Coins Gnas NEC oo Come_UCRNAS Ete FanoBOT Date st erapoteabion temo Dinersite | Cate zone ion Zone ‘ratule Description (includs the name of statute or ordinance). Obstructing Administration of Law or other Gavernmental Function _ ‘Acts of the accused associated with this Offense: IN THAT, on or about said date, THE DEFENDANT, intentionally obstructs, impairs or perverts the administration] law or other governmontal function, by force, violence. physical interference or obstacle, breach of oficial duty, f any other unlawful act. TO WIT, the defendant, did contact victim H.H. asking her involvement In an active lerimina| investigation that the defendant had knowledge of said investigation, in violation of Section 5101 of the [PA Crimes Code. - Page _of AOPC 412A - Rev. 7/18es POLICE CRIMINAL COMPLAINT [oockat number: | Oate Filed: | OTNLIveSean Number ‘Complsineincigent Numbor g aan A2018-1649900 \ox : — | Fest 4 Migaie: - Last: Defendant Name | Chiao Mera. SALMAN ‘The acts committed by the accused ere described below with each Act of Assembly or statute allegadly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically Be Rrd brat summary ot cs deus Soran on fin nes of mens) eae, ANON ha He wane Ane, wove, ots 2 you mere eel cya stints ere) lag wba fer wee Poe ear | | [naeswcmmamoaure 2 | [ Bde [7 [sae Jenn [ons [rors orcinecnss [ss er Sot eneieeaee Se pa ween | Stowe | ant — ‘Statute Description (include the name of statute or ordinance): Indecent Assault ‘Acts of the accused associated with this Offense" IN THAT, on or about said date, THE DEFENDANT did have indecent contact with a complainant, namely \victims, H.H., A.M., LJ,LW and N.A., or did causa the complainant to have indecent contact with the dafendant, without ths complainants consent, in violation of Section 3126(a)(1) af the PA Crimes Code. = Ps Pa PS] cman Q Ce Ee O sory Oo | Statute Dascription (include the name of statute or ordinance): Intimidation of Witnesses or Victims ‘Acts of the accused associated with this Offense: IN THAT, on or about said date, THE DEFENDANT, with intent to or with knowledge that his conduct would lobstruct, impede, impair, prevent or interfere with the administration of criminal justice, did intimidate or attempt to| intimidate any witness or vietim, namely victims, NA. and H.H,, to refrain from informing or reporting to aniy law lenforcement officer, prosecuting official or judge concerning any information, document or thing relating to the mmission of a crime, in violation of Section 4952(a)(1) of the PA Grimes Code. AOPC 412A ~ Rev. 7/188 POLICE CRIMINAL COMPLAINT Dockat Numser | Date Filed: | OTN/LIveScan Number’ Complaintincident Number ozrograt ? 5 PAz019-1845049 First reco a le " Last | outensont name _| itp Nae Loan ‘The acts committed by the accubed are dascribed below with sach Act of Assembly or statute allegedly violated, if propriate. When there is mors tan one offense, each offense should bs numbered chronologically (aol bet gonmay fc soe tvs heart thers hme car es red ARO he aaa slg Wana aU Ree keen Sumer at, jou mu es ee fons) an sense afte dav oNaee ene wt icant ange‘ aeleiwen J] ana fave eee Pee ons [moor vats Aa 80 Oto 0 Q taser 9 {4952 (axe | ome [rita 10, racemes code 2 [ma 46002 Streak Sine ease ee) Cond Gate NOC ORME Coe) UERIMORS Goes (apes) Newer Cartate | Oswetrzone Qwor zone Statute Description (include the name of statute or Ordinance): « Intimidation of Witnesses or Victims . ‘Acts of the accused associated with this Offense: IN THAT, on or about said date. THE DEFENDANT, with intent to or with knowledge that his conduct would struct, imoede, impair, prevant or interfere with the administration of criminal justice, did intimidate or attempt to| intimidate any witness ot victim, namely victims, NA. and H.H., to withhold any testimony, information, document Jor thing rolating to the commission of a crime fram any law enforcement officer, prosecuting official or Judge, in Violation of Section 4952(4)(3) of the PA Comes Code. " i a ee [ieee nen our 7 —— - Ba [a0 os Tater La [rst eacamen coon [1 [ua cz ee aoe Saat rt i a aca on ‘Perea a l Di iaterstate DO satery Zone OD Work Zone Statute Deseription (Include the name of statute or ordinance). Intimidation of Witnesses or Victims. ‘Acts of the accused associated with this Offense: IN THAT, on or about sald date, THE DEFENDANT, with intont to or with knowledge that his conduct would jobstruct, impede, impair, prevent or interfere with the administration of criminal justice, did intimidate or attempt to intimidate any witness or victim, namely, H.H., to give any false or misleading information or tastimony or refrain from giving any testimony, information, document or thing, relating to the commission of a orime, to an attorney representing a criminal defendant, in violation of Section 4952(2)(4) of the PA Crimes Code. AOPC 412A ~ Rov. 7/18 Page _ofcc POLICE CRIMINAL COMPLAINT Docket Number: | Date Filed: | OTN/LiveScan Number pase Complainutacident Number | 0210321 PA2019-1645948, est: ‘Migge: ast owmaunvane | Ta ‘aw The acts committed by the accused are descrivad below with each Act of Assembly or statute allegedly violated, If appropriate, When there is more than one offense, each offense shauld be numbered chronologically. Heereeiatsonmay st ee ohaeit aves he slnartolde nus ctw SAR] Oaneh Aten we Seti wanedy vend wah ne. ae he sonmary coe, ou mu ho ba Ne ct) ans bacon) wou osha) alana ae one a Tokar Seer r 0 3 ae E — oe 4 [ Number ar vite Age 60 or Organ 0 Se [14 Jose Jnsr [ee [rae esrasinescow [+ [on oxen Oweh Seton Simcha Pati Gantt Gots NECOR Gets VERNARS Cove end TERE Fe 5 tate wir eect (sate zone CWerczone “Statute Dasorption (include the name of statute or ordinances) Intimidation of Witnesses or Victims ‘Acts of the accused associated with this Offense: IN THAT, on or about said date, THE DEFENDANT, with intent to or with knowledge that his conduct would struct, impede, impair, prevent or interfere with the administration of criminal justice, did intimidate or attempt to intimidate any witnass or victim, namely, H.H,, to elude, evade, or ignore any request to appear or logal process: ‘ummoning him to appear to testify or supply evidence, In violation of Section 4952(a\5) of the PA Crimes Code, OPC 412A — Rev. 718 Page of ¥ee POLICE CRIMINAL COMPLAINT ‘Docker Number: — | Oate Fd | OTWiLIveScan Number. 7 Gomplsindnigent uber 02/0321 | Pazor9-1645348 | I Fst T Middle Teast [Defendant Name: | chad | Wieraet | Sa.swan AFFIDAVIT of PROBABLE CAUSE ‘Your Affiant is empowered by law to conduct investigations aud make arrests for offenses involving violations of the Crimes Code of Pennsylvania. In the course of his official duties, your Affant has personally been involved in an investigation into allegations that Chad Salsman committed various sex crimes. Your Affiant, Cpl. Bryan Fedor, has been a member of the Peunsylvania State Polico since May 2005, currently assigned to Troop P Tunkhannock Barracks, Supervisor of the Criminal Investigation Unit. Your affiant has been part of the Troop P Criminal Investigation Unit since 2011 and currently holds the position of Criminal Investigation Unit Supervisor at Troop P Tunkhannock Station since 2018. Cpl. Fedor successfully completed trainings in Interview and Interrogation, Statement Analysis, Crimes Against Children, Certified Class “A” Wiretap, Sex Offender Field Liaison, Advanced Practical Homicide Lavestigation and Introduction to Forensic Pathology. Your affiant has investigated multiple property crimes, homicides, sexual assaults of both adults and children leading to successful prosecution. On January 29, 2021, the 45th Statewide Investigating Grand Jury issued Presentment No. .14_ resulting. from Notice of Investigation 44, recommending that crisninal charges be filed against Chad Salsman for violations of the Crimes Code of Pennsylvania. The aforementioned Presentment was socepted by the Honorable Richard A. Lewis, Supervising Judge of the 45th Statewide Investigating Grand Jury. Having read and reviewed the Presentment, and after having participated in this investigation and considering all the facts and ciréumstagces, your Affiant is adopting the Presentment and incorporating it fully into this ‘Affidavit of Probable Cause (A copy of the Presentment is attached hereto). Based upon our review of the testimony given before the Grand Jury and the documents produced for the Grand Jury, we believe that the ostimony of the various witnesses is accurately summarized in the Presentment and that the records refecred to in the Presentment are stated accurately. (CONTINUED) 1, CPL. BRYAN_EEDOR, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I CERTIFY THAT THIS FILING COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS ENTIAL Sworn to mo and ubscrbvedtetoreme tis 3 —dayor Jebnuaty elbal pate pe Waa) 4 , Magisterial Distict Judge My commission expires first Monday of JAdtary, Sq Mmagishual Dishitck ad | Sppeichl, dongpecl |_-eee ‘| Lo ‘OPC 4116 - Rev. 07/18 Page 1 of _POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Number] Dale Finds | OTWivescan Number ‘Complaindineident Number] onset | Se Paz01$-1645549 | 7 Wide T tact 4 Defendant Name: | Chad a Mishaol __|[SALSMAN AFFIDAVIT of PROBABLE CAUSE CONTINUATION Based upon our review of the evidence, we have concluded that there is probable cause to believe that Clad Salsman engaged in illegal activities which are accurately summarized in the attached Presentment, Wehave determined that there is probable causo to conclude that Chad Salsinax violated the following laws of the ‘Commonwealth of Pennsylvania: Sexual Assault, Involuntary Deviate Sexual Assault, Indecent Assault, Promoting Prostitution, Intimidation of a Witness or Victim, and Obstruction of Justice related to five (5) female adult victims identified by initials within the presentment. (Enature oF Ata) apa eh Cale Aogibead Josted Sprcethey om AOPC 4116 - Rev. 07/18vo ti POLICE:CRIMINAL’ COMPLAINT [ docketnumber: © | nate Fite, 4] OTNLIveSoaM Number: «> i, wpe Complaintincident Number | 203723 : PA2016- 1645949 First Tate ast [oseaan sine | ES (Se: ‘ue 2. lack that a warrant of arrest ora summons be issued ang that the defendant be required to answer the charges | have made, : . 3. Iverify that the facts set forth in this complaint are true and correct to the best of my knowledge or Information and belief. This verification ts made subject to the penalties of Sectian 4904 of the Crimes Code (18 Pa.C.5.§4904) relating to unsworn falsification to authorities, 4. This complaint consists of the preceding page(s) numbered _ through _ 5. I certify that this fllng complies with the provisions of tha Case Records Public Access Policy of the Unified Judicial System of Permsylvania that require filing confidential information and documants differently than non-confidential Information and dosumsnts. The acts committed by the accused, as fisted and hereatte:, were against the peace and dignity of the Commonwealth of Pennsylvania and were-contrary to the Act{s) of the Assembly, or in violation of the statutes cited, (Before a warrant of arrest can be issued, an affidavit of probable cause must be completed, sworn to before the issuing authority, and attached,) = —— GEBRUARY 03, 2021, WL, = er ANO NOW, on this date, _febtuany 2 D621 | certify thatthe complaint has been properly completed and verified. An affidavit of prdbable cause musi be completed before 8 warrant can be issued. — Ops. Ravn aA aah g rn Sa, Magisbacch Disbick ao Spently: dugys is AOPC 412A Rov. 7/18 Page of _INTRODUCTION We, the members of the Forty fh Statewide Investigating Grand Jury, having received and reviewed evidence regarding violations of the Pennsylvania Crimes Code occurring in Bradford County, Pennsylvania pursuant to Notice of Submission of Investigation No. 44. do hereby make the follor 1 findings of fact and recommensdation of charges. OVERVIEW The Grand Jury conducted an investigation into sexual assaults committed by Chad Salsman (-Salsman”) who was sworn in as the District Attomey of Bradford County in January 2020, ‘The matier was submitted tothe Grand Jury following a referral tothe Pennsylvania Office of Attorney General in late 2019 by then-District Attorney Daniel Barrett, who cited a conifict of interest. It was determined that while he was engaged in private practice, Salsman repeatedly used his position to pressure vulnerable female clients into sexual contact at his law office located at 12 Park Street in Towanda, The Grand Jury recommends that Salsman be charged with sexual and other offenses invalving five different women, While evidence before the Grand Jury indicated that many other women were placed in the same position, those events occurred outside the statute of limitations and therefore cannot serve as the basis of eriminal charges. As detailed below, the Grand Jury finds that Salsman abused the power and the authority of his position as an attorney DINGS OF FACT. Following his graduation from the Widener University School of Law, Salsman began practicing law in 2001, During his years of private practice. he represemted numerous women in connection with criminal cases or in child custody matters, Many of Salsman’s clients struggled with addictions, had a history of being sexually abused. or suffered from other vulnerabilities, which Salsman exploited, He used his knowledge of their vulnerabilities to overcome their lackof consent and sexually assault them. In one ease, Salsman assaulted a woman whom he knew hhad been the victim of a prior violent rape, In another case, Salsman assaulted a woman who faced incarceration if Salsman did not help hee. sand then directed them In most cases, Salsman had sex with the women on his office des to his private hathroom to “clean up” using paper towels or cleaning wipes. He directed them not tw tell anyone about the assaults and, in one case. even suggested to a woman that she should not cooperate with this investigation. ‘The details of the assaults. threats and intimidation are set forth below: 1... retained Salsman to represent her in 2017 on charges of harassment and possession of drug paraphernalia, He did not bill LJ, forthe total services rendered, however. Instead, Salsman requested that she provide nude photographs or videos depis ing sexual acts between LJ. and her girlfriend. LJ. complied ‘On numerous avcasions, Salsman grabbed the breasts or buttocks of L.J. without her consent while she was present in his law oiTice. On one occasion, he led her to his desk and directed her to disrobe. Salsman then inserted his penis into L.J.”s vagina and licked her vagina without her consent, In an attempt to explain that she did not want to have sex with Salsman, Lil. told him that she was gay. This did not stop Salsman from proceeding. As Salsman continued to penetrate her - - while ehastising her for not displaying pleasure nek |. received a text message from her girlfriend inquiring “what was taking so long” at Salsman’s office. LJ. texted back. but did not tell her gilffiend what was occurring. “I was too ashamed." Salsman, seemingly undisturbed by the texting, continued to copulate. Afterwards, heinstructed L.J.to tell no one, She had to rub off his ejaculate with cleaning wipes in his private office bathroom, L.J. testified that she went home in tears and immediately showered, L.J. stated, “My girlfriend kept asking me what was so wrong and why | was quiet. | told her nothing, | was fine. 1 wouldn't tell her. She knew something wasn’t right.” L.'s girlfriend also testified before the Grand Jury. She recalled the incident and stated that while she did not know what had occurred, she recalled LJ. entering their home in distress and then immediately showering. She was aware that LJ. had been meeting with Salsman and suspected something had happened during that time, She stated that L.J. has never told her the details as to what occurred * HH In December 2017, Salsman was court-appointed to represent HLH. in a child custody matter. In the course of representing H.H., Salsman made suggestive comments and would touch her under the table during court proceedings. Salsman asked H.H, to have sex with lim but she refused. He told her to send videos of her having sex with someone since she refused to have sex with him, When H.H. again refused, Salsman told her that he needed naked pictures because he ‘was not being adequately compensated for his representation. At that point HLH. felt she had no choice and sent nude pictures to Salsman. ‘On another occasion, Salsman provided H.H. with a video of a nude woman in a bathtub. ‘The Grand Jury identified that woman and obtained her testimony. She explained the circumstances surrounding the creation of the video. She stated that she was suffering from a death in her family and that Salsman had reached out to comfort her. He then began asking for naked pictures and videos ef her. She provided Salsman with the video of her nude in the bathtubat his request. Salsman then forwarded the video to HH. without the consent of the woman in the video. HHL tes fied that Salsman revealed a steady stream of confidential or private information, ‘on matters “ineluding his eases, his legal eases on other people, picjures of other people, pictures ~ naked pictures of other clients, of people. 1 don’t know if they were elients or not his wife, pictures of his kids.” Salsman justified his demands for H.H.'s time, as well as his sexual demands, by complaining about his court appointment to her ease, Salsman told her “I don’t get paid for this, Ido everything for free.” In reality this assertion, intended to pressure his client into sex, was a lie, Salsman actually was paid for his court-appointed representation with taxpayer's funds in the amount of $2,115.00. UL testified that Salsman told her that he masturbated dozens of times a day. She knew he had “an issue" and she was concerned about his failure to effectively represent her. He sent her pictures of her own residence that he had taken from outside her home and without her knowledge. In April 2019, H.H1, sought new legal counsel and went to Salsman’s office to obtain her file, At that time Salsman forcibly grabbed her breasts while in his private office. 1H. stated that his hands were “around me, onto my breasts, onto my shoulders.” HLH. was able to kick Salsman and leave with her file, During this investigation, the Grand Jury reviewed evidence that HH. met with Salsman, aller he became the District Attorney’ of Bradford County. while she was wearing a recording device monitored by the Pennsylvania State Police. Between January and March 2020, Salsman provided I1.14 with legal advice regarding her participation in this investigation, advising her as though he represented her, even though she alre ly had a lawyer, and even though he himself was the target of the investigation. That advice suggested that H.H. should not cooperate withauthorities. Salsman also told ILI. that the investigation must be about him having sex with his; clients, but he claimed — despite his unsuccessful assault on HLH. herself ~ that the sex was all entirely consensual, and the investigation was therefore, in his word, a “witehhunt.” On December 22. 2020, a search warrant was exceuted at Salsman’s private law office. Salsman contacted H.H., despite the fact that by this point he knew he was under grand jury investig a. and despite the fact that he was now the District AUorney and therefore himself a law enforcement official. He told her he suspected that the warrant related to her, asked her why the warrant had been issued, and pressed her for any information she had disclosed. * AM. Salsman began representing A.M. on various legal matters when she was 19 years old. He represented her in connection with a child eustody matter and, on another occasion, he represented her boyfriend with respect to a child custody matter. In both instances, A.M. and/or her boyftiend paid for the legal services provided. In May 2018, A.M. contacted Salsman regarding her arrest for driving under the influence. Salsman told her that she faced jail time for the offense. A.M. advised that she did not have the money to hire Salsman beeause she had been out of work For six months. A.M. testified that once Salsman learned she was having financial difficulties. he began “coming onto” her. She stated that she felt as though she had no choice in the face of being sent to jail. Salsman told A.M. that his wife wasn't giving him what he needed at home.” Salsman had sex with A.M. without her consent on his desk in his private law office. Afterwards, he directed her to clean up in his private bathroom using paper towels. In her own swords, A.M. testified that, “he would always remove the stufon his desk, and he would have sex awith me there. And then T would have to go into the bathroom and clean before 1 left.” Duringlegal meetings, Salsman also touched A.M.'s breasts and buttocks without her consent. Salsman made her perform oral sex on him and engaged in vaginal sex with her on numerous occasions. She paid almost nothing for legal services. A.M. testified that Salsman “would tell me { would be ‘okay when it came to my DUI, and that I could take my time and make just random payments here and there so (REDACTED) his secretary would not think nothing.” After state police contacted her about this investigation, Salsman repeatedly pushed her to get information from other women bout anything they may have revealed 0 authorities. He told her never to disclose what had occurred and indicated that he could help her if he became the District Attomne; AM. testified. “He told me once he got into the D.A.'s position that everything | owed bim ‘was no fonger an issue and it would be harder for him to have me come see him with him being D.A." Salsman had sex with A.M. one final time after he was elected district attomey in November 2019. LW, In her appearance before the Grand Jury. LW. explained that Salsman represented her boyfriend. Salsman had also represented another man, who had previously sexually assaulted LW. L.W. informed Salsman that his former client had raped her. According to L.W.,. Salsman. had no visible reaction. In the course of his representation of her boy tien, L,W. was in Salsman’s presence on several occasions while attending legal meetings. Salsman also hited L.W. and her boy fiend to do repair or remodeling work at his private law office, and loaned her money In October 2018, L.W. stopped by Salsman’s law office to drop off her last repayment of the Joan. Salsman instructed her to come in through the back door which led directly into his private office. Upon entering, Salsman took the money and directed L.W. to undress. L.W testified that man “told me he wanted to see what they (her breasts) looked like because hesaid that they were big through my shirt.” Her prior rape tiad been violent and Salsman knew about it, She testified that she was too affaid to resist again, So she complied with his demand She tes ied, “He started licking my vagina... and then pulled me down closer to the edge (of the desk) when he was done and had sex with me.” After the assault, Salsman directed her to his private bathroom to clean up using paper towels, Later, he contacted her and told her not to breathe a word to anyone. or he would ruin her lite. + NA N.A. appeared before the Grand Jury and testified that she retained Salsman to represent her in connection with a child custody matter, She testified that nothing mattered to her more than securing the custody of her children: “Just my kids.” But Salsman, representing her in the most important matter in her life, required litte in the way of ees. Instead, in December 2018, Salsman began touching N.A’s breasts in his office and touching her inappropriately during court proceedings. He then began asking for aude photos of her. She testified, “I was getting up to leave and he touched my breast, 1 backed up and just kind of { was taken ~ | didn’t know how to respond to that." These instanees of contact were without her consent. Salsman informed N.A. that she could compensate him for his legal work by having sex: with him, As he put it “I could slam your pussy and you wouldn't have to pay.” N.A. began a consensual sex-for-services relationship with Salsman. When the relationship soured. however, Salsman hecame more aggressive and threatening. He told her that as her attorney he could not be in a relationship with her -- making reference to a law book in his office - - and told her to tell no one about what had occurred.Staff Members of Salsman’s staff also appeared before the Grand Jury. ‘These individuals confirmed that Salsman would often meet with female clients in his office one-on-one. Testimony demonstrated that even though Salsman’s legal secretaries had aecess to all client information, and were covered hy the attomey-client privilege. Salsman went to great lengths to keep his interactions with his clients a secret from the staff. Salsman even went so far as to ask secretaries to play music (o drown out anything that could be happening in his office and sed an air conditioner unit or noise machine to mask any sounds or noise occurring in his office. Female clients were seen leaving Salsman’s office in tears or in distress; Members of Salsman’s staff, like his clients, were placed in compromised positions by him. ‘One former staffer admitted that she herself had a consensual ongoing sexual relationship wit Salsman. Another stated that prior to her testimony, Salsman met with her in his office, and, in his capacity as the District Attorney of Bradford County. directed her to report back to him anything that occurred within the Grand Jury. ‘That witness had been ordered by the Supervising Judge not to disclose her testimony to anyone, however. Salsman later complained about the order of non-disclosure in text messages obtained by the Pennsylvania State Potics 10