COMMONWEALTH OF MASSACHUSETTS ~ FRANKLIN COUNTY DISTRICT ATTORNEY'S OFFICE
MEMORANDUM OF CRIMINAL CONDUCT
Cover Sheet and Evidence Summary
Submitted March 2026
PARTIES
COMPLAINANT
John F. Sendelbach
Shelburne Falls, MA 01370
SUBJECTS
Katherine Hennessey · Buckland, MA 01370
Brook Batteau · Buckland, MA 01370
Alouette Batteau · address of record same
PERIOD COVERED
June 2020 through February 2026 (5 years, 8 months)
WHAT COURTS AND POLICE HAVE ALREADY ESTABLISHED
This office is not being asked to evaluate competing accounts. The following are formal determinations already on record:
DECEMBER 11, 2025 — Shelburne Police Probable Cause Finding
Report 25SHL-114-OF · Sgt. Kurt A. Gilmore
Katherine Hennessey: Assault & Battery ×2 (MGL c.265 §13A) + Malicious Destruction of Property (MGL c.266 §126A)
Brook Batteau: Assault & Battery (MGL c.265 §13A)
Summons issued: 25SHL-46-AR (Hennessey) · 25SHL-47-AR (Batteau)
DECEMBER 15, 2025 — Judge William F. Mazanec III, Greenfield District Court
Denied Hennessey's HPO petition WITH PREJUDICE — formal finding of bad faith filing.
Docket: 2541RO000063 · Same judge who vacated her March 2023 HPO after audio disproved sworn testimony.
Pattern established across two proceedings before the same jurist.
MARCH 22, 2023 — Judge Mazanec, Same Court
Vacated emergency HPO issued on Hennessey's sworn claim that Sendelbach threatened to 'kill her family.'
Audio presented at hearing proved the actual statement was: 'I will never get along with the likes of you.'
Hennessey was audibly laughing throughout the encounter.
JUNE 6, 2023 — Show Cause Hearing, Docket 2341AC000088
Finding: No Probable Cause. Criminal harassment charge collapsed upon first review of complainant's evidence.
Docket notes confirm: 'Video provided thumb drive. Video also viewed show-cause hearing.'
FEBRUARY 28, 2026 — Greenfield Recorder, Public Record
Hennessey named, photographed, and quoted at public community event — 74 days after swearing she was
unable to appear in public due to fear of complainant. Recorder article and photograph included as Exhibit A.
CHARGES SOUGHT
Assault & Battery MGL c.265 §13A — Nov 30 2025 (Hennessey ×2, Batteau ×1); June 6 2020 (Hennessey, Batteau)
A&B Serious Bodily Harm MGL c.265 §13 — Pre-existing cardiac condition; AFib triggered by Nov 30 assault
Perjury MGL c.268 §1 — Three separate proceedings; each false sworn statement contradicted by recording
Malicious Destruction MGL c.266 §127 — iPhone seized during active recording, thrown into Deerfield River
Criminal Harassment / Stalking MGL c.265 §§43, 43A — Multi-year documented pattern
Filing False Police Reports MGL c.268 §13 — ~8 documented instances, 2020–2023; pattern continues
Civil Rights Violation MGL c.12 §11H — Assault to suppress lawful video recording in public space
Business Interference MGL c.266 §§127, 134B — Three consecutive workspaces targeted; defamatory landlord letters documented
PHYSICAL EVIDENCE AVAILABLE FOR THIS OFFICE
VIDEO / AUDIO
· Family recordings June 6, 28, 29, 2020 — originating assault and documented statements
· Keystone Market exterior surveillance — directly contradicts Dec 2025 sworn affidavit
· November 22, 2025 light show — 14-minute recording; transcript available
· Sgt. Gilmore bodycam — Nov 30 morning property trespass and layout documentation
· Det. Jenkins road race video — confirms he never interviewed complainant before filing charges
· LIFEPAK 15 cardiac monitor photograph — Oct 19, 2025; 130–230 BPM; MSP Officer Sheerer witness
POLICE / COURT RECORDS
· Report 25SHL-114-OF · Summons 25SHL-46-AR, 25SHL-47-AR
· Docket 2541RO000063 — Dec 15, 2025 denial with prejudice
· Docket 2341AC000088 — Jun 6, 2023 No Probable Cause; video reviewed
· March 22, 2023 vacation order — HPO vacated after audio presented
· Sgt. Gilmore June 29, 2020 email to Hennessey — documents permission structure
SWORN STATEMENTS / WRITTEN DOCUMENTS
· Zachary Livingston sworn statement, Dec 9, 2025 — neutral eyewitness; documents assault and
Brook Batteau admission: 'You don't understand, John has been after my family for five years'
· Hennessey September 6 and 9, 2024 defamatory letters to landlord Brad Walker
· Hennessey December 1, 2025 HPO affidavit — multiple statements contradicted by video and audio
· Alouette Batteau, Facebook post June 29, 2020 : 'it was all I could do not to deck him.'
MEDICAL DOCUMENTATION
· AFib diagnosis and progression records, 2020–present
· November 30, 2025 injury documentation — head, facial injuries; cardiac episode
· LIFEPAK 15 reading October 19, 2025 — documented in presence of MSP Officer Sheerer
EXHIBIT A
· Greenfield Recorder, February 28 / March 1, 2026 — Hennessey named, photographed, and quoted
at public community event, 74 days after sworn claims of inability to appear in public.
The full Memorandum of Criminal Conduct (attached) documents each charge in detail with applicable statutes and specific evidence citations. The complainant is prepared to provide complete physical evidence on request.
A copy of this memorandum has been provided to Judge William F. Mazanec III, Greenfield District Court.
John F. Sendelbach
Landscape Design / Public Art · Shelburne Falls, Massachusetts
Submitted March 2026
MEMORANDUM OF CRIMINAL CONDUCT
For Presentation to the Franklin County District Attorney's Office
Complainant: John F. Sendelbach, Shelburne Falls, Massachusetts
Subjects: Katherine Hennessey; Brook Batteau; Alouette Batteau
Period Covered: June 2020 through February 2026
Prepared: February 2026
Related Police Report: 25SHL-114-OF; Summons 25SHL-46-AR (Hennessey), 25SHL-47-AR (Batteau)
Overview
This memorandum documents criminal conduct by Katherine Hennessey, Brook Batteau, and Alouette Batteau against John F. Sendelbach across a period of approximately five and a half years, from June 2020 through early 2026. The conduct encompasses physical assault, malicious destruction of property, perjury in multiple judicial proceedings, filing of false police reports, criminal harassment, stalking, civil rights violations, and interference with business relations resulting in the constructive eviction of two consecutive workspaces.
The case is distinguished by an unusually complete evidentiary record. Audio and video recordings exist that directly contradict sworn statements made by Hennessey in two separate judicial proceedings. A neutral third-party eyewitness — Zachary Livingston, owner of Floodwater Brewing, with no prior relationship to the complainant — has provided a sworn statement documenting both the physical assault and a spontaneous admission by Brook Batteau. Shelburne Police issued a probable cause finding on December 11, 2025 (Report 25SHL-114-OF), charging both Hennessey and Batteau with assault and battery. Judge Mazanec, the same judge who vacated Hennessey's March 2023 HPO after reviewing audio evidence, denied her December 2025 HPO petition with prejudice — a formal judicial finding of bad faith.
The DA's office is not being asked to evaluate a dispute between competing accounts. The documentary record has already resolved the central factual questions in multiple proceedings. What follows is an organized account of the criminal conduct, the applicable statutes, and the evidence available to support each charge.
Established Judicial Record
Before detailing individual incidents, it is useful to establish what courts have already determined. These findings are not arguments — they are part of the formal record of this matter:
• March 22, 2023: Judge Mazanec vacates emergency HPO issued on Hennessey's sworn claim that Sendelbach threatened to 'kill her family.' Audio presented at hearing proves the actual statement was: 'I will never get along with the likes of you.' Hennessey is audibly laughing throughout the encounter.
• June 6, 2023: Show Cause Hearing, Docket 2341AC000088. Finding: No Probable Cause. Docket notes confirm: 'Video provided thumb drive. Video also viewed show-cause hearing.' Criminal harassment charge collapsed immediately upon review of evidence.
• December 15, 2025: Judge Mazanec denies Hennessey's HPO petition with prejudice — an express finding of bad faith filing. Hennessey cannot refile. This is the same judge who vacated her 2023 order. The pattern was established across two proceedings before the same jurist.
• December 11, 2025: Shelburne Police, Report 25SHL-114-OF. Probable Cause found: Katherine Hennessey — Assault and Battery (two separate incidents), Malicious Destruction of Property. Brook Batteau — Assault and Battery. Summons issued: 25SHL-46-AR (Hennessey), 25SHL-47-AR (Batteau).
Applicable Criminal Statutes
The following statutes apply across the incidents documented in this memorandum. Each is developed in full detail in the incident sections below.
MGL c.265 §13A
Assault and Battery
June 6 2020; Nov 30 2025 (×2 Hennessey; ×1 Brook Batteau)
MGL c.265 §13
A&B — Serious Bodily Harm
Nov 30 2025: pre-existing cardiac condition, AFib triggered
MGL c.265 §26
Criminal Threatening
June 6 2020: Alouette Batteau HPO threat
MGL c.265 §43
Stalking
Multi-year documented pattern across all perpetrators
MGL c.265 §43A
Criminal Harassment
Nov 22 2025 frog mask; Nov 28 walk-by; May 2025 Keystone; pattern
MGL c.266 §127
Malicious Destruction
Nov 30 2025: iPhone thrown into Deerfield River during recording
MGL c.266 §§127, 134B
Interference with Business
Three workspaces targeted; CIA commission pipeline destroyed
MGL c.268 §1
Perjury
2021 proceeding; March 2023 HPO; December 2025 affidavit
MGL c.268 §6A
Misleading Judicial Proceeding
December 2025 HPO affidavit (multiple false statements)
MGL c.268 §13
Filing False Police Report
~8 reports 2020–2023; Sept 2024 Alouette Mill complaint
MGL c.268 §1
Obstruction of Justice
March 15 2025 coordinated preemptive court filings
MGL c.12 §11H
Civil Rights Violation
June 6 2020; Nov 30 2025 (suppression of lawful recording)
MGL c.272 §99
Eavesdropping (predicate)
Mill workspace — mechanism for coordinated March 2025 filings
Documented Incidents
June 6, 2020 — Iron Bridge — Physical Assault, Criminal Threatening, Civil Rights Violation
The originating incident occurred during an unpermitted BLM demonstration on the Iron Bridge in Shelburne Falls. The street had been closed without notification to adjacent businesses, including Sendelbach's studio. What followed was documented on multiple recordings.
Sonny Walters approached Sendelbach first and persisted for over two minutes despite three explicit requests to leave. Katherine Hennessey then joined — screaming from approximately 12 inches away, fists clenched. A group of six to eight people pinned Sendelbach against the east railing, restricting both his movement and any exit. Brook Batteau participated in the sustained group intimidation. At precisely the moment 'silence' began — that is, after more than two minutes of documented assault — Alouette Batteau began recording on Facebook Live, editing out all prior context. That video reached 20,000 views.
Later that same evening, on a separate family recording from June 28, Katherine is heard applying the slur 'KKK members' directly to Sendelbach: 'I don't talk to KKK members either, but here we are.' This statement is material because her December 2025 sworn affidavit inverts it — attributing the statement to Sendelbach. The original audio predates the inversion by four and a half years.
On a June 29 family recording, Katherine states: 'Yeah, I hate you. Really do. That's not against the law. I can hate you all I want.' Brook Batteau: 'Quit your white whining.' Alouette Batteau closes the distance from ten feet to 24 inches and states: 'I already talked to three lawyers. I know I can get a restraining order against you if I want. And I will.' This threat was delivered five years before its execution.
APPLICABLE CHARGES
• MGL c.265 §13A Assault and Battery — Katherine Hennessey; Brook Batteau (group physical intimidation and pinning)
• MGL c.265 §26 Criminal Threatening — Alouette Batteau ('I know I can get a restraining order against you... And I will')
• MGL c.12 §11H Civil Rights Violation — coordinated group action to interfere with Sendelbach's lawful presence in a public space
EVIDENCE
Family recordings of June 6, 28, and 29, 2020. Alouette Batteau's Facebook Live recording, which — despite beginning after the assault — corroborates the timeline and proves the edit. The Change.org petition filed by non-attendee Bianca Cavanaugh-Green, which was removed by the platform for violations (defamation and misinformation), corroborates the community response and its basis in the edited video.
2020–2023 — Pattern of False Police Reports — Abuse of Process, Obstruction, Stalking
Over a period of approximately three years, the Hennessey-Batteau family filed approximately eight false police reports against Sendelbach. Not one resulted in charges. Each was dismissed, denied, or found to lack probable cause. In the majority of these reports, Shelburne Police did not interview Sendelbach before processing the complaint — a practice enabled by Sergeant Gilmore's June 29, 2020 email to Hennessey, in which he stated 'I've talked to John. It doesn't work,' functionally designating Sendelbach as unworthy of further engagement. That email is the structural explanation for everything that followed in the department's handling of this case.
The March 2023 filing illustrates the pattern at its most explicit. Hennessey's HPO affidavit quoted Sendelbach as threatening to 'never let go as long as my family is alive' — framed as a homicidal threat. Audio of the same encounter, presented to Judge Mazanec on March 22, proves the actual statement was 'I will never get along with the likes of you,' delivered while Hennessey was audibly laughing. The emergency HPO issued on that false testimony was vacated.
Detective Jenkins co-signed the criminal harassment charge without ever having met, interviewed, or reviewed any evidence provided by Sendelbach. Standard protocol when a formal homicidal threat allegation is filed is to contact the named individual. Jenkins drove to Hennessey's residence. He did not come to Sendelbach. He confirmed this on video at a summer 2023 road race where Sendelbach confronted him — stating he had never met Sendelbach before the show cause hearing and that Sendelbach had received 'due justice.' He appeared not to understand what due justice requires.
In September 2024, Alouette Batteau entered Sendelbach's workspace at The Mill, returned home claiming harassment, and Brook called police. Responding officers found No Crime Involved. Bodycam footage debunked the claim. Within days, Hennessey sent defamatory letters to Mill landlord Brad Walker — an escalation in direct response to a false report that police had already dismissed.
APPLICABLE CHARGES
• MGL c.269 §13A Filing False Police Report — per incident; eight documented instances
• MGL c.268 §1 Obstruction of Justice — use of police process to suppress lawful conduct and accumulate false appearance of problematic behavior
• MGL c.265 §43A Criminal Harassment — pattern of conduct across multiple years designed to cause fear and institutional damage
EVIDENCE
Police reports 25SHL-series (all dismissals and no-probable-cause findings). Show cause docket 2341AC000088 (June 6, 2023). Audio recording disproving March 2023 HPO affidavit. March 22, 2023 vacation order. Bodycam footage of September 2024 Mill incident (No Crime Involved). Det. Jenkins road race video (confirming he never interviewed Sendelbach before filing charges). Sgt. Gilmore's June 29, 2020 email to Hennessey.
March 15, 2025 — Coordinated Preemptive HPO Filings — Abuse of Process, Obstruction, Insider Access
On Friday, March 15, 2025, Katherine Hennessey, Brook Batteau, and Alouette Batteau filed three separate HPO petitions against Sendelbach simultaneously. Sendelbach had his own HPO petition scheduled for Monday, March 17 — two business days later. Court scheduling is not a public record. The question of how the Batteau family knew he was scheduled for Monday is not hypothetical: they filed two days before his appearance specifically to poison the court's perception before he could speak.
The physical environment at The Mill workspace provides the most probable answer. Stall partitions did not reach the ceiling — every conversation in the workspace was audible to adjacent tenants. Ann Loftquist, a neighboring tenant, had been observed by Sendelbach on multiple occasions cleaning in the sink area near his work stall despite having her own sink. This anomalous behavior, combined with the impossibility of otherwise knowing his Monday court date, points to eavesdropping as the mechanism by which the family obtained the scheduling information.
The effect of the coordinated Friday filing was precisely what it was designed to achieve: Judge Tolan received three petitions from the opposing family before Sendelbach said a word. All six petitions — theirs and his — were denied. But the reputational and procedural damage of appearing before a judge who has already processed three complaints against you is not neutralized by a symmetric denial.
APPLICABLE CHARGES
• MGL c.268 §6 Abuse of Legal Process — coordinated filing timed to preempt complainant's own scheduled petition
• MGL c.268 §1 Obstruction of Justice — using court filings to interfere with Sendelbach's access to the judicial process
• MGL c.272 §99 Eavesdropping (predicate) — mechanism by which court scheduling information was obtained
EVIDENCE
Court docket records showing simultaneous filing of three petitions on March 15, 2025. Court records showing Sendelbach's scheduled Monday March 17 filing. Physical layout documentation of The Mill workspace (open-top partitions). Contemporaneous notes regarding Loftquist's anomalous behavior near Sendelbach's work area.
May 2025 — Keystone Market — Manufactured Distress, False Report, Perjury
Sendelbach entered Keystone Market in Shelburne Falls. Hennessey followed him into the store and positioned herself directly behind him at the deli counter. He turned, stood his ground, and said nothing. She pushed past within 12 inches. He said quietly: 'You've got a lawsuit coming.' She screamed 'I FEEL UNSAFE!' at the top of her lungs. The store owner escorted her out.
What the store's exterior surveillance camera captured next is the evidentiary core of the perjury charge that follows. Behind the store owner's back: Hennessey displayed a broad smile. She gave a prolonged middle-finger gesture directed at the store. She laughed hard enough that her body rocked forward. She was not in distress. She was performing distress for an audience, and she stopped the performance the moment she believed the audience was gone.
Her December 1, 2025 sworn affidavit described Sendelbach at this encounter as 'puffing himself up,' 'yelling wildly,' and 'laying in wait.' The surveillance video shows none of this. Judge Mazanec viewed the video on December 15, 2025. He denied the petition with prejudice.
APPLICABLE CHARGES
• MGL c.269 §13A Filing False Police Report — affidavit account directly contradicted by surveillance video
• MGL c.268 §13 Perjury — sworn statements describing conduct that the video proves did not occur
• MGL c.268 §6A Misleading a Judicial Proceeding — submitting false affidavit to obtain court-ordered protection
EVIDENCE
Keystone Market surveillance video — complete sequence including exterior footage showing laughter, middle-finger gesture, and post-performance demeanor. Hennessey's December 1, 2025 affidavit. Judge Mazanec's December 15 denial with prejudice.
November 22, 2025 — Frog Mask — Criminal Harassment, Stalking, False Police Report
On the evening of November 22, 2025, Hennessey attended a public art installation event on the Iron Bridge wearing a giant paper-mache frog mask. Her subsequent sworn affidavit explains this decision: she 'suspected Mr. Sendelbach might show up and didn't want him to recognize me.' She positioned herself approximately six feet in front of him while he spoke publicly for fourteen continuous minutes. She did not retreat at any point. She showed no visible distress. At the conclusion of the event, she addressed him directly by name — 'John, I hope you get the help you need' — and left immediately after.
On this same date, November 22, Hennessey filed a police report claiming fear of Sendelbach. The affidavit accompanying her December HPO petition would cite this filing as evidence of her genuine fear. The filing and the conduct are irreconcilable. A person who genuinely fears another's presence does not attend an event where she expects that person to be present, arrive in disguise, position herself in his immediate vicinity for fourteen minutes, and address him directly at the end. She attended to observe him. The disguise was not protective — it was surveillance equipment.
APPLICABLE CHARGES
• MGL c.265 §43A Criminal Harassment — deliberate attendance and sustained positioning within six feet at Sendelbach's public event
• MGL c.265 §43 Stalking — component of documented multi-month pattern of deliberate targeted appearances
• MGL c.269 §13A Filing False Police Report — fear claim filed same date as conduct inconsistent with genuine fear
EVIDENCE
Witness accounts of November 22 event. Hennessey's own sworn affidavit, which confirms the disguise and the intent — she admits she expected him to be present and chose to attend anyway. Police report filed same date. The internal contradiction between the report and the admitted conduct.
November 28, 2025 — Moonlight Magic — Criminal Harassment, Stalking
On November 28, 2025, Hennessey attended the Moonlight Magic public event in downtown Shelburne Falls. Sendelbach was visible in his workspace at The Mill — a fishbowl-style display space with plate-glass windows fully exposed to the street. Hennessey walked directly past the window. She made direct eye contact with Sendelbach through the glass. She laughed.
Daughter Alouette Batteau, walking alongside her, appeared anxious and moved quickly past the window. The contrast between the two responses is significant. The daughter's reaction resembled genuine discomfort. The mother's was provocation — deliberate, visible, and documented.
This is the middle event in a three-part escalation across eight days: November 22 (police report claiming fear), November 28 (brazen public mockery at the window), November 30 (physical assault). The sequence is not coincidental. Each step was chosen.
APPLICABLE CHARGES
• MGL c.265 §43 Stalking — deliberate appearance six days before physical assault, part of documented escalation
• MGL c.265 §43A Criminal Harassment — targeted confrontation designed to intimidate
EVIDENCE
Sendelbach's contemporaneous account. Corroborating witness accounts from Moonlight Magic attendees. The three-event sequence itself — November 22, November 28, November 30 — as documentation of deliberate escalating conduct.
November 30, 2025 — Morning — Property Trespass, Criminal Harassment, Perjury
On the morning of November 30, 2025, hours before the evening assault, Hennessey drove onto property at the Neighbors Convenience Store building where Sendelbach rented workspace. She drove past the store entrance — where newspapers are sold, near the street — to the far end of the parking lot, where Sendelbach's car was parked and partially screened by the building.
Upon seeing him, she initially displayed a peace sign and smiled. He did not respond. She transitioned immediately to a prolonged middle-finger gesture, mouthed profanity, drove forward ten feet, stopped, repeated the gesture, and then sped away. Sendelbach called police. Sergeant Gilmore responded, walked the property line with Sendelbach, reviewed bodycam footage, and returned later to clarify the geography of the lot.
Hennessey's December 1, 2025 sworn affidavit describes this incident as follows: she drove into the lot 'to run and get a paper,' saw Sendelbach, and 'chose to drive away.' This is geometrically false. The store entrance and newspaper rack are adjacent to the street. His car was at the far end of the lot. There is no route from the street to a newspaper purchase that passes his vehicle. The drive to his car was the purpose, not the incidental result.
APPLICABLE CHARGES
• MGL c.266 §120 Criminal Trespass — driving onto rental property to the location of Sendelbach's vehicle
• MGL c.265 §43A Criminal Harassment — deliberate confrontation on the morning of the day of the assault
• MGL c.268 §13 Perjury — sworn affidavit account of this incident is factually impossible given the property's physical layout
EVIDENCE
Sendelbach's contemporaneous account. Sgt. Gilmore bodycam footage documenting the property layout investigation. Hennessey's December 1, 2025 affidavit containing the false 'to run and get a paper' account. Physical layout of the Neighbors Convenience Store property (documented by Gilmore on same date).
November 30, 2025 — Evening — Floodwater Assault — Assault and Battery, Malicious Destruction, Civil Rights Violation
On the evening of November 30, 2025, Sendelbach was standing on the public sidewalk outside Floodwater Brewing in Shelburne Falls, lawfully recording. What followed is documented in Sergeant Gilmore's probable cause report (25SHL-114-OF), in Zachary Livingston's sworn statement of December 9, and in Floodwater's exterior surveillance footage.
Tom Del Negro exited Floodwater screaming profanities at Sendelbach. Del Negro had no prior acquaintance with him — he had been primed by Batteau family members inside the establishment. Brook Batteau then charged out and shoved Sendelbach hard with both hands. Sendelbach fell backward off the curb. Katherine Hennessey exited approximately ten seconds later. She began striking him repeatedly in the head and face. A second unidentified person pinned Sendelbach's arms while she continued striking. Sendelbach did not retaliate at any point during the assault.
Hennessey then seized Sendelbach's iPhone, which was actively recording the incident. She walked approximately seventy-five feet to the bank of the Deerfield River and threw the lit, recording phone into the water — approximately thirty feet from the bank. The 2020 Facebook comment thread beneath the petition had included the promise: 'throw his camera in the river.' Five years of impunity. Then she followed through.
Approximately thirty seconds after the first assault, Hennessey followed Sendelbach and continued punching and kicking him from behind — a second, legally distinct assault at a separate location. Sendelbach suffered head and facial injuries. His pre-existing atrial fibrillation was triggered. He required medical attention.
Zachary Livingston — Floodwater's owner, with no prior relationship to Sendelbach, and notably the son of Joan Livingston whose Recorder had amplified the false 2020 narrative — confronted Brook Batteau immediately after the incident. Batteau admitted the shove. He stated: 'You don't understand, John has been after my family for five years.' That admission establishes premeditation. Brook Batteau was present throughout the December 15 hearing and chose not to repeat that statement under oath.
APPLICABLE CHARGES
• MGL c.265 §13A Assault and Battery — Katherine Hennessey: first assault, 30+ strikes to head and face
• MGL c.265 §13A Assault and Battery — Katherine Hennessey: second assault, continued striking and kicking at river bank (separate incident, ~30 seconds after first)
• MGL c.265 §13A Assault and Battery — Brook Batteau: hard two-handed shove causing Sendelbach to fall off curb
• MGL c.265 §13 A&B Causing Serious Bodily Harm — victim had documented pre-existing cardiac condition; assault triggered atrial fibrillation episode; elevated risk of stroke and cardiac event
• MGL c.266 §127 Malicious Destruction of Property — iPhone seized during active recording, carried 75 feet, thrown into Deerfield River
• MGL c.265 §43 Stalking — culminating act of documented multi-year pattern of targeted conduct
• MGL c.12 §11H Civil Rights Violation — assault to suppress lawful video recording of a public space
NOTE ON THE DESTROYED PHONE
The destruction of the recording phone was not incidental to the assault — it was its operational objective. Hennessey was aware the phone was recording. She seized it because it was recording. She then carried it seventy-five feet to the river and threw it in. This is deliberate evidence destruction, committed in the course of the assault, which elevates the Malicious Destruction charge and raises the question of whether an Evidence Tampering charge under MGL c.268 §13B is also applicable.
EVIDENCE
Probable cause report 25SHL-114-OF (December 11, 2025). Summons 25SHL-46-AR (Hennessey) and 25SHL-47-AR (Batteau). Zachary Livingston sworn statement, December 9, 2025 — documenting the assault, Brook Batteau's admission, and Batteau's 'five years' statement. Floodwater exterior surveillance footage. Medical documentation of injuries and cardiac episode. LIFEPAK 15 photograph from October 19, 2025 State Police visit (heart rate 130–230 BPM — documenting pre-existing cardiac state six weeks before assault). The Deerfield River — the phone is there.
December 1, 2025 — HPO Affidavit — Perjury, False Statements in Sworn Document
On December 1, 2025, Hennessey filed an HPO affidavit in Greenfield District Court. The affidavit contains multiple statements that are directly contradicted by available documentary evidence.
The Keystone Market account describes Sendelbach as 'puffing himself up,' 'yelling wildly,' and 'laying in wait.' The surveillance video shows none of this occurred. Judge Mazanec watched the video on December 15.
The Neighbors Convenience Store morning account states she drove in 'to run and get a paper' and 'chose to drive away' upon seeing Sendelbach. As established above, the physical layout of the property makes this account geometrically impossible.
The affidavit inverts the June 2020 'KKK members' statement — attributing to Sendelbach a slur that audio documentation proves she herself applied to him in June 2020.
The affidavit characterizes the November 22 frog-mask attendance as evidence of her fear of Sendelbach. Her own description of that evening — attending in disguise because she expected him to be there, positioning within six feet for fourteen minutes, addressing him directly by name at the end — is inconsistent with the fear she claims. A frightened person does not take those actions.
APPLICABLE CHARGES
• MGL c.268 §1 Perjury — multiple sworn statements directly contradicted by video, audio, physical evidence, and the affiant's own admissions elsewhere in the same document
• MGL c.268 §6A Misleading a Judicial Proceeding — filing of false affidavit to obtain emergency court-ordered protection
EVIDENCE
Hennessey's December 1, 2025 affidavit (complete document). Keystone Market surveillance video. Neighbors Convenience Store property layout (documented by Sgt. Gilmore). Audio recording from June 28, 2020. Hennessey's own statements within the affidavit re: November 22 event.
Pattern: 2020–2026 — Defamation Campaign — Business Interference, Constructive Evictions
The Hennessey-Batteau family's conduct was not limited to physical assault and false court filings. Over the full period of the campaign, they systematically targeted Sendelbach's workspaces using the same defamatory template — dangerous, racist, sexist, threatening — adapted to each new landlord relationship.
At 44 State Street, where Sendelbach had operated for nine years, the false campaign — false reports, community misinformation, and sustained pressure — created conditions under which the landlord could no longer maintain the tenancy without continued harassment. Sendelbach vacated under constructive eviction conditions. He lost nine years of established clientele, repeat collectors, and a commission pipeline to the Culinary Institute of America that included nine proposed works at values of $50,000 to $100,000 each.
At The Mill, the playbook was repeated. On September 6 and 9, 2024, Hennessey sent defamatory letters to landlord Brad Walker characterizing Sendelbach in identical terms. Walker initially refused to act and offered mediation. He subsequently joined the campaign. Walker told a third party, Parsons, that he had made a 'joke' $2,000 offer to 'take' Sendelbach. These letters arrived within days of the September 2024 Alouette Batteau false Mill complaint — a false report that police had already dismissed as No Crime Involved. The letters and the complaint were coordinated, not independent.
APPLICABLE CHARGES
• MGL c.266 §§127, 134B Interference with Business Relations — coordinated campaign targeting three consecutive workspaces using defamatory template
• MGL c.265 §43 Stalking — multi-year pattern of targeting Sendelbach's economic relationships and livelihood
EVIDENCE
Hennessey's September 6 and 9, 2024 letters to Brad Walker. 44 State Street and Mill tenancy records. Bodycam footage of September 2024 Mill incident (No Crime Involved finding). Parsons account of Walker's $2,000 statement. CIA commission records documenting the derailed pipeline.
Pattern: 2021 and 2023 — Prior Perjury — Established Course of False Testimony
The December 2025 perjury is not an isolated incident. Two prior proceedings establish a documented pattern of false statements under oath.
In a 2021 proceeding, Hennessey testified that she had not locked elbows with another person to block Sendelbach's path. The judge watched the video during the proceeding. The video showed her doing exactly what she testified she had not done. She denied it while the judge watched.
In March 2023, her HPO affidavit quoted Sendelbach as threatening to 'never let go as long as my family is alive.' Audio of the same encounter proves the actual statement was 'I will never get along with the likes of you,' delivered while she was laughing. Judge Mazanec vacated the HPO upon hearing the audio on March 22.
Three proceedings. Three sets of false sworn statements. Three instances where documentary evidence — video or audio — directly contradicted the testimony. The same judge presided over two of the three and made the same determination in each: the evidence does not support the sworn account.
APPLICABLE CHARGES
• MGL c.268 §1 Perjury — 2021 proceeding: denied locking elbows while judge watched video showing her doing so
• MGL c.268 §1 Perjury — March 2023: claimed homicidal threat; audio proves otherwise
• MGL c.268 §13 Pattern of False Statements in Judicial Proceedings — three separate proceedings, same mechanism, same result
EVIDENCE
2021 proceeding transcript and video (judge's contemporaneous observation of the contradiction). Audio recording disproving March 2023 HPO affidavit. March 22, 2023 vacation order. December 15, 2025 denial with prejudice (same judge, establishing pattern across two of the three proceedings).
Evidence Inventory
The following categories of evidence are available in support of the charges documented in this memorandum:
Audio and Video Recordings
• Family recordings, June 6, 28, and 29, 2020 — originating assault and subsequent documented statements
• Alouette Batteau's Facebook Live recording — corroborates timeline; the edit itself is evidence
• Sonny Walters bicycle encounter recording — documents same behavioral pattern applied to different target
• Keystone Market exterior surveillance video — directly contradicts December 2025 affidavit on multiple points
• Det. Jenkins road race video — confirms he never interviewed Sendelbach before co-signing the charge
• Sgt. Gilmore bodycam footage — November 30 morning; property layout documented
• Multiple encounter recordings across the five-year period documenting the stalking pattern
Police and Court Records
• Report 25SHL-114-OF — Probable Cause, December 11, 2025
• Summons 25SHL-46-AR (Hennessey) and 25SHL-47-AR (Batteau)
• Show Cause docket 2341AC000088 — No Probable Cause, June 6, 2023; video reviewed
• March 22, 2023 vacation order — HPO vacated after audio presented
• December 15, 2025 denial with prejudice
• September 2024 police report — Alouette Batteau Mill complaint; No Crime Involved
• Walters HPO audio — judge's verbal-only restriction documented; public misrepresentation documented
• Sgt. Gilmore's June 29, 2020 email to Hennessey — the permission structure documented
Written Documents
• Hennessey's September 6 and 9, 2024 defamatory letters to Brad Walker
• Hennessey's December 1, 2025 HPO affidavit — multiple false statements documented against video and audio
• Change.org petition — removed by platform for violations (defamation, misinformation)
Sworn Statements
• Zachary Livingston sworn statement, December 9, 2025 — documents assault, Brook Batteau's admission, and the 'five years' statement
• Sendelbach's HPO affidavit — comprehensive sworn documentation of the complete incident history
Medical Documentation
• AFib medical records — onset concurrent with campaign onset 2021; documented progression
• LIFEPAK 15 photograph — October 19, 2025, Massachusetts State Police barracks; heart rate 130–230 BPM; Officer Sheer neutral third-party witness
• November 30, 2025 injury documentation — head and facial injuries; cardiac episode following assault
Summary Statement
The aggregate of conduct documented in this memorandum constitutes a sustained, multi-front campaign of physical assault, judicial process abuse, economic sabotage, and false reporting across five and a half years. It is distinguished from most cases presented to this office by the quality and completeness of the documentary record: audio recordings that disprove sworn testimony, video recordings that contradict affidavit statements point by point, a neutral eyewitness sworn statement, a police probable cause finding, and two judicial determinations by the same judge across two separate proceedings — each reaching the same conclusion when confronted with the same evidence.
The November 30, 2025 physical assault provides the most immediate basis for prosecution. The probable cause has been found, the summons issued, the neutral witness sworn, the footage secured. The perjury pattern across three proceedings provides a separate charge sequence that would be unusual in its evidentiary completeness: in each instance, the false statement is contradicted not by competing testimony but by recording. You can hear what she said. You can watch what she did. The sworn accounts describe neither.
This memorandum is submitted to support the District Attorney's investigation and any prosecutorial action the office determines to be appropriate.
John F. Sendelbach
Landscape Design / Public Art · Shelburne Falls, Massachusetts
