In a sentencing memo filed Wednesday, prosecutors said there was also a quota system within the troop’s “X-Team” program. Troopers were expected to issue at least 12 citations during an eight-hour overtime shift, prosecutors said.

Prosecutors in US Attorney Andrew E. Lelling’s office last month described how troopers working four-hour overtime shifts for the Accident and Injury Reduction Effort, or AIRE, program within the disbanded Troop E were required to issue at least eight citations per shift.

In a new court filing, federal prosecutors say troopers in a troubled State Police unit had a second quota system for issuing traffic tickets on the Massachusetts Turnpike.


“Any failure to issue the required number of citations drew negative scrutiny from supervisors and command staff,” prosecutors wrote in the memo, which was filed in the case against Daren DeJong, a retired trooper who pleaded guilty to embezzlement in January.

As the Globe reported last month, such quotas are considered unconstitutional in Massachusetts, and the State Police has for years denied using them. Last month, the agency said it had no current policy or procedures that establish quotas, doesn’t endorse them, and that no one in the current command staff remembers a quota system ever being in place.

“We do not, and have never, endorsed a quota system,” spokesman David Procopio said Wednesday in an e-mail.

Last spring, State Police announced a slate of reforms in the aftermath of the overtime fraud scandal, including disbanding Troop E. The department has said its “AIRE” and “X Patrols” were discontinued in early 2017.

The new court filing also revealed prosecutors estimate DeJong fraudulently collected more than twice as much money to which he pleaded guilty.

DeJong, 57, of Uxbridge, was arrested in July for allegedly collecting about $14,000 for overtime he didn’t work in 2016.


After DeJong pleaded guilty, US District Judge Mark L. Wolf ordered prosecutors to provide any information indicating whether DeJong’s scheme began before, or continued after, 2016. Wolf indicated he wanted to consider such conduct in deciding on a sentence.

Prosecutors estimated that DeJong fraudulently collected another $16,000 in overtime pay in 2015, and about $1,000 more in January 2017, according to Wednesday’s filing.

State Police began an internal investigation into overtime programs at Troop E in early 2017, according to prosecutors.

DeJong collected about $190,000, including more than $53,000 in overtime, in 2017; about $200,000, including more than $68,000 in overtime, in 2016; and $188,000, including about $67,000 in overtime, in 2015, according to records of the state comptroller’s office.

The new memo also revealed DeJong — like at least one other trooper implicated in the fraud scandal — destroyed or disposed of copies of traffic citations as part of his scheme. Falsifying and destroying traffic citations, or attempting to do so, is illegal under state law.

Including DeJong, 46 current and former Troop E members — representing approximately one-third of the division — have been accused by an internal State Police audit of collecting overtime for hours and shifts they didn’t work.

The audit’s findings have been shared with state and federal prosecutors, who are conducting parallel investigations.

Troopers during both regular and paid detail shifts also wrote “bogus” traffic citations, prosecutors have said.


Criminal charges have been filed against 10 members. DeJong is one of eight to plead guilty.

Two have been sentenced. One was sentenced to a year of supervised release, including three months of home detention. Another was ordered to serve three months in prison, followed by a year of supervised release. Both were ordered to pay back what they embezzled.

DeJong is scheduled to be sentenced May 1. On Wednesday, prosecutors recommended he spend six months in prison, followed by a year of supervised release, and pay a fine and restitution. DeJong’s attorney declined to comment Wednesday.

DeJong worked for the department for about three decades before retiring last March, days after the department accused him of skipping shifts. He is collecting a $75,000-a-year pension, state records show.

Matt Rocheleau can be reached at matthew.rocheleau @globe.com. Follow him on Twitter @mrochele