Keith A. Stiles, former police chief of Leesburg, is threatening to file a $350,000 federal lawsuit against the town, claiming that he was fired in April for exposing possible misuse of the town's credit card by top officials.

Stiles's attorney, Elaine Charlson Bredehoft, sent town officials a draft copy of the 18-page complaint Thursday. In an attached letter, Bredehoft said she plans to file suit in U.S. District Court in Alexandria on Friday if "we have not heard from you or resolved this matter" by then. She declined to comment further.

Earlier this year, the Town Council, at the direction of then-acting town manager Paul E. York, voted 4 to 2 to dismiss Stiles. Stiles had been appointed chief in 1995. Officials said Stiles was terminated because of high turnover among his officers and concern that he was too quick to order internal investigations.

The firing came less than two months after Stiles provided information to Loudoun Commonwealth's Attorney Robert D. Anderson that sparked a criminal investigation into whether then-Town Manager Steven C. Brown and then-council member Joseph R. Trocino had misused the town's credit cards.

Brown and Trocino denied any wrongdoing, but both resigned March 1 as part of a deal with prosecutors to drop the case. Brown admitted that he had made personal purchases with the town's American Express card but said he wrote checks to the company for his share. No criminal charges were filed.

Stiles's draft complaint alleges that public statements made by town officials regarding his dismissal were "merely a pretext for the true reason for his termination." It goes on to say that he was not provided a "legitimate justification" for his termination.

"Defendants terminated Mr. Stiles in retaliation for reporting the illegal activities" of Brown and Trocino, the draft complaint states. The complaint alleges wrongful discharge, defamation and violations of Stiles's constitutional and civil rights.

Council members and Leesburg Town Attorney Deborah Welsh declined to comment Friday on the specifics of the letter or the draft complaint.

But council member Leonard McDonald, named as a defendant in the draft, said Stiles has "no grounds whatsoever" to file a lawsuit. "He's chosen by the town manager, who has the ability to hire and fire," McDonald said.

The draft complaint says that Stiles's performance evaluations were "exceptional" and that he was never "counseled by Brown or York for any deficiency in performance or attitude."

In addition to McDonald and the Town of Leesburg, the draft complaint names Mayor James E. Clem, Vice Mayor B.J. Webb and York as defendants.

Critics have charged that Stiles's poor management skills led to unrest in the department and contributed to 23 officers leaving within four years. Officers also complained that Stiles had ordered 113 internal investigations in his last two years, causing them to live in "daily fear" of losing their jobs, according to council members.

During Stiles's last weeks as chief, officers circulated a petition for a vote of no confidence in his leadership, but it was never presented to the council.

McDonald, Clem, Webb and council member Robert J. Zoldos voted in April to fire Stiles. Council member Kristen C. Umstattd and former council member J. Frank Buttery Jr. voted to retain him, while new member Mervin Jackson abstained.

Stiles's supporters say he ran a tight ship and was punished for being a whistleblower.