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Judicial Watch • JW v Chicago Office of Mayor show cause 00462

JW v Chicago Office of Mayor show cause 00462

JW v Chicago Office of Mayor show cause 00462

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Date Created:August 16, 2017

Date Uploaded to the Library:August 16, 2017

Tags:electronically, santell, SVENSON, mayors, honor, 00462, hearing, mayor, search, chicago, filed, plaintiff, request, FOIA, department, office


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E-Notice
2016-CH-00462
CALENDAR:
To: Alice Christine Svenson
christine@svensonlawoffices.com
NOTICE ELECTRONIC FILING THE CIRCUIT COURT COOK COUNTY, ILLINOIS
JUDICIAL WATCH, INC. vs. THE OFFICE THE MAYOR THE
2016-CH-00462
The transmission was received 01/09/2017 4:00 and was ACCEPTED with
the Clerk the Circuit Court Cook County 01/09/2017 4:02 PM.
RULE SHOW CAUSE(SET FOR MOTION HEARING)
EXHIBITS
EXHIBITS
EXHIBITS
Filers Email:
Filers Fax:
Notice Date:
Total Pages:
christine@svensonlawoffices.com
(312) 467-2902
1/9/2017 4:02:28
DOROTHY BROWN
CLERK THE CIRCUIT COURT
COOK COUNTY
RICHARD DALEY CENTER, ROOM 1001
CHICAGO, 60602
(312) 603-5031
courtclerk@cookcountycourt.com
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CALENDAR:
PAGE
CIRCUIT COURT
COOK THE CIRCUIT COURT COOK COUNTY, ILLINOIS COUNTY, ILLINOIS
CHANCERY DIVISION
COUNTY DEPARTMENT, CHANCERY DIVISION
CLERK DOROTHY BROWN
JUDICIAL WATCH, INC.,
Plaintiff,
vs.
THE OFFICE THE MAYOR THE CITY CHICAGO
and
RAHM EMANUEL, his
official capacity Mayor the
city Chicago
Defendants.
____________________________________)
Case No.: 00462
Honorable Judge Demacopoulos
PLAINTIFF PETITION FOR RULE SHOW CAUSE
WHY DEFENDANTS SHOULD NOT HELD CONTEMPT
NOW COMES Plaintiff Judicial Watch, Inc. Plaintiff counsel, and petitions this
Court enter order for rule show cause why Defendants The Office the Mayor the
City Chicago and Rahm Emanuel, his official capacity Mayor the City Chicago,
should not held contempt, and support thereof states follows: September 23, 2016, after full hearing Defendants Motion Dismiss Plaintiff
Complaint, this Honorable Court concluded follows:
(a) that Mayor Emanuel proper party this cause,
(b) denied Defendants motion dismiss Counts and Plaintiff Complaint;
(c) did not rule Defendant motion dismiss Count III Plaintiff Complaint;
(d) ordered that the parties are decide the search terms, and Defendants response shall
come from the FOIA officer for the Officer the Mayor. (See Attached Exhibit
Order September 23, 2016). This Court further stated open court that the parties are meet and confer and agree
upon search terms, saying that would the parties decide how they wish
define the search terms, (See Attached Exhibit transcript proceedings September
23, 2016, 27) and for new search done. (See 39). Subsequent the Court order, the parties met and conferred. Plaintiff proposed
search terms and asked that the email accounts specific employees the Office the
Mayor searched for those specific terms for the time period October 20, 2014 December 2015. Plaintiff also asked Defendants for information about how searches could conducted
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PAGE that Plaintiff could narrow the search parameters. November 2016, Defendants informed Plaintiff counsel that the searches
yielded result over 900,000 emails. Defendants did not identify the methods used what
its capabilities are. Later that day, Plaintiff again asked Defendants about how searches could conducted that could narrow the search parameters. For example, Plaintiff wants know
Defendants can conduct searches with AND clauses w/NUMBER WORDS clauses.
addition, Plaintiff asked Defendants possible break down the search results terms
and/or email accounts. Plaintiff believes such information may also allow narrow the search
results. light recent news and other court rulings1, November 2016, Plaintiff
requested that Defendants confirm that they are searching the non-government email accounts
See http://www.chicagotribune.com/news/local/politics/ct-rahm-emanuel-personal-emailmet-1108-20161107-story.html
the employees the extent those employees were using other accounts besides their official
government accounts conduct official government business.
Plaintiff subsequently followed with Defendants email November 16,
2016, November 28, 2016, and December 2016 relative all the above issues. date,
Defendant has not responded Plaintiff let alone answer any the questions Plaintiff has posed
concerning Defendants search efforts.
Because Defendants have failed respond Plaintiff inquires, Plaintiff cannot
comply with the Court September 23, 2016 order. addition, Defendants failure respond Plaintiff inquiries violates the Court order.
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PAGE
The conduct the Defendants willful and malicious and contempt the
order previously entered this cause.
10. The conduct the Defendants failing comply with the terms and conditions the
previous court order without compelling cause justification.
WHEREFORE, Plaintiff petitions this Court enter order for rule show cause
why Defendants should not held contempt and order Defendants comply with the
Court September 23, 2016 order.
Dated: January 2017
Respectfully submitted,
/s/ Christine Svenson
Christine Svenson
Ill. Bar No. 6230370
Cook County Attorney No. 44565
SVENSON LAW OFFICES
505 LaSalle Street, Suite 350
Chicago, 60654
Tel: (312) 467-2900
Fax: (312) 467-2902
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CALENDAR:
PAGE
CIRCUIT COURT
COOK COUNTY, ILLINOIS
CHANCERY DIVISION
CLERK DOROTHY BROWN
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CALENDAR:
PAGE
CIRCUIT COURT
COOK COUNTY, ILLINOIS
CHANCERY DIVISION
CLERK DOROTHY BROWN
Judicial Watch Office Mayor 462
Report Proceeding
Taken on: September 23, 2016
Judicial Watch Office Mayor
Hearing 09/23/2016 STATE ILLINOIS SS. COUNTY COOK
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PAGE THE CIRCUIT COURT COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION
JUDICIAL WATCH, INC.,
Plaintiff,
vs. No. 00462
THE OFFICE THE MAYOR
THE CITY CHICAGO
and
RAHM EMANUEL, his
official capacity Mayor the city Chicago
Defendant. Report proceedings had the hearing the above-entitled cause before the HONORABLE ANNA HELEN DEMACOPOULOS, Judge said Court, commencing 10:43 a.m. September 23, 2016.
APPEARANCES:
SVENSON LAW OFFICES,
MS. CHRISTINE SVENSON behalf the Plaintiff;
CITY CHICAGO, LEGAL INFORMATION, INVESTIGATIONS PROSECUTIONS,
MR. PHILLIP SANTELL behalf the Defendant.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 THE COURT: Good morning, CounseL. MR. SANTELL: Good morning, your Honor. name Phillip Santell, This corporation counsel for the City Chicago representing defendant this matter. THE COURT: Good morning. MS. SVENSON: Good morning, your Honor. Christine Svenson, behalf plaintiff, Judicial Watch, Inc.
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PAGE THE COURT: You may seated. going ask that you all argue from counsel table. just ask that you stand that you can clearly heard. know its easier spread out your paperwork the table. Were here today defendants motion dismiss. MR. SANTELL: Thats correct, your Honor. THE COURT: have read have the amended complaint, the defendants motion, plaintiffs response, defendants reply supporting affidavit, and then plaintiffs sur-reply. just have question before begin. the defendants reply supporting affidavit, there mention that June 2016, there was subsequent response the FOIA request. Does the plaintiff have that?
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 MS. SVENSON: No. glad you brought that up, your Honor, because are not possession that. was surprised see that the affidavit. Counsel did produce yesterday response, and dated with yesterdays date. MR. SANTELL: Your Honor, may. THE COURT: Please. MR. SANTELL: This matter that discussed with supervisor who handled -ELECTRONICALLY FILED
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PAGE THE COURT: You need clearer. MR. SANTELL: This matter that discussed with supervisor, Amber Ritter, and this matter that came attention, and wasnt sure whether not there was subsequent response that went out clarified response that went out. true that the reply mentioned. looked for it. could not find it. Therefore, reached out counsel ensure she had it. She indicated that she couldnt find it. Therefore, ensure that everything was taken care of, sent the one dated yesterday her. exactly the same the reply that went out January 7th. The only thing that different that addressed from the Mayors office opposed
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 from the Chicago Police Department. All the exemptions are the same. The records that were produced are the same. exactly the same. THE COURT: Except for the cover letter, the words, Chicago Police Department are replaced with Office the Mayor. MR. SANTELL: That correct, your Honor. THE COURT: And dated July 14th? MR. SANTELL: Well, not entirely sure there
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PAGE was one dated July 14th that was sent out. would not have sent out, but did send one counsel yesterday, and have copy with today. THE COURT: you have now? MS. SVENSON: do. THE COURT: Does that change anything for today? MS. SVENSON: dont think that does. THE COURT: Okay. least were clear that you have second response the FOIA request. MS. SVENSON: yesterday, yes. THE COURT: All right. Counsel, ahead. MR. SANTELL: Thank you. Your Honor, today were defendants motion dismiss plaintiffs amended complaint pursuant Section 2619.1, which combines both Section 2615 and
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 2619. Here its the defendants contention that plaintiffs complaint fails under both 2615 and 2619 because excessively vague and without specific factual allegations. And looking the face the complaint, clear that the city has met its obligation under FOIA, which therefore both these defeat the plaintiffs claim. Starting with Section 2615, generally Section 2615 deals with the legal sufficiency the
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PAGE complaint based upon defects that are apparent the face. important note that Illinois fact pleading jurisdiction. Therefore, plaintiff must allege specific facts not mere conclusions conjecture. Legal conclusions and factual conclusions that are unsupported allegations and specific fact will disregarded ruling motion dismiss. That was the case Cummings versus City Waterloo, which available 289 Ill. App 3rd, which believe was the First District appellate case. Generally speaking, the plaintiff must allege specific facts that allow defendant essentially placed notice the claims that are against them and allow them form defense those claims. Here this case after amending their pleadings, plaintiffs
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 still have not alleged specific facts that would enable them survive 2615 motion dismiss. Specifically, Count plaintiff alleges that they did not receive response the FOIA request. Looking the face the complaint and the documents that are attached the subsequent findings, clear that this simply not supported the defendants complaint. Plaintiff acknowledges Paragraph their amended complaint that they
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PAGE received response from the city dated January 2016, and they have attached that response their filings with this Court. Now, plaintiff arguing that this somehow nonresponsive, but thats not the case, your Honor. Its simply the fact that this was simple clerical error, that Chicago Police Department was listed when should have been the Mayors office. THE COURT: But, counsel, everything that has been attached -20 MR. SANTELL: Yes, your Honor. THE COURT: and even the question that the Court had before even began today and even your own admission that you yourself were unclear whether not there was specific response from the Mayors office
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 this FOIA was unclear even yesterday. MR. SANTELL: Now, response that, Judge, would essentially its not dismissive but believe that its distinction without indifference. And the reason that say that because the FOIA response that went out the plaintiff, believe was just over 3,000 documents, including documents from the City Law Department, from the Mayors office, from CPD. was city wide search. believe there are
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PAGE more than e-mail inboxes that were searched. Therefore, whether not its entitled from the Mayors office from CPD from the Law Department whatever is, thats unimportant because you look the substance the letter, its clear that the Mayors office inbox the Mayors office -16 the Mayors e-mail, his personal e-mail, was searched well his staff. THE COURT: Thats not clear. And the Mayors office website itself and going quote it. Each city department separate agency responsible for maintaining its own records. Requests should submitted the department that maintains the records you want. MR. SANTELL: Yes. Thats entirely true.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 THE COURT: youre demanding city that the requester make request the specific department, why okay then for the city respond generically? MR. SANTELL: Well, the citys position, Judge, that this was special instance. had more than requests from the same material covering the October 2014 shooting Laquan McDonald. had numerous different requesters asking for different things.
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PAGE Therefore, order conserve resources and try answer everyones FOIA request the truncated period time thats required FOIA, the city did something that might unusual. What the city did that tried come with search terms and search -15 and places search that would essentially cover all the requests and provide, many cases, like this one, lot more information than would have been provided the individual searches were run. For instance, would have simply searched the Mayors office, all the information that was provided plaintiff from the CPD, from the Law Department, that would have been excluded. this case, kind deal with the exigency thats required FOIA and try get the response out
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 since there were many demand, kind for lack better term try come with group search terms and inboxes which search get these communications that would cover all the requests. Given the fact that theres such limited time and given the fact city resources were limited, this solution that was come with. THE COURT: Collectively. MR. SANTELL: Essentially, yes.
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PAGE THE COURT: And doesnt that defeat the whole purpose individual public bodies under FOIA? MR. SANTELL: No. dont believe does. believe that this situation different than your usual FOIA request. The usual FOIA request, may, lets say -16 THE COURT: There usual FOIA. MR. SANTELL: Thats correct, your Honor. Maybe more typical FOIA request better way put it. more typical FOIA request would say the Department Revenue, please, you know, tell give documentation related how many boots the department maintains. this instance, this FOIA request and all these other requests were for documents from different
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 city departments involving the same item. essentially, all these FOIA requests taken together kind forced look beyond just one department order try fulfill the request, and thats what tried do, your Honor. tried fulfill the requests and tried provide everyone with the documentation that needed and documentation that they are asking for. THE COURT: Look, understand that hindsight
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PAGE now when were talking courtroom its different than the time constraints public relations issue that the city was managing the time answer and respond all these FOIA requests. This may have been the expeditious and cost effective way respond the multiple FOIA requests. get that, but now when were court and were looking the law specifically, its very clear that the Mayors office different than the Chicago Police Department and the Law Department. MR. SANTELL: Yes, absolutely. Thats true. THE COURT: until yesterday when was very clear that the response was coming from the Mayors office, Count No. was you did not respond. The Mayors office did not respond.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 MR. SANTELL: Well, your Honor, again, without being dismissive THE COURT: understand. MR. SANTELL: would argue. THE COURT: Youre difficult position standing here this courtroom having answer this question for other people that made that decision. MR. SANTELL: Well, the reason would say that thats perhaps distinction without indifference
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PAGE because the Mayors staff, the Mayors e-mail, everything was searched response her request. And not the instance where Judicial Watch this case alleging that they sent request CPD, they sent request the Chicago Fire Department, they sent request the office Emergency Management Communications, and they only received this one request back. There are other requests. They didnt make request CPD. when they received the request, should have been clear that was simply error that Chicago Police Department was listed the top. THE COURT: Then theres the subsequent e-mails Ms. Ritter identifying specifically. And understand that her position the time sure that was chaos. totally understand that, that
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 must have been chaos with all the requests the various city departments were being inundated. But some point time, now that things have kind settled, still have still kind restricted what the FOIA statute says, and each individual agency which each individual department the city individual entity public body. MR. SANTELL: Yes, absolutely. Thats entirely true, your Honor, but the citys position that
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PAGE although Let phrase this another way. That although each individual entity its own body that this particular instance, the request would have not been answered fully these other bodies werent involved. THE COURT: So, other words, the response still would have been the same. other words, the documents that were turned over would still the same. MR. SANTELL: The documents from the Mayors office would exactly the same. Our position that gave essentially went above and beyond. gave lot more documents the interest transparency the plaintiff than their request they requested. Given the fact that the plaintiffs made other requests any other city agency
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 THE COURT: dont know that, though. dont know that based these pleadings. MR. SANTELL: Well, thats true, your Honor. Their allegations are they submitted FOIA request December 2nd and that they subsequently received response January 7th, but the response was entitled from the Chicago Police Department. Those are the allegations, not mistaken them. Therefore, the city feels that did respond.
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PAGE There was clerical error the response that had subsequently been cleared up. The responsive documents, everything, all the e-mails are identical. The exemptions that are asserted are identical. Its the same response essentially. Its just fashioned from the Mayors office opposed CPD. THE COURT: Lets move Count No. the sufficiency the search terms. MR. SANTELL: Now, the second count, plaintiff alleging that the search was insufficient. explained Amber Ritters affidavit, there were many requests for the same -22 THE COURT: just lost that. want the record clear. you want repeat that? MR. SANTELL: explained Amber Ritters
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 affidavit, which attached our reply, the city had received many different requests for essentially the same information. Therefore, what the city did came with inboxes searched and search terms used. use the terms Laquan, Van Dyke, Van Dyke with different spelling, and also LM, the abbreviation for Laquan McDonald. So, therefore, came with the terms that would universally applicable and would pick out the relevant information and the relevant
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PAGE documents. And, addition, the responsive letter clearly states that, quote, believe this production fulfills the terms the FOIA request. the extent you are seeking additional material, please direct renewed FOIA request the appropriate city department. this case, plaintiff did not submit subsequent FOIA request. Instead, they filed lawsuit against the city. Theyre arguing that the search was inadequate because the terms, dash-camera and recording, were not used the terms that were searched. Its not clear from their request, which very general, and attached their sur-reply. believe Exhibit Their request for any and all records -24 THE COURT: Counsel, slow down.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 MR. SANTELL: Okay. apologize. THE COURT: You want clean record. MR. SANTELL: There request was for, quote, any and all records communications sent from officials the office the Mayor, including but not limited to, Mayor Rahm Emanuel, regarding, concerning relating police dash-camera recording the October 20, 2014 shooting Laquan McDonald, including but not limited the release any such video
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PAGE recordings the public. Now, plaintiff attempting argue that since the terms camera, recording dash were not used, that the search inadequate. Well, your Honor, theres couple problems with that. First being that the generalized terms camera, dash, recording would not gather materials responsive this request. The generalized terms that were not set out search terms searched the request there was requests basically saying that please search the Mayors staff Mayor Rahm Emanuels e-mail for these specific key words. That was not done. This generalized request was for material that dealt with the release the material related the shooting Laquan McDonald. THE COURT: You skipped the words police
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 dash-camera. MR. SANTELL: Yes, your Honor, because thats what was released. The police dash-camera was released. That was the information that was released. whether not gather responsive documents, the terms that were used were specific this instance, Van Dyke, two spellings, Laquan, LM, those items. were search CPD e-mails for dash CPD e-mails for camera recording the Mayors office, would come with
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PAGE perhaps lot things that would irrelevant these proceedings. THE COURT: But there more than one dash-cam video recording this instance the October 20th shooting; isnt there? MR. SANTELL: believe there were now cant remember exact number. THE COURT: And thats exactly the point. you limited the search just Van Dyke, which officer, and you limited the search the victim, Laquan McDonald LM, and you limited the search just those, you are excluding all those other possible dash-cams that were involved. MR. SANTELL: Well -24 THE COURT: Because those e-mails did not
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 contain the victims name, single officers name, then you are excluding all those e-mails. MR. SANTELL: Well, the e-mails that excluded were e-mails that are not related all this proceeding. your Honor can certainly imagine, there are hundreds dash-cams different vehicles all across the city the Police Department. Whether not there are communications that deal with those, they would have nothing all with the Laquan McDonald
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PAGE instance for the period time was searched. using these expansive, open-ended terms, would bringing perhaps cant even guess how many additional e-mails, but they would not relevant e-mails. The relevance would Laquan McDonald, LM, Van Dyke was searched. Those would the relevant terms. THE COURT: How did the terms The affidavit says that want use the exact words gleaned from the many requests and then calculated produce the broader set relevant records. Who made that decision, and that was the case, were other requesters involved making that decision excluding Judicial Watch? MR. SANTELL: dont believe that other requesters
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 were involved. think what occurred that looking the great number requests the city received, that order answer them, perhaps terms were taken from certain letters. Again, was not involved that process. cant say definitively, but looking the affidavit, believe thats what indicates, that there wasnt necessarily give and take speak with the requesters, but that looking the request, these terms were used.
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PAGE THE COURT: Okay. understand, and mean this sincerely that you standing front having answer these questions very difficult, but these are questions that have ask required the statute. The statute very specific that every single body must have FOIA officer. Who the FOIA officer for the Office the Mayor? MR. SANTELL: this time, believe was Chloe Rasmas. THE COURT: Who? MR. SANTELL: Chloe Rasmas believe was. THE COURT: And dont have any documents from her him. MR. SANTELL: What happened, your Honor, the
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 City Chicago Department Law represents basically all the agencies that were involved here. this was understanding that this was handled through the Department Law given the large number requests and the different bodies that were involved different city entities that were involved. THE COURT: Okay. MR. SANTELL: going ahead with Count failure produce all nonexempt information. Here, the
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PAGE plaintiff alleges that simply because there were redactions, that the production incomplete. this case, there were more than 3,000 e-mails that were produced. There were, believe, five six different exemptions that were cited. Here, plaintiff doesnt allege any specifics what they take issue with. There indication that they take issue with, say, (d)(iv), for example, (c), for example sorry 7(1)(c) (7)(1)(d)(iv) any the different FOIA exemptions. They basically state that this production was incomplete simply because contained redactions. Judge, this doesnt give the city anything speak which form defense. THE COURT: Has there ever been request for
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 index yet? MR. SANTELL: Not from Judicial Watch, your Honor, far aware. sure counsel will able correct that its incorrect. addition, your Honor, Mayor Rahm Emanuel personally should dismissed from the suit well pursuant Section 2615. THE COURT: Why? MR. SANTELL: Because looking the authority
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PAGE sue, which found ILCS 140/11, which indicates denial request for public records injunctive declaratory relief. indicates that any person denied access inspect copy any public records public body may file suit for injunctive declaratory relief. you switch the definition section, which found 5ILCS140/2, public body defined term. Its found under Public body means all legislative, executive, administrative advisory bodies the State, State universities and colleges, counties, townships, cities, villages, incorporated towns, school districts any other municipal corporations, boards, bureaus, committees commissions the State and any subsidiary bodies any the foregoing, cetera.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 Your Honor, there given this definition and given the fact that the language that allows someone bring suit for declaratory injunctive relief specifically lists public body. dont believe that the Mayor individual appropriate defendant this matter. Now, opposition this point THE COURT: The suit Rahn Emanuel his official capacity. Its not his unofficial capacity.
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PAGE MR. SANTELL: That correct. Our position that should simply against the Office the Mayor, not against Rahn Emanuel. support their argument that the Mayor proper party, counsel cites opinion from the First District Appellate Court the matter Quincy Stone (phonetic), which was decided 1991. And have copy for your Honor your Honor does not have one. This deals with the instance where -19 THE COURT: Hold just second. ahead MR. SANTELL: This deals with the instance where someone trying bring injunctive suit against alderman. And the issue before the Court whether not that alderman can sued, whether not the
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 individual alderman public body. And this lawsuit, the Court described FOIA used before the 2010 amendment. Before 2010, you were denied anything from public body, you had appeal the head that public body. And essentially after you would receive denial from the head the public body, you would receive use phrase key the courtroom, that essentially this was prerequisite that had met prior the ability bring suit.
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PAGE Now, this matter, there language that indicates that this person should have brought suit against the Mayor and the city counsel. Now, the Mayor the head the city counsel, and they were together public body. Given the fact that this opinion not broad the plaintiffs set out be, and believe that its distinguishable being the fact that works with older version FOIA, and its also dealing with entirely different set facts, which deals with alderman, city counsel and Mayor head city counsel. believe this case distinguishable. believe the FOIA definition public body clear under Section was read and indicated into the record well the authority sue public body. believe there authority argue that
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 the Mayor individual appropriate defendant under FOIA. Thank you. THE COURT: Counsel. MS. SVENSON: Thank you, your Honor. the outset, would point out that defendants motion dismiss states plaintiff fails plead facts showing that the city failed respond. Thats Argument Argument plaintiff has not pled facts showing that the city failed conduct
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PAGE sufficient search. Argument plaintiff has not pled facts showing the city failed produce all nonexempt information. thats just false. pled that the office the Mayor did not respond, that the office the Mayor failed conduct sufficient search, that the office the Mayor failed produce all nonexempt information. That was addressed counsels argument, but think its important note that they are trying mislead the Court saying that its the city thats involved here. Its the Office the Mayor. And simply put, the Office the Mayor did not respond our FOIA request. The January 7th, 2016 letter Ms. Ritter clearly states that she was responding FOIA request
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 directed the Chicago Police Department. She also states your request you sought, quote, any and all records communication sent from officials the CPD, including but not limited superintendant Garry McCarthy, regarding, concerning relating police dash-camera recording the October 20, 2014 shooting Laquan McDonald. Thats false. Thats not what were seeking all. Its very clear from our FOIA request what were seeking.
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PAGE our amended complaint, specifically note that -12 THE COURT: now having received yesterdays response that clearly identifies the Office the Mayor, does that satisfy the request? MS. SVENSON: does not. did not come from the FOIA officer from the Office the Mayor. know that now. does not provide with the search was not accurate sorry not complete. THE COURT: Forget that. Lets stick with the issue whether not the Office the Mayor has responded because thats big issue. MS. SVENSON: Right. not believe so. Theres affidavit attached the request, dont believe.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 THE COURT: you have the request that was sent yesterday for the Court view? MS. SVENSON: Yes. THE COURT: the response. sorry. The response the request. (Document tendered.) THE COURT: Can have one minute read it? MS. SVENSON: Sure. THE COURT: the body exactly the same.
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PAGE The only difference now says the Office the Mayor. MS. SVENSON: believe thats correct. THE COURT: Okay. And the letter signed Mr. Santell assistant corporation counsel. MR. SANTELL: That correct, your Honor. sent counsel yesterday. THE COURT: ahead, Counsel. MS. SVENSON: So, yes, not believe this was properly responsive because there does not come from the FOIA officer from the Office the Mayor, and there are affidavits attached showing that they did complete search. THE COURT: ahead. MS. SVENSON: Relating the actual search, the
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 search was inadequate, and they are trying change the law misread the law. Its not the requesters burden show that they conducted accurate search. Its their burden, and they just simply didnt it. This not about the shooting Laquan McDonald. This about the dash-cam recording. There was absolutely search know for the term, quote, dash, unquote, quote, camera, unquote, quote, recording any variance thereof.
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PAGE THE COURT: you get this response January 2016, and you see that doesnt have those search terms. there any subsequent follow-up request? MS. SVENSON: Yes. THE COURT: get there were some e-mails Ms. Ritter that say, hey, FOIA the Mayors office, not CPD. Was there any follow saying want dash, slash, camera, dash-camera request? Was there ever, ever second request? MS. SVENSON: Yes, via e-mail. Those were clients e-mails Ms. Ritter who specifically note those search terms werent used, and requested that they used. believe that those e-mails were attached one the -24 THE COURT: They are. Just give one second.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 MS. SVENSON: Sure. THE COURT: ahead. MS. SVENSON: Were alleging that the search was not adequate, there was affidavit containing facts that they conducted thorough search. did get the affidavit from Ms. Ritter. However, there were inaccuracies because never received the July 2016 response that she claimed that she had sent. They failed produce clear and convincing evidence that
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PAGE the information fell falls within the FOIA exemption. The information was redacted. Theres index, and theres indication with the redacted information which exemption applies what was redacted to. THE COURT: havent seen the redactions, and not going look 3,000 e-mails. telling you right now. question Judicial Watch this: The redactions that have seen other cases, when the redaction appears, actually identifies which section its being redacted under. other words, personal information, deliberative process, attorney/client privilege, whatever. those redactions have the section cites? MS. SVENSON: believe not. should have double checked that yesterday, but certainly correct
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 saying that. Maybe counsel knows the answer that. MR. SANTELL: Judge, dont believe totally honest with the Court THE COURT: dont want anyone lying. MR. SANTELL: cant say. Its been long since looked it, your Honor. dont recall. Sorry. MS. SVENSON: percent sure right about that.
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PAGE THE COURT: All right. MS. SVENSON: Again, dont believe had any explanation for the redactions. sit here today, feel they have not responded properly, that they are trying put the burden back us, that they have disregarded the law. The law clear that they have show they conducted exhaustive search pursuant our FOIA request, and they havent done so. THE COURT: When you say that they have not claimed the appropriate exemption, but yet you cant tell the redactions have that, mean, are you going objecting redaction when relates somebodys date birth Social Security number personal information?
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 MS. SVENSON: No. THE COURT: Okay. the redactions are claiming exemption that something specific, like deliberative process anything like that, that has specifically pled that the Court can make determination whether not in-camera inspection, which probably more likely happen, but youre not going objecting the exemption some redactions, then were just wasting our time.
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PAGE those need specifically pled. Any other argument? MS. SVENSON: No. THE COURT: Mr. Santell. MR. SANTELL: may follow up. THE COURT: Sure. MR. SANTELL: The city takes issue with the characterization that anything the city has done has made attempt mislead the Court. believe that, your Honor said earlier, weve been entirely front with the Court all times. And will take take issue with the characterization that anything weve done intended mislead. this case, your Honor, plaintiff takes issue with the fact that there was affidavit that was
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 attached the FOIA response. Your Honor, never include affidavits part FOIA response. THE COURT: But the statute says that the only person that can respond the FOIA officer. MR. SANTELL: Well, Judge, this case, individuals with the Department Law who are trained FOIA officers with the Illinois Attorneys Generals office responded this request. Therefore, FOIA officers working for the Department Law responded
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PAGE the request, given the fact that the Department Law represents all the agencies whose emails were produced with the request part the responsive documents. Now, whether not subsequent FOIA request was made, your Honor, dont believe that the attachment the exhibit the plaintiffs sur-reply establishes that subsequent FOIA request was made. THE COURT: what? cant hear you clearly when you read looking down. MR. SANTELL: sorry. dont believe that the attachments plaintiffs sur-reply establish that subsequent FOIA request was made. This lawsuit was filed January 20. April after the filing the lawsuit, there
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 communications between gentleman from Judicial Watch, Michael Bekesha and Amber Ritter and Christine Svenson, and specifically references the lawsuit. So, therefore, the lawsuit was already filed and was ongoing that point time regarding the response. Therefore, dont believe there was subsequent FOIA request made. THE COURT: But, Mr. Santell, again, give you know that this difficult because youre standing
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PAGE here having answer for people who made decisions that you may not have been part of. understand that. And so, dont mean any ill-feelings towards you personally, but, again, here make decision, all right. Somebody created the search terms, and those search terms traditionally with FOIA requests, people come together and its the requester and the public body that create what search terms are going used. Thats common practice, isnt it? MR. SANTELL: Absolutely. THE COURT: And so, understand that January 2016 December 2015 that the city was crisis situation that public relation issue that the Mayors office, the city Law Department, the Chicago
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 Police Department, everybody made decision that, you know what, were just going give everything. But now that were here court lawsuit, bound the statute. And question that other cases, its common that people get together, the requester and the public body, that come with the search terms. Thats what was done informally with these e-mails. Its not uncommon that that happens. doesnt require second FOIA request.
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PAGE MR. SANTELL: Thats true. That correct. However, again, your Honor has clearly said the record, this was situation that didnt necessarily afford the city time given the truncated given the five-day requirements set FOIA that necessarily didnt have the luxury time that with all the requesters. And, finally, detail factual basis for all the exemptions that were cited and relied upon sent out the letters that were provided January 7th and yesterday the plaintiff indicating what was that was redacted and the basis for it. Therefore, believe that have shown that correspondence the applicability all the exemptions. Thats all have. Thank you, your Honor.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 THE COURT: All right. This motion dismiss that has been filed the Office the Mayor. First off, want address whether not the Mayor himself, Rahn Emanuel, proper party the lawsuit. believe that the FOIA statute requires that its public body that can the subject FOIA request, and therefore any subsequent filings Circuit Court review the response that FOIA response would name the public body and the named official. the case
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PAGE People versus Stone, although believe that the city asking this Court consider dicta, that particular case, was lawsuit filed against the alderman. And that specific case, specifically states that the plaintiff there pursued the request the records the wrong person. Instead suing the defendant individually, she must pursue her remedy against the head the public body pursuant the act. The act defines head the public body the president, mayor, chairman, president, officer and on. Therefore, plaintiff must pursue her remedy the Circuit Court filing injunction, injunctive declaratory relief against the Mayor and against the city counsel.
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 MR. SANTELL: Yes your Honor. THE COURT: understand that under the old statute, but that specific part the statute hasnt changed. believe that the Mayor proper party. MR. SANTELL: may interject. The requirement that individual who was therefore whose FOIA request was denied appeal the head the public body has been thrown away the 2010 amendment, FOIA
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PAGE has fact changed. THE COURT: understand, but still think that the Mayor proper named party, will remain named party. This specific request was only the Mayors office. not know Judicial Watch issued FOIA request other individuals not other bodies. dont know. The only one thats front this time the one that was sent the Office the Mayor the city Chicago. three minutes before start this hearing, was still unclear whether not response from the Office the Mayor has been sent Judicial Watch. And, again, Ive said repeatedly through this hearing, completely understand, and its understandable and its reasonable how the city
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 collectively responded the multitude FOIA requests after the release the Laquan McDonald video Judge Valderrama. However, this stage, have look the statute. relates Count No. believe that the motion dismiss under 2615 and 2619 will denied. may proper motion for summary judgment now that that subsequent response has been filed, but this stage the proceedings, believe
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PAGE that they have stated claim that the Office the Mayor has not responded. Count No. the sufficiency the search terms, again, collectively that time, may have been appropriate they thought public relations-wise thats the way should have been responded. Again, the statute very clear that every single public body must have officer. this specific case, the responses come from Mr. Santell, even take the response that were talking about that was tendered yesterday. Specifically the Just give one second. Each the individual city departments are subsidiary bodies Chicago, and public bodies defined FOIA. And the Court citing Duncan Pub
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 versus the City Chicago 709 N.E. 1281, citing the Board Regents Regency University System versus Reynard, 292 Ill. App. 3d. Individual departments, which are city funded and city controlled are public bodies, and each individual subject the mandates FOIA. this specific case, the Court also looking the attorney generals public access counselor and their recommendation. There they
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PAGE specifically define the FOIA officer and specifically define public records and who required respond those public records. The response did not come from the office the Mayors FOIA officer. came from the corporation counsel, which does represent the Mayors office and the Mayor, but the FOIA statute very clear that must come from the FOIA officer. this specific case, there was multiple communications between the parties about the specific search term that was used. The Law Department through the corporation counsel representing the Office the Mayor and the Mayor did not alter change the requests the search terms, even though the plaintiff here, Judicial Watch, had specifically asked them that. very well may that the 3,000 pages e-mails that
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 have already been tendered will include additional Strike that. That was very unclear. very well may that the 3,000 e-mails that have already been tendered are all inclusive everything that relates the October 20, 2014 shooting. However, all know that theres more than one dash-cam involved the shooting that happened October 20th 2014 than just the one released Judge Valderrama. dont know the search was inclusive
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PAGE enough relates this specific request. And so, the defendants motion dismiss Count No. going denied. Usually FOIA requests were dealing with motions for summary judgment. Here are dealing with motion dismiss, which different, but think its one the same. think that the search insufficient just using the search terms Laquan McDonald, Van Dyke spelled two different ways and LM. going leave the parties decide how they wish define the search terms. not going that. You all decide how the search terms because dont know what youre looking for. However, plaintiff, you are going limited what your original request was. You cannot expand anymore from
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 todays date. the motion dismiss Count No. going denied. Count No. dont know what the new search going reveal. its going the same e-mails different e-mails. going not rule Count No. You may want amend your complaint based the new responses that you get. However, theres going new amended complaint that going allege that they havent sufficiently claimed
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PAGE nonexempt information, then needs specifically pled. other words, e-mail N0. 2055 claims exemption deliberative process, and dont think thats true, then that will least refine the search for in-camera inspection. And will willing the in-camera inspection that time the unredacted e-mails make that determination. Mr. Santell, you could please make sure -19 and cant imagine, unless the city doing differently than any other case every other case that Ive done with FOIA request and the city has redacted information, the redaction gives the specific section that being used for that specific redaction. that would sufficient. And the plaintiff,
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 hoping that youre not going objecting personal information, because will enormous task for through that, but youre getting the substance, and think thats what you want. going not rule Count No. this point based ruling Count No. and asking for new search done. MS. SVENSON: Your Honor, may ask question. With respect what you were saying about the plaintiff
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PAGE limited the original request, are you speaking about our request from our -mails? THE COURT: Your original FOIA request that was filed December 2015 specifically states, any and all records communications sent and from officials the Office the Mayor, including but not limited Mayor Rahm Emanuel, comma, regarding, comma, concerning relating police dash-camera recordings the October 20, 2014 shooting Laquan McDonald, including but not limited the release any video recordings the public. Your subsequent e-mails specifically address the search terms that were used and that did not include specific search terms. MS. SVENSON: question is, are relegated
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 just those search terms that had suggested use because probably have more that would like submit? THE COURT: No. But youre not going get anything more than what youve already asked for the original FOIA. MS. SVENSON: Right. Okay. Thank you. THE COURT: that clear? MS. SVENSON: That answers question.
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PAGE THE COURT: Youre not going get anything more than what your original request was. Youre limited. you want more than that, then you have file new FOIA. MS. SVENSON: Right. THE COURT: Have addressed everything? MS. SVENSON: believe so. MR. SANTELL: believe so, your Honor. THE COURT: Give one minute make sure have gone over notes and addressed everything. MS. SVENSON: Actually, have one more thing once youre ready. Are they going required submit affidavit showing? THE COURT: Theres requirement that they need
YVer1f
Judicial Watch Office Mayor
Hearing 09/23/2016 submit affidavit, but the response, its clear. should coming from the FOIA officer. there problem with that? MR. SANTELL: No. THE COURT: this stage now that were tendering, you know, almost year later. MR. SANTELL: No, your Honor. dont believe theres any sort exigency involved here. believe should able have the Mayors FOIA officer
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PAGE respond. THE COURT: Since were going doing new search this point, they can file new response from the Office the Mayor, from the Mayors FOIA officer with new search terms. Let make sure covered everything; think have. MS. SVENSON: Thank you, your Honor. MR. SANTELL: Thank you, your Honor. (Which were all the proceedings had the above-entitled cause.)
Judicial Watch Office Mayor
Hearing 09/23/2016 STATE ILLINOIS SS. COUNTY COOK Alexandra Szajna, being first duly sworn, oath says that she Certified Shorthand Reporter and Registered Professional Reporter doing business the City Chicago, County Cook and the State Illinois; That she reported shorthand the proceedings
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PAGE had the foregoing hearing; And that the foregoing true and correct transcript her shorthand notes taken aforesaid and contains all the proceedings had the said hearing. ________________________________
ALEXANDRA SZAJNA, CSR, RPR
CSR No. 084-004778 SUBSCRIBED AND SWORN
before this 3rd day October, A.D., 2016.
_______________________________ NOTARY PUBLIC
Judicial Watch Office Mayor
Hearing 09/23/2016
Index: (c)..calculated
act 33:17,18
(c) 19:18 19:8 38:3,6 39:5
3,000 7:7 19:12
-mails 39:11
27:15 36:24 37:3
actual 25:24
4:23 6:9 24:10
38:8
addition 14:11
20:5
additional 14:14
17:13 37:1 8:5
address 33:3 36:3
amended 2:16
39:21
3rd 5:18
addressed 3:24
23:17 40:15,19 6:3 10:23 35:5
39:6
1281 36:1
14th 4:8,10
1991 21:16
37:11 38:1 39:6 7:10 15:8 24:6
30:23 37:5 39:18
2010 22:3 34:9 20:10
affidavit 2:18,22
5ILCS140/2 20:16 6:10
30:2
7(1)(c) 19:18
709 36:1
7th 3:23 13:6
23:23 32:19
2015 31:22 39:13
2055 38:12
6:2 20:7 35:6
2619 5:1,2 35:6
2619.1 4:24
289 5:18
292 36:3 36:1
2nd 13:5
agencies 19:2
30:11
agency 7:20 12:6,
abbreviation 14:6
ability 22:9
above-entitled
41:20
absolutely 10:20
12:8 26:6 31:20
access 20:13 36:8
accurate 24:18
26:3
acknowledges
6:8
ahead 4:20 19:8
21:20 25:17,23
27:2 28:8
23:23 26:11 27:7
31:22
2615 4:24 5:2,8,9
afford 32:13
37:5,8 39:18
20th 16:13 37:8
3:3 13:20 14:1
17:17 18:6 24:23
27:4,6 29:24 40:23
41:1
affidavits 25:21
2014 8:7 15:8 24:6
2016 2:22 6:10
admission 6:23
advisory 20:18 13:16 35:12
20:18
140/11 20:10
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PAGE
administrative 30:24 6:9
adequate 27:4
answers 40:9
back 11:17 28:15
anymore 37:24
based 5:10 13:2
apologize 15:1
App 5:18 36:3
began 6:22
appears 27:18
begin 2:20
appellate 5:19
behalf 2:8
21:15
applicability
32:23
applies 27:13
Board 36:2
April 30:24
boards 20:21
argue 2:11 11:4
bodies 9:11 12:13
15:11 22:24
arguing 6:13
14:18
argument 21:13
23:8,10,17 29:11
asserted 13:13
assistant 25:14
19:5 20:18,23
34:16 35:23 36:5
body 12:7,12
18:14 20:14,16,17
21:4 22:1,4,5,6,14,
21,24 25:9 31:17
32:6 33:6,9,17,18
34:8 35:17
boots 9:21
bound 32:3
bring 21:3,22 22:9
attachment 30:15
bringing 17:12
attachments
broad 22:15
30:21
alleging 11:13
attention 3:13
amend 38:6
big 24:21
birth 28:23
attempting 15:11 31:2
Bekesha 31:2
applicable 14:8
alleges 6:3 19:10
Amber 3:12 13:20,
19:1,20
appeal 22:4 34:8
attempt 29:18
alter 36:21
basically 15:19
basis 32:17,21
alleged 6:1
13:19 27:3
38:7 39:6
apparent 5:10 14:1,22 24:23
25:21 26:23 30:1
19:15 38:9
34:9 22:1,19 33:13
allege 5:13,20
aware 20:3
amendment 22:3
attached 6:6,11,
13:4,8
22:23,24
amending 5:24
alderman 21:23,
allegations 5:4,15
authority 20:9
attorney 36:8
broader 17:20
brought 3:1 22:11
burden 26:2,4
28:15
bureaus 20:22
attorney/client
27:20
Attorneys 30:7
calculated 17:19
Judicial Watch Office Mayor
Hearing 09/23/2016
camera 15:12,15
16:8 26:8,17
capacity 21:9
care 3:21
case 5:17,19,24
6:14 8:23 11:12
14:16 17:22 19:12
22:20 29:23 30:5
33:9,12,13 35:18
36:7,17 38:20
cases 8:16 27:17
32:4
cetera 20:24
chairman 33:19
change 4:15 26:1
36:21
changed 34:4,10
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PAGE
chaos 11:24 12:1
characterization
29:17,21
checked 27:24
Chicago 2:4 4:1,5
6:16 10:18 11:14, 13:7 19:1 24:1
31:24 34:19 35:23
36:1
Chloe 18:18,21
Christine 2:7 31:2
Circuit 33:7,22
cited 19:14 32:18
cites 21:14 27:22
cities 20:20
citing 35:24 36:1
city 2:4 5:5,17 6:10
7:8,9,20 8:1,3,12, 9:6 10:1,12
12:2,7,24 13:9
14:1,3,15,18 17:7
18:2 19:1,6,22
22:12,13,19,20
23:7,9,11,19
29:16,17 31:22,24
32:13 33:10,24
34:19,24 35:22
36:1,4 38:19,21
Index: camera..department
citys 8:4 12:9
conduct 23:9,15
claim 5:7 35:10
conducted 26:3
claimed 27:8
28:19 38:9
27:5 28:16
conjecture 5:14
claiming 29:3
conserve 8:10
claims 5:22,23
constraints 10:11
38:12
clarified 3:15
clean 15:2
clear 4:17 5:5 6:7
7:14,18 10:17,22
11:19 13:23 14:21
22:22 24:8 27:9
28:16 35:16 36:16
40:8 41:1
cleared 13:11
clearer 3:10
clerical 6:15 13:10
clients 26:20
collectively 9:8
35:1,13
colleges 20:19
contained 19:21
contention 5:1
controlled 36:4
convincing 27:9
copy 4:12 20:13
21:17
corporation 2:3
25:14 36:14,20
corporations
20:21
correct 2:15 4:7
18:10,20,22 19:7, 20:8 21:8,15,
19,23 22:2 23:3,19
24:12,19 25:1,2,4,
7,9,13,17,23
26:10,14,24 27:2, 28:3,4,10,19
29:2,5,13,15,18,20
30:3,18 31:8,21
32:3 33:1,7,11,22
34:2,11 35:24 36:7
39:12 40:4,8,10,
15,18,24 41:5,11
courtroom 10:10
11:6 22:8
commissions
20:22
committees
20:22
common 31:19
32:5
communication
24:3
communications
9:4 11:16 15:4
17:8 31:1 36:18
39:14
complaint 2:17
4:23 5:2,5,10 6:5,
8,9 24:10 38:6,8
complete 24:18
25:22
completely 34:23
conclusions
5:13,14
counsels 23:17
counselor 36:9
count 6:3 10:23
13:16,18 19:8
35:5,12 37:11
38:1,3,6 39:5,6
counties 20:19
couple 15:14
court 2:1,6,10,16
3:7,10 4:4,8,13,15,
17,20 6:12,18,21
7:18 8:1 9:8,10,16
10:9,16,21 11:3,5, 12:15 13:1,16, 14:24 15:2,24
16:12,17,24 17:17
decision 11:7
17:21,23 31:13
32:1
decisions 31:10
declaratory
20:12,14 21:3
33:23
covering 8:6
defendant 2:4
CPD 7:9,12 8:21
11:13,18 13:15
16:8 24:4 26:16
created 31:15
Cummings 5:17
counsel 2:1,4,11
3:4,17 4:11,20
6:18 14:24 20:3
21:14 22:12,13,19, 23:3 25:14,16, 28:1 33:24
36:14,20
decided 21:16
defects 5:10
crisis 31:23
comma 39:16
decide 37:19,21
covered 41:15
correspondence
cost 10:14
31:22 39:13
defeat 5:7 9:10
create 31:18
combines 4:24
December 13:5
cover 4:4 8:15 9:4
9:17 20:4 21:10
25:12,15 27:24
32:10
32:22
dealt 15:22
dash 15:12,15
16:8 26:7,16
dash-cam 16:12
26:6 37:7
dash-camera
14:19 15:7 16:1,3
24:6 26:17 39:17
dash-cams 16:22
17:6
date 3:5 28:23
38:1
dated 3:5,21 4:8, 6:10
deal 8:23 17:8
dealing 22:18
37:13,14
deals 5:9 21:18,21
22:19
5:21 21:6 23:1
33:16
defendants 2:14,
17,18,21 4:22 5:1
6:8 23:6 37:11
defense 5:23
19:23
define 36:10,11
37:20
defined 20:16
35:24
defines 33:18
definition 20:15
21:2 22:21
definitively 18:5
deliberative
27:20 29:4 38:13
demand 9:1
demanding 8:1
denial 20:11 22:6
denied 20:12 22:4
34:8 35:7 37:12
38:2
department 4:1,5
6:16 7:8,13,20,22
8:2,22 9:20,22
10:3,18,19 11:14, 12:6 13:7 14:15
17:7 19:1,4 24:1
30:6,9,10 31:24
Judicial Watch Office Mayor
Hearing 09/23/2016
executive 20:18
32:1 36:19
departments
10:1 12:2 35:22
36:3
detail 32:17
determination
29:6 38:17
dicta 33:11
difference 25:10
differently 38:20
difficult 11:5
18:12 31:9
Index: departments..Honor
e-mail 7:10,16
11:10 15:20 26:19
38:12
e-mails 11:21
13:12 16:8,24
17:2,3,4,13,14
19:12 26:14,20,22
27:15 32:7 36:24
37:3 38:5,17 39:21
earlier 29:19
fell 27:10
exemption 27:10,
file 20:14 40:12 28:20 29:3,8
38:13
exemptions 4:1
13:13 19:14,19
32:18,23
exhaustive 28:17
exhibit 14:22
30:15
exigency 8:23
41:12
filed 14:17 30:23
31:4 33:2,12 35:9
39:13
generals 30:7
finally 32:17
find 3:17,19
Fire 11:14
direct 14:14
effective 10:14
expansive 17:11
five-day 32:14
directed 24:1
emails 30:11
expeditious
FOIA 2:23 4:18 5:6
discussed 3:8,11
Emanuel 15:6
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PAGE
5:16 6:2 23:6 33:1
35:6 37:11,15 38:1
20:5 21:8,12 33:4
39:16
Emanuels 15:20
dismissed 20:6
Emergency 11:15
dismissive 7:3
enable 6:1
11:2
disregarded 5:16
28:15
distinction 7:4
11:9
distinguishable
22:16,20
District 5:19 21:15
districts 20:21
document 25:6
documentation
9:21 10:7
documents 6:6
7:7 9:24 12:16,18, 13:11 14:10
16:5 18:22 30:12
double 27:23
Duncan 35:24
Dyke 14:5 16:6,18
17:15 37:18
explained 13:20,
explanation
28:12
extent 14:13
enormous 39:2
ensure 3:18,20
entities 19:6
face 5:4,11 6:5
entitled 7:11 13:6
fact 5:11,15 6:15
entity 12:7,11
error 6:16 11:19
13:10
essentially 5:21
7:3 8:15 9:9 10:2
12:20 13:14 14:2
22:5,8
establish 30:22
establishes 30:16
9:5,6 12:23 21:2
22:14,16 29:24
30:10 34:10
facts 5:13,21 6:1
22:18 23:7,9,11
27:4
factual 5:4,14
32:17
failed 23:7,9,11,
gave 12:20
filings 6:11 33:7
expand 37:24
dismiss 2:14 4:23
gather 15:16 16:5
general 14:21
easier 2:13
10:14
Garry 24:5
filing 30:24 33:22
findings 6:6
41:8
6:4 7:1,5 8:11,12, 9:11,14,16,18,
19,23 10:2,13,15
12:5 13:4 14:13,
15,17 18:15,16
19:19 22:2,17,21
23:2,22,24 24:9,16
25:20 26:15 27:10
28:17 30:1,2,4,7,8,
13,16,22 31:7,16
32:9,14 33:5,6,8
34:7,9,15 35:1,24
36:6,10,13,15,16
37:13 38:21 39:12
40:6,13 41:2,9,13
36:8
generalized
15:15,17,21
generally 5:8,20
generically 8:3
gentleman 31:1
give 9:20 18:7
19:22 26:24 31:8
32:2 35:20 40:18
glad 3:1
gleaned 17:18
Good 2:1,2,6,7
great 18:2
group 9:2
guess 17:12
follow 26:16 29:14
handled 3:9 19:3
follow-up 26:12
happen 29:7
forced 10:3
happened 18:24
foregoing 20:23
Forget 24:19
form 5:23 19:23
37:7
head 22:5,6,13,19
33:17,18 34:8
hear 30:18
15,16 27:9
found 20:10,16,17
everyones 8:11
fails 5:2 23:6
front 18:11 29:19
evidence 27:9
failure 19:8
exact 16:16 17:18
falls 27:10
fulfill 10:4,5
hey 26:15
excessively 5:3
false 23:13 24:7
fulfills 14:13
hindsight 10:9
excluded 8:22
fashioned 13:14
fully 12:13
Hold 21:19
feel 28:13
funded 36:4
honest 28:3
17:3
excluding 16:21
17:2,23
feels 13:9
34:17
heard 2:12
hearing 34:20,23
Honor 2:2,7,15
3:2,6 4:7,22 6:14, 9:17 10:5 11:1
Judicial Watch Office Mayor
Hearing 09/23/2016
12:9 13:3 15:13
16:2 17:5 18:24
20:2,5 21:1,17
23:4 25:15 28:6
29:19,23 30:1,14
32:11,24 34:1 39:8
40:17 41:7,17,18
hoping 39:1
hundreds 17:6
index 20:1 27:11
identifies 24:13
27:18
legal 5:9,14
indication 19:16
item 10:1
legislative 20:17
items 16:7
letter 4:4 7:14
27:12
indifference 7:4
9:11 12:6,7,11
21:5 22:1 23:1
34:7 35:22 36:3,5
33:16
individuals 30:6
34:16
information 8:17,
ELECTRONICALLY FILED
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2016-CH-00462
PAGE
imagine 17:5
38:19
important 5:11
23:18
in-camera 29:6
38:15,16
inaccuracies
27:7
individual 8:18
ILCS 20:10
Illinois 5:11 30:7
14:11 23:23 25:13
11:9
informally 32:7
ill-feelings 31:12 14:3,9 16:4
19:9 23:12,17
27:10,11,12,20
28:24 38:10,22
39:2
injunction 33:22
injunctive 20:11,
January 3:23 6:10
13:6 23:23 26:10
30:23 31:21 32:19
Judge 7:2 8:4
19:21 28:2 30:5
35:3 37:8
judgment 35:8
Judicial 2:8 11:12
17:23 20:2 27:16
31:1 34:15,22
36:23
July 4:8,10 27:7
June 2:22
instance 8:5,19
15:13 26:1
inbox 7:15
insufficient 13:19
inboxes 7:10 9:3
14:4
include 30:2 37:1
39:23
including 7:7
15:5,8 24:4 39:15,
inclusive 37:4,9
incomplete
19:11,20
incorporated
20:20
incorrect 20:4
37:17
intended 29:22
kind 8:23 9:1 10:3
12:3,4
lack 9:2
language 21:2
22:10
interject 34:6
involving 10:1
irrelevant 16:10
issue 10:11 19:16, 21:23 24:20,21 14:6 16:7,20
long 28:5
looked 3:16 28:6
lost 13:22
lot 8:17 12:21
16:10 18:17 20:5
21:5,12,13 22:12, 23:1,14,15,16,
20,21 24:14,16,20
25:11,20 33:2,3,
19,23 34:4,12,18, 35:11 36:15,21
39:15,16 41:13
Mayors 3:24
6:17,24 7:8,12,15,
16,18 8:20 10:17,
22,24 11:10 12:18
13:15 15:19 16:9
26:15 31:24 34:14
36:13,15 41:9,13
Mccarthy 24:5
Mcdonald 8:7
14:7 15:8,23 16:20
17:9,15 24:7 26:5
35:2 37:18 39:18
means 20:17
mention 2:22
luxury 32:15
mentioned 3:16
mere 5:13
met 5:5 22:9
Michael 31:2
made 11:7 12:23
minute 25:7 40:18
17:21 29:18 30:14,
17,23 31:7,10 32:1
minutes 34:19
maintaining 7:21
mislead 23:19
maintains 7:22
15:8,23 16:7,19
17:9,14 24:7 26:5
35:2 37:17 39:18
16:22 17:22 18:1,4
19:2,5,6 23:20
37:7 41:8
lists 21:4
key 15:20 22:7
Laquan 8:7 14:5,7
involved 12:14
listed 6:16 11:20
interest 12:21
inundated 12:2 16:18,19,20 24:4
37:23 39:10,15,19
40:11
inspect 20:13
38:15,16
limited 9:5,6 15:5,
mayor 4:6 15:5,6,
lying 28:4
jurisdiction 5:12 21:4,22 33:22
inspection 29:7
letters 18:4 32:19
17:15 37:18
37:14
9:23 11:12 12:12
16:6,13 17:10
21:18,21
inadequate 14:19
leave 37:19
issued 34:15
identifying 11:22
Ill 5:18 36:3
29:16,21,24 31:23
indicating 32:20
individually
identical 13:12,13
Index: hoping..municipal
9:22
make 8:2 11:17
29:5 31:13 38:17, 40:18 41:15
making 17:22
Management
11:15
29:18,22
misread 26:2
mistaken 13:8
morning 2:1,2,6,7
motion 2:14,17
4:23 5:16 6:2 23:6
33:1 35:6,7 37:11, 38:1
large 19:4
managing 10:12
motions 37:14
law 7:8,12 8:21
mandates 36:5
move 13:16
material 8:6 14:14
multiple 10:15
10:16,18 19:1,4
26:2 28:15,16
30:6,9,10 31:24
36:19
lawsuit 14:17 22:2
30:23,24 31:3,4
32:3 33:4,12
15:22
36:17
materials 15:16
multitude 35:1
matter 2:5 3:8,11,
municipal 20:21 21:6,15 22:10
Judicial Watch Office Mayor
Hearing 09/23/2016
41:2,9,13
Index: N.E...Regents
Phillip 2:3
officers 17:1
phonetic 21:16
N.E. 36:1
officers 30:7,9
phrase 12:10 22:7 38:12
official 21:9 33:9
pick 14:9
named 33:9 34:12,
officials 15:4 24:3
places 8:15
39:14
necessarily 18:7
32:12,14
needed 10:7
nonexempt 19:9
23:11,16 38:10
nonresponsive
6:14
older 22:17
ongoing 31:5
open-ended
17:11
opinion 21:14
22:14
opposed 3:24
note 5:11 23:18
24:11 26:20
notes 40:19
notice 5:22
ELECTRONICALLY FILED
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2016-CH-00462
PAGE
plaintiff 2:8,24
number 16:16
18:2 19:4 28:23
numerous 8:8
13:15
opposition 21:7
order 8:10 10:4
18:3
objecting 28:22
29:8 39:1
obligation 5:6
occurred 18:1
October 8:7 15:8
16:13 24:6 37:5,8
39:18
office 3:24 4:5
6:17,24 7:8,12,15, 8:20 10:17,23, 11:15 12:18
13:15 15:5 16:9
18:16 21:11 23:13,
14,16,20,21 24:13,
16,20 25:10,20
26:15 30:8 31:24
33:2 34:15,18,21
35:10 36:13,15,20
39:15 41:13
officer 16:18
18:15,16 24:16
25:20 30:4 33:19
35:17 36:10,13,16
plaintiffs 2:17,19
4:23 5:2,7 22:15
30:15,22
plaintiffs 5:24
12:23
plead 23:7
original 37:24
39:10,12 40:6,11
outset 23:5
5:12,20 6:3,8,13
7:6 8:21 12:22
13:18 14:16 15:11
19:10,15 23:6,8,10
29:23 32:20 33:14, 36:22 37:23
38:24 39:9
pages 36:24
paperwork 2:13
Paragraph 6:9
part 30:2,12 31:11
34:3
parties 36:18
37:19
party 21:14 33:4
34:5,12,13
people 11:7 31:10, 32:5 33:10
pleading 5:12
pleadings 5:24
13:2
pled 23:8,10,13
29:5,10 38:11
10:18 11:20 13:7
15:7,24 16:3 17:7
24:1,6 32:1 39:17
position 8:4 11:5,
personally 20:6
31:13
19:13 30:11
production 14:12
19:11,20
proper 21:14 33:4
34:4,12 35:7
properly 25:19
28:14
provide 8:16 10:6
24:17
provided 8:17,21
32:19
public 9:11 10:11
12:7 15:10 20:11,
13,16,17 21:4
22:1,4,5,6,14,21, 31:17,23 32:6
33:6,9,17,18 34:8
35:14,17,23 36:4,
8,11,12 39:20
20:7 28:17 33:17
pursue 33:16,21
pursued 33:14
put 9:18 23:21
28:14
possession 3:2
practice 31:19
prerequisite 22:8
privilege 27:21
problem 41:3
problems 15:14
Rahm 15:6,20
20:5 39:16
Rahn 21:8,12 33:4
Rasmas 18:19,21
reached 3:17
read 2:16 22:22
25:7 30:19
ready 40:21
reason 7:5 11:8
reasonable 34:24
recall 28:6
receive 6:4 22:6,7
Pub 35:24 12:9,19 21:10
prior 22:9
27:19 28:23 39:1
produced 4:2
pursuant 4:23
period 8:12 17:10
personal 7:16
19:9 23:11,16 27:9
21:7 23:5 31:5
39:6 41:12
president 33:19
22:11 30:4 33:15
produce 3:4 17:19
purpose 9:11
police 4:1,5 6:16
27:20 29:4 38:13
point 12:3 16:17
percent 28:8
person 20:12
process 18:5
question 2:19
6:21 11:6 27:16
32:4 39:8,24 40:9
questions 18:12,
Quincy 21:15
quote 7:19 14:12
15:3 24:2 26:7,8
received 6:10
11:16,18 13:5 14:2
18:2 24:12 27:7
recommendation
36:9
record 13:22 15:2
22:23 32:12
recording 14:19
15:7,12,15 16:9,13
24:6 26:6,8
recordings 15:10
39:17,19
records 4:2 7:21, 14:23 15:4
17:20 20:11,13
24:3 33:15 36:11, 39:14
redacted 27:11,
12,13,19 32:21
38:21
redaction 27:18
28:22 38:22,23
redactions 19:11, 27:14,17,21
28:12,21 29:2,9
references 31:3
refine 38:14
proceeding 17:5
Regency 36:2
proceedings
Regents 36:2
16:11 35:9 41:19
Judicial Watch Office Mayor
Hearing 09/23/2016
related 9:21 15:23
17:4
relates 28:22 35:5
37:5,10
relating 15:7 24:5
25:24 39:17
relation 31:23
relations 10:11
relations-wise
35:15
release 15:9,22
35:2 39:19
released 16:3,4
37:8
relegated 39:24
relevance 17:14
relevant 14:9
ELECTRONICALLY FILED
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2016-CH-00462
PAGE
17:14,16,20
relied 32:18
relief 20:12,14
21:4 33:23
remain 34:12
remedy 33:16,21
remember 16:16
renewed 14:15
repeat 13:23
repeatedly 34:22
25:1,5 26:12,17,18
28:17 30:8,10,12,
14,16,23 31:7 32:9
33:6,14 34:8,14,16
37:10,24 38:21
39:10,11,12 40:11
requested 12:22
26:21
requester 8:2
31:17 32:5
requesters 26:2
requesters 8:8
17:22,24 18:8
32:16
represents 19:1
30:11
request 2:23 4:18
6:5 8:2,11 9:14,18,
19,23 10:4 11:11,
13,14,15,16,18
12:12,22 13:4
14:13,15,17,21,23
15:3,16,18,21 18:9
19:24 20:11 23:22, 24:2,9,14,23
responsive 13:11
14:11 15:16 16:5
25:19 30:12
restricted 12:5
reveal 38:4
Revenue 9:20
review 33:8
Reynard 36:3
Ritters 13:20,24
rule 38:5 39:5
ruling 5:16 39:6
run 8:18
required 8:12,24
18:13 36:11 40:22
requirement 34:6
40:24
requirements
32:14
requires 33:5
resources 8:10
9:6
respond 8:3
36:20
responsible 7:20
23:23 26:15,20
27:6 31:2
require 32:9
10:13,14,23,24
13:9 23:7,14,21
30:4 36:11 41:10
responded 24:21
28:14 30:8,9 35:1,
11,16
Santell 2:2,3,15
3:6,8,11 4:7,9,21
6:20 7:2,24 8:4
9:9,12,17 10:20
11:1,4,8 12:8,18
13:3,18,24 15:1,3
16:2,15,23 17:3,24
18:18,21,24 19:8
20:2,9 21:10,21
25:14,15 28:2,5
29:13,14,16 30:5, 31:8,20 32:10
34:1,6 35:18 38:18
40:17 41:4,7,18
satisfy 24:14
school 20:20
responding 23:24
search 7:9 8:14,15
response 2:17,23
9:3 13:17,19 14:4, 15:13,17,19
16:8,18,19,20
23:10,15 24:17
25:22,24 26:1,3,7,
11,21 27:3,5 28:17
31:15,16,18 32:6
35:13 36:19,22
37:9,16,17,20,21
3:4,14,15 4:18 6:4,
10,11,24 7:2,6
8:24 10:22 11:11
12:15 13:6,10,14
24:13 25:4,5 26:10
27:8 30:1,2 31:6
33:8 34:21 35:8,19
38:3,14 39:7,22,23
40:1 41:12,14
searched 7:10,16
38:7 9:5,24 10:2,6,
13,15 11:17 12:1, 13:21 14:2
15:18 17:19 18:2
19:4 31:16 35:1
36:21 37:13
reply 2:18,21 3:16,
representing 2:4
responses 35:18
Ritter 3:12 11:22
respect 39:9
represent 36:14
36:12 41:1,12
requests 7:21 8:6,
replaced 4:5 14:1
Index: related..Stone
8:19 11:11 14:4,20
15:18 17:10,15
searches 8:18
seated 2:10
section 4:24 5:8,9
20:7,15 22:22
27:18,22 38:23
Security 28:23
seeking 14:14
24:8,9
send 4:11
separate 7:20
set 15:17 17:20
22:15,18 32:14
sort 41:8
sought 24:2
speak 18:8 19:22
speaking 5:20
39:10
special 8:5
specific 5:3,13,15, 6:1,24 8:2
15:20 16:6 18:14
29:3 33:13 34:3,14
35:18 36:7,17,18
37:10 38:22,23
39:23
specifically 6:3
10:17 11:22 21:4
24:10 26:20 29:5, 31:3 33:13
35:20 36:10,23
38:10 39:13,21
settled 12:4
specifics 19:15
shooting 8:7 15:8,
spelled 37:18 16:14 24:7 26:5
37:6,7 39:18
spelling 14:6
show 26:3 28:16
spellings 16:7
showing 23:7,9,
spread 2:13 25:21 40:23
shown 32:22
staff 7:17 11:10
15:19
signed 25:13
stage 35:4,9 41:5
simple 6:15
stand 2:12
simply 6:7,15 8:19
standing 11:5
11:19 19:10,21
21:11 23:21 26:4
sincerely 18:11
single 17:1 18:14
35:17
sit 28:13
situation 9:13
31:23 32:12
skipped 15:24
slash 26:17
slow 14:24
Social 28:23
18:11 31:9
start 34:20
Starting 5:8
state 19:20 20:19,
stated 35:10
states 14:12 23:6, 24:2 33:14
39:13
statute 12:5
18:13,14 30:3 32:4
33:5 34:3 35:5,16
36:15
solution 9:7
stick 24:19
somebodys
Stone 21:16 33:10
28:22
Judicial Watch Office Mayor
Hearing 09/23/2016
Strike 37:2
subject 33:6 36:5
submit 14:16
40:3,22 41:1
submitted 7:22
13:4
12,18,24 26:13,19
27:1,3,23 28:8,11
29:1,12 31:2 39:8, 40:7,9,14,16,20
41:17
switch 20:15
System 36:2
subsequent 2:23
3:14 6:6 11:21
14:17 26:12 30:13,
16,22 31:7 33:7
35:8 39:21
subsequently
13:5,11
subsidiary 20:23
35:23
substance 7:14
39:3
ELECTRONICALLY FILED
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2016-CH-00462
PAGE
sue 20:10 22:23
Index: Strike..yesterdays
top 11:20
totally 11:24 28:3
towns 20:20
vague 5:3
townships 20:20
Valderrama 35:3
traditionally
31:16
table 2:11,13
takes 29:16,23
talking 10:10
35:19
task 39:2
transparency
12:21
10:20 12:9 13:3
32:10 38:14
truncated 8:11
32:13
suggested 40:1
suing 33:15
suit 20:6,14 21:3,
8,22 22:9,11
summary 35:7
37:14
superintendant
24:4
supervisor 3:9,12
support 21:13
supported 6:7
supporting 2:18,
sur-reply 2:19
14:22 30:16,22
victim 16:19
typical 9:18,19
video 15:9 16:13
35:20 37:1,4
26:7 36:19
terms 8:14 9:3
13:17 14:4,5,8,13,
19,20 15:12,15,17
16:5 17:11,16,17
18:3,9 26:12,21
31:15,16,18 32:6
35:13 36:22 37:17,
20,21 39:22,23
40:1 41:14
thereof 26:9
thing 3:23 40:20
things 8:9 12:3
16:10
thought 35:14
thrown 34:9
time 8:12 9:6
10:11,12 11:23
12:3 17:10 18:18
29:9 31:5 32:13,15
34:18 35:13 38:16
times 29:20
survive 6:2
today 2:14 4:12,
4:14,16,19 23:4
24:15,22 25:3,8,
36:1,2
tendered 25:6
surprised 3:3
Svenson 2:7,8 3:1
versus 5:17 33:10
victims 17:1
term 9:2 20:16
sufficiently 38:9
version 22:17
turned 12:17
sufficiency 5:9 38:24
variance 26:8
vehicles 17:6
true 3:15 7:24
tendering 41:5
sufficient 23:10,
17:15 37:18
telling 27:15
sued 21:24
13:17 35:12
37:9
Van 14:5 16:6,18
trained 30:6
32:20 35:20
15,22 6:22 28:13
todays 38:1
35:2 39:19
view 25:2
villages 20:20
unclear 6:23 7:1
34:20 37:2
uncommon 32:8
understand 10:9
11:3,23,24 18:10
31:11,21 34:2,11,
understandable
34:24
understanding
19:3
unimportant 7:13
universally 14:8
universities
20:19
wasting 29:9
Watch 2:9 11:12
17:23 20:2 27:16
31:1 34:15,22
36:23
Waterloo 5:18
ways 37:18
website 7:19
wide 7:9
words 4:4 12:15, 15:21,24 17:18
27:19 38:12
University 36:2
working 30:9
unofficial 21:9
works 22:17
unquote 26:7,8
wrong 33:15
unredacted 38:17
unsupported
5:15
unusual 8:13
usual 9:13,14,16
year 41:6
yesterday 3:4,21
4:12,19 7:1 10:21
25:2,16 27:24
yesterdays 3:5
24:12
ELECTRONICALLY FILED
1/9/2017 4:00
2016-CH-00462
CALENDAR:
PAGE
CIRCUIT COURT
COOK COUNTY, ILLINOIS
CHANCERY DIVISION
CLERK DOROTHY BROWN THE CIRCUIT COURT COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, CHANCERY DIVISION
JUDICIAL WATCH, INC.,
Plaintiff,
vs.
THE OFFICE THE MAYOR THE CITY CHICAGO
and
RAHM EMANUEL, his
official capacity Mayor the
city Chicago
Defendant.
____________________________________)
Case No.: 00462
Honorable Judge Demacopoulos
NOTICE PETITION FOR RULE SHOW CAUSE
To:
Amber Ritter (via email amber.ritter@cityofchicago.org)
Philip Santell (via email Philip.santell@cityofchicago.org)
Assistant Corporation Counsel
City Chicago Department Law LaSalle Street
Suite 1720
Chicago 60602
PLEASE TAKE NOTICE that January _____, 2017, 9:30 am, soon counsel
may heard, shall appear before the Honorable Judge Demacopoulos any judge sitting
her stead, the courtroom usually occupied her Courtroom 2008 the Circuit Court
Cook County, Municipal Division, Daley Center, Chicago IL, and present the attached Petition
for Rule Show Cause.
____/s/ Christine Svenson________
CERTIFICATE SERVICE
The undersigned hereby certifies under penalties perjury provided law pursuant 735
ILCS 5/1-109, that the above notice and attached pleading(s) were EMAILED the addresses
listed above before 5:00 January 2017.
____/s/ Christine Svenson_________ Christine Svenson
ELECTRONICALLY FILED
1/9/2017 4:00
2016-CH-00462
PAGE
Svenson Law Offices
505 LaSalle Street
Suite 350
Chicago 60654 312.467.2900 312.467.2902
Attorney code no. 44565
Chancery DIVISION
Litigant List
Printed 01/09/2017
Case Number: 2016-CH-00462
Plaintiffs
Plaintiffs Name
Plaintiffs Address
State Zip
JUDICIAL WATCH, INC.
Unit
0000
Total Plaintiffs:
Defendants
Defendant Name
Defendant Address
State
Unit
THE OFFICE THE
MAYOR
0000
EMANUEL RAHM
Service
0000
Total Defendants: