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Judicial Watch • JW vs Office of Mayor Hearing Nov 15, 2017 Condensed

JW vs Office of Mayor Hearing Nov 15, 2017 Condensed

JW vs Office of Mayor Hearing Nov 15, 2017 Condensed

Page 1: JW vs Office of Mayor Hearing Nov 15, 2017 Condensed

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Number of Pages:12

Date Created:November 16, 2017

Date Uploaded to the Library:November 16, 2017

Tags:Condensed, McCorkle, Burger, Mayor Rahm Emanuel, Ritter, SVENSON, Laquan, Litigation, honor, Nov, terms, MCDONALD, mayor, hearing, 2017, search, Emails, Services, illinois, chicago, FOIA, office


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STATE ILLINOIS (Whereupon, the following SS: proceedings were held open COUNTY COOK court.) THE CIRCUIT COURT COOK COUNTY, ILLINOIS THE COURT: Good morning. COUNTY DEPARTMENT CHANCERY DIVISION MS. SVENSON: Good morning. MS. RITTER: Good morning, Judge. Amber Ritter JUDICIAL WATCH, INC., behalf the City. Plaintiff, MR. PHILLIP: Phillip Santell, S-A-N-T-E-L-L, vs. No. 00462 corporation counsel behalf the defendants. THE OFFICE THE MAYOR MS. SVENSON: Christine Svenson behalf THE CITY CHICAGO the plaintiff. and THE COURT: All right. continued this RAHM EMANUEL, his from last week couple issues. official capacity MS. RITTER: Right. Mayor the City THE COURT: ahead, Miss Ritter. Chicago, MS. RITTER: last time were here week Defendant. ago, your Honor, few things had come back REPORT PROCEEDINGS the hearing and explain the court. And the first one the above-entitled cause before the going give the court and Miss Svenson Honorable ANNA HELEN DEMACOPOULOS, Judge said packet materials that you asked Court, November 15, 2017, the hour through. will through that together. 9:30 a.m. The first page this packet and the Reported by: Patricia Wangler, CSR second page the your Honor had asked License No.: 084-002417 verify with our tech people show the court when APPEARANCES: this search for the mayoral custodian was first SVENSON LAW OFFICES, done, when we, you know, expressed plaintiff MS. CHRISTINE SVENSON that was going very voluminous search. 505 North LaSalle Street, Suite 350 the first entry should say this Chicago, Illinois 60654 the log that the tech department maintains show (312) 467-2900 searches that they conduct you know, christine@svensonlawoffices.com emails. this printout, screenshot, Representing the Plaintiff, printout from their log that they, you know, maintain the normal course business. CITY CHICAGO DEPARTMENT LAW, the first entry, you see says date MS. AMBER ACHILLES RITTER received, February 28th 2017. And that reflects MR. PHILLIP SANTELL the custodians that are talking about you North LaSalle Street, Suite 1720 can see the custodian column. Chicago, Illinois 60602 And then where says number items, (312) 744-0741 says 399,000, that little bit larger than the amber.ritter@cityofchicago.org number expressed which was approximately 100,000 phillip.santell@cityofchicago.org because that includes thats hits opposed Representing the Defendant. emails from what told. So, other words, still huge number, but probably translates about 100,000 emails and 400,000 items. THE COURT: lets back before any further and get into any greater detail. this response plaintiffs petition for rule
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
1..4
YVer1f show cause relates when you actually Van Dyke and then Vandyke spelled without space. began making the request the department that what the folks gave me. the new search terms? And you can see, says results file produced. MS. RITTER: Correct. They gave the emails March 3rd. THE COURT: But werent the new search terms THE COURT: Okay. So, Miss Svenson, have you when were the new search terms agreed upon? seen this printout? MS. RITTER: Well, dont know that they have MS. SVENSON: have not until this morning. ever been agreed upon, but was then, THE COURT: would you like opportunity February lets pull those emails again that look that and have Miss Ritter over with discussed last week. And think counsel you explain what contained there before pulling them up. forward here? was recall from our conversation MS. SVENSON: That would helpful. here last week that exact time. was February THE COURT: think that would helpful. 2017. this was result that request run MS. RITTER: Sure. this search. THE COURT: just going take short afraid may not have those emails recess with you folks. going ask the with today, but think counsel looks like court reporter stay. going handle some counsel does where and, course, the search other cases and then call you folks back up. terms that are talking about here are the ones MS. SVENSON: Sure. that are that have discussed last week, the And, your Honor, have motion nine search terms that are release with adjudicate lien Judge Ehrlichs courtroom. exclamation point and different words. Would you like step down there now And recall mean certainly THE COURT: Whatever you want. recall from our conversation last week was MS. SVENSON: see can early. February that those emails were exchanged asking THE COURT: Whatever you want. run that search. this the result that. MS. SVENSON: uncontested THE COURT: All right. you can just give turns out. one minute. THE COURT: dont have anything, right? MS. RITTER: Sure. down there now. THE COURT: All right. ahead. MS. SVENSON: will try and that and get MS. RITTER: So, your Honor, was saying, that done. the and afraid dont have copy those THE COURT: Sure. emails that discussed week ago, but see that (Recess taken.) counsel does. she can clarify (Whereupon, Mr. Santell left MS. SVENSON: You can look them. the proceeding.) THE COURT: looking them well. (Whereupon, the following looks like March 21st 2017. proceedings were held open MS. RITTER: the day that that the court.) day that produced the the second that THE COURT: you want identify the day that searched for the second you yourselves for the record. can see the second line this log shows that MS. SVENSON: Sure. Christine Svenson March 3rd those particular should back up. behalf plaintiff. have personally have own MS. RITTER: Amber Ritter for defendant. software the emails all the custodians over THE COURT: All right. So, Miss Svenson, did these five individuals. asked because they you have opportunity meet with Miss Ritter were not searched earlier, asked the folks over the document that she has now provided then search these five custodians for those the Court? extra search terms. This would the LM, Laquan, MS. SVENSON: did.
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
5..8
YVer1f THE COURT: All right. And have had chance order September ordered the parties sit down look well. And think understand and come with and agree search terms. it. just want make sure that the record Its really kind unclear from the clear about what discussed the last court emails whether not there was agreement that date and what are discussing today. what these were the search terms that were going currently pending Judicial Watchs second rule run and then turned over the agreement was show cause relates the courts order will run these search terms see how many hits from September 2016. will produce see its possible for run What the court had asked the mayors these terms and then turn over those documents. office the last court date, which was That might error. should have November 8th for todays hearing, was produce been little more clear court order some documentation show when actually was probably. can say that its the parties that they asked the department run the new fault not bringing attention maybe search terms that were least discussed between the plaintiff did bring attention and the parties March 2017. may not have been diligent it. And also asked the parties confer the other hand, dont see any emails with each other see they could still come from the mayors office either. And know, agreement about terms that can searched based Miss Ritter, you have said that was done what was disclosed the last court date about verbal communication with them. how voluminous the search would reveal went And cant back and forth this, with the terms that were tentatively discussed right? not going have full hearing shouldnt say tentatively discussed, the terms that said/she said and the emails that its going were discussed the March emails. produce this many. want get the merits lets the first thing first, here. All right? relates when the mayors office actually made Its going produce extraordinary the request their department run the amount hits. And now want get that searches, which think what the second portion todays hearing. reading documentation that you have produced today, this correctly, the three last sheets here Miss Ritter? MS. RITTER: Yes. MS. RITTER: Correct. THE COURT: what the emails would THE COURT: All right. ahead. produce. And this only three the MS. RITTER: And did speak with counsel custodians the hallway. And wont speak for her, but she MS. RITTER: Correct. did say she wanted run her client also, THE COURT: that were selected for the nine but happy continue now. search terms and combination, correct? MS. SVENSON: With respect the search MS. RITTER: Thats correct. And may, results that got. there one wrinkle that spoke with counsel THE COURT: All right. lets one thing about, prior stepping up, just now that wanted time. make clear for the record. the person, MS. SVENSON: Okay. Sure. Melissa Clark, who runs these searches, when THE COURT: appreciate, Miss Ritter, that you submitted her affidavit support our motion -18 have produced this. And think explains lot our response should say the petition for what was going during March 2017 and the rule show cause the affidavit and then also second rule show cause that was filed the attached Exhibits and she printed out petitioner. screenshot that was dated, you know, But, again, concern that between October 12th, 2017, that the bottom thats March and September 2017 there was breakdown said, attached Exhibit and communication. will put that. court one for each those custodians. this was
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
9..12
YVer1f substantiate that each these custodians has somewhat lower than what she said her affidavit. quite bit web traffic email traffic that They are still very high would submit. And was going withheld from these terms. will explain that. She realized this week when had her run But, for example, the first the three run the same search provide hit count custodians, Lisa Schrader, who was not even per search term this court ordered, which employed with the City during think some the what these other attachments reflect, that her period question, her numbers are little original search, she was quite distressed lower than the others. realize this, she made typo. But the total hit count for her reflects, the bottom each these sheets with that corrected search term, 2,136 hits whereas such Exhibit which reflects Adam Collins her this printout for her affidavit she had emails, say query. And can hand this said was 19,557 hits. its significantly the Court you dont have this front you. less. Just make clear, this the Having said that though and can see attachment Melissa Clarks affidavit that here, and have provided counsel, course, you previously filed response the petitioner for know, the Court ordered, the hit counts per rule show cause. the court can see, and search terms. counsel can look that and see will describe for the record, where says there anything that that would useful query, that she typed out the search terms that she for further narrowing it. was asked search. although these numbers are The first one, the court can see, says significantly lower because that typo, that the releas, R-E-L-E-A-S. And then the wild card figure first search she did for this, they are still quite which discussed means high. Miss Schrader had about 2,000 emails. THE COURT: The asterisk. Miss Rowntree had about 3,700 emails. And MS. RITTER: The asterisk which means Mr. Collins had almost 7,000 emails. includes release seen released, releases, So, again, you take average say release. But the first search term should have 3,000 emails per custodian conservative read release with that wild card character and estimate, times custodians, its still over recording. 60,000 emails you extrapolate out the And then the second one, the Court can custodians, all custodians. see, correct. says release with the wild our position would that card character and video. and then on. still you know, these terms are still too broad But for the first one she failed type and too elicit too many hits all the and recording along with that. what happened search. other words, FOIA requires that initial search that she did was actually reasonable search. And this number hits would overbroad, broader than even plaintiff had asked outside the context what would for because she didnt use the qualifier and reasonable. recording for that first term. just want make clear the court She just had release which going that little bit different than what had capture everything that says release whether not originally expressed. also says recording. THE COURT: their request for the individual realizing her error this week when hits per term actually was fruitful? late last week when she was running this new MS. SVENSON: Probably. think so. request for the same search terms but hit count per MS. RITTER: And would agree that term, mentioned, she extraordinarily sorry fruitful. You can actually see that some these about it, but what have provided the Court terms have significantly less hits than others. now the actual hit term per count. And those are terms that plaintiff And you can see that the numbers are interested in, those might places start.
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
13..16
YVer1f THE COURT: let ask you some questions, THE COURT: The 2,000 that are left, they Miss Ritter, that understand the manpower not relate Laquan McDonald, they would thats involved. nonresponsive the FOIA request. MS. RITTER: Yes. MS. RITTER: Thats right. THE COURT: lets with Miss Adam THE COURT: Would you agree with that, Collins? Miss Svenson? MS. RITTER: Yes. MS. SVENSON: Yes. THE COURT: Which seems have almost 7,000 THE COURT: Okay. There would need hits. Lets assume that the request would only through for redaction exception? Mr. Collins emails, 7,000 emails. Would the MS. RITTER: Correct. would just have City then, the mayors office then have review each one much briefer scale review through each individual email and what they for context see deemed pertains would they were going redactions for this incident. exemptions then? MS. SVENSON: Actually should clarify, MS. RITTER: Yes, with one caveat making believe that our FOIA request, going have little bit less onerous than what your Honor just double-check this, requested information with described because have expressed, you know, last respect the Laquan McDonald dash cam recording. week when were here, have already produced THE COURT: Shooting October 20. all Mr. Collins emails with the terms Laquan, MS. SVENSON: Right. Van Dyke with space and without space and LM. THE COURT: The specific MS. SVENSON: Right. THE COURT: this THE COURT: day. MS. RITTER: Correct. MS. SVENSON: Right. THE COURT: requester. MS. RITTER: further discuss that, the MS. RITTER: Thats correct. Yes. other part your Honors order from last week, THE COURT: Okay. which have worked through with counsel, MS. RITTER: the extent that any come with other search terms that had these sure quite few would just assume suggested last week that thought might more that several these 7,000 emails also say Laquan. fruitful getting other emails that may about For example, hypothetically there was the this incident but dont have the words Laquan, statement lets talk about the release the Van Dyke, the other spelling Vandyke and LM. Laquan video Laquan McDonald video, they that end have agreed, and have THE COURT: They already have it. already got the folks searching, although MS. RITTER: Already have that. these 7,000 dont have the results yet because they were tied emails, what would get these ready this, the additional terms Laquan spelled are ordered produce them just hypothetically incorrectly with L-E, Q-U-A-N because that take these 7,000 from the department. have might typo that people make. And think software that can pull out the ones that have actually some the court filings had his name those terms that already produced, Laquan, spelled that way. Van Dyke, with both spellings, and LM. the McDonald, his last name, which which number hits that havent already produced experience has showed going elicit lot that 7,000 might significantly lower, maybe unrelated items about McDonalds restaurant half, maybe, you know, two-thirds. dont know. other things, but will through those and dont know because havent done that yet. check. THE COURT: But then you have have Pulaski, because thats the name the manpower then and look lets say street that was shot on, case people refer from the 7,000 you have already produced 5,000. especially the just days after the MS. RITTER: Right. incident that shooting Pulaski. havent
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
17..20
YVer1f seen that, but possible. search terms, there really court order that And then the last term Burger King says anything different. And for hold because which also going elicit lot them contempt court order, dont think unrelated hits. But because the video from the that there court order that says produce those Burger King restaurant, the surveillance video was now that you have agreed the terms. Does that issue the time. suggest those search make sense? terms and plaintiff has agreed that those make MS. SVENSON: does make sense. sense. THE COURT: And, said, you can tell your THE COURT: You have agreed those? client that taking the responsibility this MS. SVENSON: did. and that court order probably should have been THE COURT: you think that those terms would more clear, that probably should have said once more fruitful than the nine terms that you all you agree the search term, then the City should have agreed to? produce. MS. SVENSON: Well, speaking with client, Now, think was little the City mean note that some these dont generate well that its very clear even from the lot hits. wondering can back emails well the log that you have now client and sort talk him about those produced that the City really didnt much more detail. between March and September. THE COURT: Okay. dont have any problem. MS. RITTER: understand your position. want get the emails. disagree, that did produce several hundred MS. SVENSON: understand. May just say some thousand emails June. But understand and THE COURT: But those are the same emails that THE COURT: Yes. were produced from the original production MS. SVENSON: completely understand your understanding. position with respect moving along. would MS. RITTER: No, they are not, your Honor. like state that just for the record that Those emails that produced June were let believe that agreement was made about back up. March 2nd 2017 regarding the search terms. And the original production December believe that the document just received, 2015 from the mayors office identified, and you know, backs our contention that, you know, forgetting the number, but was something like there was unnecessary delay because didnt custodians that were employees the mayors receive until June. Its all spelled out office that thought would constitute having done motion. just wanted state that for the reasonable search, meaning these are the people record. that would know something about this incident. THE COURT: agree. And here why searched their emails for the same struggled with it, not happy with the City and time period for those terms, Laquan, LM, Van Dyke the mayors office. Thats just personal gut and then Vandyke without space. reaction. response your Honors order and But for purposes rule show cause, response our conversations with plaintiff, you have show that violation court agreed expand that search these other order. And, indicated, maybe court order additional custodians. those additional could have and should have been little more custodians are the folks that are listed this clear. log that were part the other words, these court order only that the parties are the the members the custodians that would agree the search terms. And they did. plaintiff has identified that they are interested There contention. They agreed the search in, that did not originally search their emails terms. for anything. Now, what you did thereafter with the THE COURT: For the first five terms?
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
21..24
YVer1f MS. RITTER: Correct. these search terms wed like pursue. Some THE COURT: All right. the first production have just much lesser amount hits. prior the lawsuit was for only five custodians THE COURT: for purposes todays order and think what will reflect that petitioner MS. RITTER: think was like custodians. plaintiffs second rule show cause going THE COURT: Seventeen custodians denied and that feel that the court order was MS. RITTER: Yes. that the parties were agree search terms. THE COURT: and five search terms. And thats what was done. What was produced June was What they were with those agreed custodians and search terms. search terms really unclear, and there MS. RITTER: Right. And, course, had court order that reflects what was done with already produced the custodians minus the those search terms. not good math head but minus And the court going take ownership the believe that already produced yields that. probably should have been little new custodians essentially. clearer court order. THE COURT: Got it. MS. SVENSON: Should put that the order? MS. RITTER: didnt doubly produce what THE COURT: You dont have put the had already produced December 2015. What order, but the record. produced June instead was those new custodians MS. SVENSON: the record. that hadnt been named our initial search using THE COURT: But for purposes telling your those same four search terms that initially ran. client, think taking ownership it. THE COURT: Okay. So, Miss Svenson, still Secondly, the original terms that the doesnt preclude you from eventually saying that nine terms that the parties had agreed they failed produce the end this case March 2017 that plaintiff now going MS. SVENSON: Okay. look what has now been produced today those THE COURT: thats the situation. search terms and determine they want continue MS. RITTER: And one more piece that are pursue those and which ones they want doing since last were here week ago oh, pursue, and, secondly, that the parties have now well, did touch the fact that have agreed agreed additional search terms, those being those additional search terms that mentioned, Laquan spelled different ways, McDonald spelled Laquan with McDonald, Burger King, and different ways, Burger King spelled different Pulaski. will produce those. ways, and Pulaski and that the parties believe that mean just going based those search terms will reveal much more fruitful experience with these sorts terms and this yield the emails that plaintiff actually subject matter, dont imagine that going looking for this FOIA request. That means that elicit more than few thousand hits. And you are going produce them. that shouldnt 100,000 hits based MS. RITTER: Yes, with the caveat that its THE COURT: are abandoning the something like 100,000 hits, can revisit this MS. RITTER: No. saying thats issue. addition the Those are what the City would THE COURT: more than 100,000 hits, submit when are trying work out something then the parties will advise the Court. that think reasonable, would additional MS. RITTER: Okay. Fair. terms that might elicit more emails about this THE COURT: Fair enough? incident opposed about other completely MS. SVENSON: Yes. unrelated incidents. THE COURT: That way new court order MS. SVENSON: Right. Wed like back clear. client and, you know, based what received MS. RITTER: Let the grounds being today figure out which those which among clear, your Honor just mentioned McDonald spelled
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
25..28
YVer1f different ways. you have suggestion how MS. SVENSON: dont think so. think are should spell good. THE COURT: have idea. You are saying THE COURT: Okay. that you have done MS. RITTER: there date MS. RITTER: No, actually never searched for THE COURT: When you want come back? the word McDonald because our experience with the MS. SVENSON: Gosh, definitely after emails, and this pertains many different Thanksgiving. searches that did, nobody people werent THE COURT: trial December. referring the issue the McDonald issue. They MS. SVENSON: Okay. were referring either the Laquan McDonald THE COURT: going little incident simply the Laquan incident. hectic here. have done for the purposes other MS. SVENSON: Sure. The whole month you are situations with other clients with the police trial? department search for the word McDonald now THE COURT: The first two weeks, yes. add our initial search. And have found that MS. RITTER: can make myself colleague while elicits thousands hits, literally none available any time. them are related this incident that didnt MS. SVENSON: leave visit parents already have the word Laquan the email meaning December 19th. mean could come the 18th. already produced it. THE COURT: 18th fine. happy again with these MS. RITTER: Thats fine for me. custodians with the mayors office. just want THE COURT: And thats for status make clear, never did search for the word MS. SVENSON: Status. McDonald based our educated reason think THE COURT: what have done today. that wouldnt elicit reasonable hits MS. RITTER: 9:30? reasonable results. THE COURT: Yes. THE COURT: you have preference, MS. SVENSON: Great. Miss Svenson? THE COURT: Okay. Thanks all. MS. SVENSON: Well, thinking out loud. MS. SVENSON: Thanks, Judge. think some people spell M-A-C opposed M-C. THE COURT: Actually lets mean that would 10:00 oclock. That way dont have hold THE COURT: Thats reasonable. the 9:30 call because know that you all are going MS. SVENSON: Right. want talk. MS. RITTER: Sure. (Whereupon, further MS. SVENSON: And just leave that. proceedings said cause THE COURT: Yes. were adjourned MS. RITTER: And then your Honor also mentioned December 18, 2017, the hour different spellings the phrase Burger King. 10:00 a.m.) suppose can make one word thats what you are THE COURT: assuming Burger and then capital Burger King, small Burger and then King, two separate words, that type thing what referring to. MS. RITTER: not case sensitive, but can run one word THE COURT: Right. MS. SVENSON: Okay. THE COURT: Did miss anything?
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
29..32
YVer1f STATE ILLINOIS SS: COUNTY COOK Patricia Wangler, Officer the Court, says that she shorthand reporter doing business the State Illinois, that she reported shorthand the proceedings said hearing, and that the foregoing true and correct transcript her shorthand notes taken aforesaid, and contains the proceedings given said hearing. TESTIMONY WHEREOF: have hereunto set verified digital signature this 16th day November, 2017. ______________________________ Patricia Wangler, CSR Lic. No. 084-002417
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
YVer1f
bottom
10,13,18,23
breakdown
12:20,23 13:11
10:23
12th
11:13
26:14,16
22:6,22
context
16:8
24:7
19,557
15:12
14:12
abandoning
26:14
continued
21:2,5 26:7
business
actual
4:9
14:23
10:11
Burger
12:20,23 16:3
2,000
13:11 17:5
addition
15:23 19:1
2,136
call
26:16
7:18
additional
15:10
20:11 24:17 26:6,18
19:18
capture
7:21
2015
14:16
affidavit
24:5 25:18
2016
9:8
12:17,19 13:15 15:1,
4:1,12 16:4,6 24:20
25:10,12
21st
6:13
28th
cases
agree
11:2 16:20 19:5
22:11,21 23:12
4:11
5:6,8 20:8 21:7,9,13
22:22 23:5 24:16
26:5
9:18 11:4,6 22:3
3:15 6:6 10:7
12:20,23
3:10 8:17
City
approximately
6:10 19:14
Clark
12:16
13:24 14:1
Clarks
attached
4:15
3rd
13:15
12:20,23
clear
attachment
6:18 7:4
13:15
attachments
13:7
10:10 21:14,17 23:9
26:23
11:13,14
4:20
average
Collins
16:2
16:1 17:6
Collins
13:11 17:10,19
25:10,15,19
column
back
5,000
18:23
3:17 4:22 6:18 7:18
11:20 21:16 24:3
26:22
backs
9:18 26:9,13,23
began
25:13
7,000
16:1 17:8,10 18:5,
21:24 26:20
concern
conduct
3:7,9,10 8:18
bit
4:15 13:2 16:15
17:16
4:6
confer
9:16
6:1
4:5 5:2 9:13 10:2
18:13
exclamation
5:22
exemptions
17:14
Exhibit
13:18
12:23 13:11
4:23 21:18
Exhibits
12:20
expand
disagree
6:8
corporation
corrected
15:10
correctly
12:4
discuss
3:18 7:10 15:3
explains
19:24
discussed
5:10,20 6:9 9:4,14,
21,22,23 13:23
discussing
9:5
counsel
count
13:8
13:5 14:20,23 15:9
8:22 22:5
9:12 10:4
documents
15:16
11:9
couple
4:2,16 16:16 17:17
extent
extra
6:24
document
documentation
counts
10:18
expressed
18:3
distressed
3:9 5:10,17,18 6:10
10:8 12:13 15:15,17
20:2
20:17 26:10
explain
9:19
5:4 10:6 12:9,11,12
14:7 17:23 18:1
19:10 25:1
24:16
experience
23:20
disclosed
3:9
correct
extraordinarily
14:21
extraordinary
12:1
extrapolate
16:5
double-check
3:13
19:16
court
doubly
3:3,4,12,15,18,19,24
4:22 5:5 6:3,6,12
7:5,8,13,15,17,23
8:1,4,8,14,15,20,23
9:1,4,9,10,19 10:7,
14,17,24 11:11 12:6, 13:6,13,17,21,24
14:6,22 15:16 16:14, 17:1,5,8,22,24
18:2,9,21 19:1,5,8,
18,20,22 20:14 21:9,
11,19,23 22:11,16,
17,20 23:1,3,4,8,10, 24:24 25:2,6,8,
16,22 26:2,14
courts
9:7
courtroom
7:21
custodian
4:1,13 16:3
custodians
4:12 6:20,23 12:8,24
13:1 15:5 16:4,6
24:7,17,18,20 25:3,
5,6,10,12,15,19
communication
22:7
department
11:15
12:11
10:22
5:2
behalf
combination
completely
based
16:5
4:13
19:9
diligent
24:15
copy
10:24 11:19
22:6
60,000
9:4 11:11 12:15
13:14 16:14 22:19
23:11,15
client
attention
400,000
3:7 15:6 17:11 22:12
23:12,14,17 26:16
clarify
asterisk
15:24
check
Christine
17:9 18:4
399,000
character
3:6 8:19
assume
16:3
chance
amount
4:16
3,700
22:8
20:20
12:2
3,000
14:4,8
Amber
caveat
9:1
ahead
22:4
7:18
17:15
agreed
agreement
2nd
13:22 14:4,8
20:22 25:24
5:16 6:8
4:11 5:14 6:13 9:15
10:19,23 12:22 22:4
card
case
afraid
2017
cam
19:17
adjudicate
exception
exchanged
detail
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16:9 20:17 21:3
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20:8 25:24
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4:11 5:9,13 6:1
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13:22 26:24
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13:13
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11:21
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11:10 14:18
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
gave
7:2,4
generate
21:15
initial
manpower
14:11 25:20
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17:2 18:22
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3:19 6:3
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25:21
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18:6,12
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24:5,21
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19:3
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4:7 12:21
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McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052
search
4:1,3 5:3,5,6,15,18, 6:2,23,24 9:14,20
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21:8 23:6,7
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9:8 10:23 11:1 23:18
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19:18 20:24
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3:24 4:5
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9:21,22
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13:6 14:3,14,21,23
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20:4 24:8
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4:18 5:22 16:10 20:6
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20:2
McCorkle Litigation Services, Inc.
Chicago, Illinois (312) 263-0052