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

JW vs Office of Mayor Hearing Nov 15, 2017 Full

JW vs Office of Mayor Hearing Nov 15, 2017 Full

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

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Number of Pages:36

Date Created:November 16, 2017

Date Uploaded to the Library:November 16, 2017

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