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Judicial Watch • JW vs Office of Mayor Hearing Nov 8, 2017 Condensed

JW vs Office of Mayor Hearing Nov 8, 2017 Condensed

JW vs Office of Mayor Hearing Nov 8, 2017 Condensed

Page 1: JW vs Office of Mayor Hearing Nov 8, 2017 Condensed

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Tags:Condensed, Mayor Rahm Emanuel, mails, Ritter, SVENSON, Laquan, honor, Nov, terms, MCDONALD, mayor, hearing, 2017, search, FOIA, office


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Judicial Watch Office Mayor 462
Report Proceeding
Taken on: November 08, 2017
Judicial Watch Office Mayor
Hearing 11/08/2017 STATE ILLINOIS SS. COUNTY COOK THE CIRCUIT COURT COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, CHANCERY DIVISION
JUDICIAL WATCH, INC.,
Plaintiff,
vs.
THE OFFICE THE MAYOR THE No. 2016 000462
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 DEMACOPOULOUS, Judge said Court, commencing 2:11 p.m. November 2017.
APPEARANCES:
SVENSON LAW OFFICE,
MS. CHRISTINE SVENSON, behalf the Plaintiff;
CITY CHICAGO, LEGAL
MS. AMBER RITTER and
MR. PHILLIP SANTELL behalf the Defendant.
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MS. SVENSON: Good afternoon, your Honor.
THE COURT: Good afternoon.
MS. SVENSON: Hi. Christine Svenson. sorry.
THE COURT: ahead. Did Ms. Ritter step out?
MR. SANTELL: She did, your Honor. Shell back just two seconds. you would just wait THE COURT: problem. ahead. Were going
the wait. not going start without her.
MS. SVENSON: Sure, course.
MR. SANTELL: Thank you, Judge.
(Brief pause.
MS. RITTER: Good afternoon, your Honor. Amber
Ritter for the City.
THE COURT: Good afternoon.
MS. SVENSON: Good afternoon, Christine Svenson
behalf plaintiff, Judicial Watch, Inc.
THE COURT: Come up, counsel. you guys will
just move over little bit.
MR. SANTELL: Yes, thank you.
THE COURT: just saw your objection the
extension time give one minute MS. SVENSON: Sure.
THE COURT: read it.
(Judge viewing document.)
THE COURT: All right. the parties can
identify themselves for the record.
MS. RITTER: Amber Ritter for the Mayors office
and City Chicago.
MR. SANTELL: Phillip Santell,
Assistant Corporation Counsel behalf the named
defendant.
MS. SVENSON: Christine Svenson, Sam, Victor, behalf the plaintiff
Judicial Watch, Inc.
THE COURT: All right. were today
plaintiffs second rule show cause against the City,
the Mayors office Its actually just the Mayor,
correct?
MS. RITTER: And the Mayors office.
THE COURT: The Mayors office. And have
motion for extension time file the response
the petition for rule show cause, reply that was
filed today the response, and then objection
the rule the extension time.
MS. SVENSON: Yes. apologies. was actually
filed Monday, but did not get chambers until
today.
THE COURT: Yes.
MS. SVENSON: Right.
THE COURT: Ive received everything this
moment lets just start with that proposition.
guess the first thing that should dealing with
the Mayors response motion for extension time.
MS. RITTER: Your Honor, our response the
petition for rule show cause was you know, was set the previous schedule was set your order
September 11th and deeply sorry that did not get
the response filed time. was fault and with
caseload being very unpredictable, and apologize very
much. have attached the proposed, you know, response the motion for extension time. would just
ask allowed file it, you know, now. And
believe counsel her reply brief did address the
arguments the response. seems that the
briefing takes into account arguments the response,
not just the motion for the extension time.
THE COURT: Ms. Svenson, ahead.
MS. SVENSON: may. defendants request petition for
additional time microcosmic how theyve
handled this entire case. they Their response was
due October 10th. e-mailed counsel This
actually not reply. But e-mailed counsel
sometime mid October asking them they were
intending file reply, and they told they were
going seek extension. They didnt seek that
extension, course, until November 5th, couple days
ago because, course, this hearing was coming up. And dont believe that they have shown good cause.
Because typically when good cause shown, you know,
theres affidavit attached explaining the reasons why
the deadline couldnt met, you know with, you
know, cases that were up, summary judgment motions, jury
trials, whatever may be. And instead they just
attached affidavit person, which also
interesting about that because that person evidently
didnt begin her search until October 12th, which was
two days after their response was due. way have they shown good cause
able even granted, our opinion, leave file
the response.
MS. RITTER: Just that last point, thats
actually not The October 12th date the search
actually not accurate and not whats reflected the
motion. had the person, you know, conduct the
search again that she could print out that piece
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paper that that was attached our exhibit
exhibit show the number hits that were called from
the search. thats not when she originally did the
search, thats just when she printed the sheet that
would show, you know, the hits.
THE COURT: guess biggest concern though,
Ms. Ritter, that your response was due October 12th. doesnt strike you like oh, my, its October 12th.
Its October 15th. Its October 24th. Oh, my, its now
November 5th. better let Judge Demacopoulos know that
Ive blown her deadline.
MS. RITTER: apologize. agree with obviously with the Court that that would the proper
avenue. the Court isnt willing give the
extension time file the response, happy
just argue, you know, the merits our response here
today having with plaintiff having refiled her motion
and then her reply. mean, without, you know, being
allowed file the actual written response, can talk
about the merits it.
Because the This motion comes down the
fact that that plaintiff since March and weve
been telling them since March thats its not possible
has been asking produce over hundred thousand
e-mails their very broad search terms. And weve
gone back and forth telling them that this going over hundred thousand hits and its all
encapsulated the reply motion that she filed with
e-mails back and forth that she attached exhibits.
THE COURT: Ms. Ritter, you know, going stop
you there because really think that you need take
deep breath and look some the e-mails that you
have authored. lets not get into the substance
the argument quite yet.
MS. RITTER: Okay.
THE COURT: Lets stick Although respect
your position, Ms. Svenson, want get the
substance here. All right. Lets get the merits.
And not happy.
MS. RITTER: know.
THE COURT: Its very disrespectful your
opponents. Its disrespectful the Court. Its
disrespectful the entire judicial process that you
think that, you know what, Judge, fine. you dont
want file response time, you dont want
give extension, thats fine. You know what, just
let argue it.
The entire purpose setting the briefing
schedule that can prepared. that can
prepared hear your arguments that can make
informed decisions and that dont fly the seat.
MS. RITTER: understand that. didnt mean
sound flippant.
THE COURT: Well, you did.
MS. RITTER: And apologize.
THE COURT: Thats the entire purpose the
briefing schedule that are prepared well
make the best decisions that can. over the plaintiffs objection, going allow them file their response that can get the merits that can get what important
this case. All right. the response will filed.
Has been filed with the Clerks office?
MS. RITTER: No. was asking leave file can file it, you know, right directly after this with
the Clerks office.
THE COURT: will filed instanter. soon were done with the hearing today, down the 8th
floor file instanter.
MS. RITTER: Okay.
THE COURT: Have you received copy though?
MS. SVENSON: have.
THE COURT: All right. lets get the merits
here. All right. just have couple questions and want make sure that reading the filings
correctly. Back Just give minute. Sorry. brief pause.)
THE COURT: September 23rd 2016, the Court
ordered motion dismiss that the parties should
get together and determine search terms that should
done new search because the Court felt that the
searches the terms that were originally used were not
sufficient satisfy the FOIA request that was actually
sent. And there are certain e-mails that were attached both the rule show cause and the response from
both parties. Subsequent those e-mails, something
was turned over June court. dont know what was
turned over June. can somebody inform what was
turned over June?
MS. RITTER: can.
THE COURT: Okay.
MS. RITTER: June following correspondence, course, between had that point identified
with worked with plaintiff identify custodians
from the Mayors office that they wanted search
their in-boxes. Because originally think they asked
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for everyone and thats over hundred employees. worked with them and got down that are
people that they thought might involved with this
scenario. then June what produced them
court was disk that had all these people for the
time period issue, which October 20th, 2014
through December 2015, with the search terms Laquan,
Van Dyke, which the shooting officer, course,
spelled both Van Dyke, one word and Van Dyke with
space and thats just case catch any, you know,
missed typos the name. And which often
what saw that how people refer the incident.
They werent calling the Laquan incident. They were
calling the incident. those are the three
search terms that produced. all these
custodians were searched and those were produced
counsel June with think was six e-mails that
were redacted withheld, which think your clerk had
asked for that and thats what prepared and gave counsel.
THE COURT: All right. that correct?
MS. SVENSON: No. Well, partially. guess
should clarify. that date court, was handed CD. didnt know what represented because there
was cover letter attached.
THE COURT: Correct.
MS. SVENSON: then had follow with
e-mails numerous occasions find out whether there
were any exemptions, what the even represented. So,
yes, did receive the back June, but didnt
know until many months later what even represented.
Probably maybe even two months ago when found out.
THE COURT: Okay. But the still did not have
the additional search terms that were ordered
September MS. RITTER: Correct.
THE COURT: 2016.
MS. RITTER: But there were additional specific
search terms that were ordered September 2016.
THE COURT: Correct.
MS. SVENSON: But agreed THE COURT: Hold on. Hold on, Counsel.
MS. SVENSON: sorry.
THE COURT: Hold on. the first response, the first FOIA response
the search terms that were used were Laquan, Van Dyke
one word, Van space Dyke, and but were limited
certain amount custodian searches?
MS. RITTER: Right.
THE COURT: The second response, the June response,
June 2017 response now has custodians, correct?
MS. RITTER: Correct.
THE COURT: But using those same search terms?
MS. RITTER: Correct.
THE COURT: question how has the City
conformed this Courts order about additional search
terms that ordered you agree with plaintiff?
MS. RITTER: the way that weve conformed
this Court about that that have entertained these
additional search terms. mean, course, your
court your order provided that need come you
know, come some agreement work out some search
terms what your Honor has very specific
search terms THE COURT: Slow down, Ms. Ritter, because that
record mess right now.
MS. RITTER: apologize.
THE COURT: repeat that.
MS. RITTER: Okay. Your order Your Honors
order didnt suggest any specific search terms
search, but instead suggested that conferred with
plaintiffs counsel and come with terms that, you
know, would agreeable and reasonable
produced. counsel for plaintiff and plaintiff came with And can read them for the record, youre
interested.
THE COURT: Yes.
MS. RITTER: These these search terms
addition the four that just mentioned, Laquan, Van
Dyke, Van Dyke with space, and that they would
like the City search these custodians and these
terms. And these terms are release without exclamation point, which say because theres boolean search function that our
system has. that would allow for release.
THE COURT: boolean spelled?
MS. RITTER: And what that means
when theres wild card character, this case exclamation point, that exclamation point
substituted for any letters that could appear after that the last letter. other words, this
would encompass the word release because that would would replacing that exclamation point
released releasing releases from the other
words that not thinking about, releasing think
said that. the first term they wanted was release,
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Judicial Watch Office Mayor
Hearing 11/08/2017 exclamation point and the recording.
what that means any e-mail that has both the word
release with the exclamation point and the word
recording anywhere the e-mail attachment any
point, those two words are the e-mail then would
called. Thats the first option. The second option
release, exclamation point and video. The
third the same spelling release and dash. The
fourth same spelling release and camera. And then get recording, the normal spelling and video
recording and dash recording and camera. And then dash
and camera. And then one word, dash cam. having Yeah, having taken those
search terms and giving them our department, who
runs the department the City that runs searches
e-mails, they informed that the magnitude the
search going such that would difficult
even perform the search because shuts down their
systems for days.
THE COURT: Where that?
MS. RITTER: That the the affidavit
Melissa Clark (phonetic), attached our response
Exhibit and its par- can give your
Honor.
THE COURT: Please.
MS. RITTER: And its Let just look the
paragraph. Ill hand you. Paragraph and
This the second page her affidavit.
THE COURT: dont have it. Its not linked.
MS. RITTER: She the affidavit explains,
Melissa Clark the person the Citys department
innovation and technology who runs e-mail searches.
Theres only one person citywide that does this. she well-versed how e-mail searches work. This all
she really does all day long. She input these search
terms gave her these search terms search.
And you can see and believe its paragraph
the next page, she says that, Due And dont have
her exact wording the top head. But due the
extent the large size the search, she wanted
identify just few the custodians start with
just she could give flavor how big how
magnitude search this was going be. She
knows THE COURT: But whats missing from her affidavit,
Ms. Ritter, and what concern for purposes
today MS. RITTER: Mm-hmm.
THE COURT: which the rule show cause
when did you give Ms. Clark this request?
MS. RITTER: would have been back the spring
when were talking about these search terms maybe was early summer.
THE COURT: then this not reflected any
your e-mails and/or her affidavit?
MS. RITTER: believe Her affidavit what
she did, not what our interpretation, you know, whats
burdensome. But believe THE COURT: No. No. No. Youre missing
question here. Listen carefully.
MS. RITTER: Mm-hmm.
THE COURT: Whats missing from her affidavit
when did you give her this request?
MS. RITTER: Well, think can answer that
question look through these e-mails, would have
been referred to. looking through the e-mails that
counsel attached her reply believe she also
attached them her initial petition you see that Let just Give moment, your Honor.
THE COURT: Sure.
MS. RITTER: can find them.
(Brief pause.)
MS. RITTER: Okay. the page
looks like counsels reply, which the part the
e-mails that she attaches.
THE COURT: sorry. Say that again.
MS. RITTER: Sure. Page its stamped the
side from the e-filing page thats the page that looking from counsels reply plaintiffs
reply. that the e-mail from Ms. Svenson dated
August 22nd, 3:19 p.m. And not sure this
actually answer when she first did the search, but
were big THE COURT: August 22nd 2017?
MS. RITTER: Thats what And believe told her this earlier and references that this
e-mail. said apologize that was
(indecipherable), but think was.
THE COURT: sorry. Say that again.
MS. RITTER: said the e-mail apologize
that wasnt communicated you earlier, that would
yield that the search that just described yields
over hundred thousand hits. But believe was
communicated her earlier.
THE COURT: And going ask you again,
Ms. Ritter.
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MS. RITTER: Mm-hmm.
THE COURT: Show where when you requested
Ms. Clark MS. RITTER: can back and get that
information. would have been obviously much prior
this August 22nd.
THE COURT: 2017?
MS. RITTER: Yes.
THE COURT: order was March 2000
sorry September 2016. And looking the
these e-mail correctly, appears March 2017, you
all had agreed these terms. And the last e-mail Let make sure reading correctly. Friday,
March 3rd, 2017, 12:49 p.m. from you Ms. Svenson
and Michael Akesha (phonetic) that follows e-mails
thats got all these search terms that they have
created. And its from you that says and
quoting: does make sense. will have them start
that now.
MS. RITTER: Right.
THE COURT: And the first time that theres any
memorialization from you plaintiff that this search going yield more than 100,000 e-mails your
e-mail September 2017.
MS. RITTER: couple points that. First
all, that when March 2017, March 3rd,
had that communication which was memorialized that
e-mail and said would have You know, does make
sense. will have them start that now, meaning they
will run that search.
Now, did phone calls and recall speaking
with plaintiffs counsel who was here and also
Mr. Vicasia (phonetic) the phone where explained
that those search terms are broad that its yielding
just unwelding number hits, over hundred
thousand exact. dont isnt true that these e-mails
reflect the only communications that had the only
time that expressed plaintiff that those very
broad search terms, you know, which are now specifically
tailored the Laquan McDonald shooting are going
yield did yield based Ms. Clarks search, which
was started March 2017 THE COURT: then theres follow-up e-mails from
them. March 29th, Amber, anything this.
response. Response March 29th, Hi, Christine,
going receiving lot this tomorrow from
client. will take day put into productable
(phonetic) format plan get you Friday. thats March 2017. But yet June, you give
them something thats completely different than what the e-mails that youre responding. Because June
what youre giving them not searches that include
those terms. Its searches that include the terms that
you originally gave them.
MS. RITTER: believe that they had also asked run the terms that originally searched all those custodians. wasnt completely unrelated
what they were asking. was part what they asked
for.
THE COURT: April, Amber, any updates.
response.
MS. RITTER: produced several thousand e-mails reviewed several thousand e-mails produce
them plaintiff. That does, your Honor, with all
respect take great amount time.
THE COURT: Has anything been produced more than
what the June CD?
MS. SVENSON: No.
MS. RITTER: No. Since the time that produced
those e-mails with those search terms that noted.
THE COURT: have you produced anything other
than the June CD?
MS. RITTER: Correct. No. Well, except the
original production December 2015, which was also
several thousand e-mails.
THE COURT: ahead, Ms. Ritter.
MS. RITTER: One thing would submit the Court mentioned the e-mails and the dialogue that had, the search terms the plaintiff these second
set search terms with the words like recording and
camera, were are likely elicit thousands and
thousands not dozens tens thousands hits
that are mean, probably almost all them are
unrelated. can give you two reasons why believe
that. The first that, you know, there are lots other issues that come before the Mayors office that
has with cameras and recordings, and specifically
red light THE COURT: not sure that thats true.
MS. RITTER: But this THE COURT: But why havent you filed formal
response saying that?
MS. RITTER: Well, because Because dont know
for fact whats those e-mails because havent
started looking them. The breathe them
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huge. And they also weve produced all the
e-mails from those custodians that have the words
Laquan Van Dyke them, definition these
hundred thousand hits more than hundred thousand
hits are all e-mails that have these search terms that
dont even say the word Laquan theyre very unlikely connected that incident. because that
have expressed plaintiff multiple occasions,
including the phone that these search terms are
simply significantly too broad constituting what consider reasonable amount searching that need comply with the FOIA request. have
asked them come with better search terms,
more narrow search terms.
THE COURT: Where that? Where that e-mail?
MS. RITTER: believe was the phone.
THE COURT: MS. RITTER: No. sorry. apologize for
getting excited here. But think the
e-mail and its THE COURT: Which e-mail?
MS. RITTER: Yes. The e-mail August 22nd
2017 that referenced earlier from Ms. Svenson
and others three paragraphs long. Actually, the
second The whole e-mail. say, addition the
information that supplied yesterdays letter, the
search you requested below, which with what
discussing here, still yields over hundred thousand
hits. And then moving says, you can propose
terms that would significantly narrow your request, then can try again and see how many hits yields. And
then say, way advice, try helpful
get this completed, mentioned before have
that conversation about that, terms like recording and
camera not sufficiently specific and likely
yield thousands hits unrelated subjects
voluminous communication such red light camera
program and lawsuits. asking them give the
opportunity try give words terms that would
get down less than, you know, hundred thousand
e-mails.
THE COURT: head, Ms. Svenson.
MS. SVENSON: plaintiff has been trying get
compliance with this Courts order since September 2016. The parties conferred via e-mail March 2017 and reached agreement the search terms
that were used. this point this Court
pointed out, were given records
March 29th sorry the day following
March 29th, pursuant e-mail from counsel.
never received those records. finally received already stated June 2017 without cover
letter. have, course, then asked questions about
what that represented, meaning that and Because
didnt know that there were exemptions, what part the
search represented. was like pulling teeth get
answers. followed with them June 28th,
July 10th, July 17th. Defendant did not respond defendants did not respond any those e-mails.
finally said, you know, look July July 17th e-mail, are force file another petition for
rule didnt get compliance, didnt hear anything.
The only time ever heard anything from them right
before court hearing.
With respect what counsel indicated about
the telephone conferences, recall maybe two the
most the last two years. And dont remember
exactly the representations that they made. But
there had been, sure they would have been
memorialized e-mail.
With respect to, you know, theyre claiming
the voluminous nature the hundred thousand plus hits, went over this August with them. responded
and said, okay, via e-mail can you tell how many
hits THE COURT: Hold second. Hold on.
(Discussion off the record.)
MS. SVENSON: notably every time they
e-mailed us, get back them within day two. August 22nd, she did indicate Ms. Ritter indicated
that there were over hundred thousand hits. got
back them August 23rd, you know, still asking
about the exemptions issue, you know, two months after got the CD. And then secondly, how many hits does
particular term generate. That could help lot. Then
thats all have know. mean, knowing that
theres over 75,000 hits from one custodian isnt that
helpful. Whats helpful is, you know, which search term
generates 30,000 and which generates 5,000. Then youd much And thats the purpose Thats why asked
these questions.
THE COURT: And guess for purposes right now,
Ms. Ritter, concern when did you ask Ms. Clark this?
MS. RITTER: That would have been And
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apologize for not having the exact date when spoke
about this earlier. But based these e-mail
exchanges, would have been March 2017. run
the initial search both those broad search terms that discussed and the original search terms discussed the custodians.
THE COURT: then what you have attached
Exhibits and are you telling that Ms. Clark
was going have this document thats going have
date it?
MS. RITTER: dont know that Shell only have
the document with the date still she printed the initial time had her print the screen out
that can attach the affidavit. cant
relate whether shes still You know, she ever
prints the first time opposed just advising
about the number hits that was yielded.
afraid dont know the answer that question.
THE COURT: And guess, Ms. Svenson, going
ask you this question. And its question that you
dont feel comfortable asking behalf your client, will respect that.
Are you more interested getting these
e-mails holding the Mayors office contempt?
MS. SVENSON: would say both. need these
e-mails. But also mean, dont know what else do.
THE COURT: understand that. And dont know
what else either. heres what going do.
MS. RITTER: dont mean interrupt, but have idea, that would helpful.
THE COURT: Ms. Ritter, please. But you know what, you give idea, you better follow through with
it.
MS. RITTER: Certainly. suggested,
could come with more narrow search terms, would
produce them. know took time THE COURT: Okay. So, Ms. Ritter, that was your
idea, why didnt you send e-mail with that?
MS. RITTER: did.
THE COURT: No, you dont see single e-mail
that says what your suggested terms are.
MS. RITTER: Well, they would like suggest
terms, happy that. But that wasnt what
understood our communications about. And frankly
the search terms that initially suggested were the
ones the four that your Honor has front her (inaudible).
THE COURT: And already ruled that those are
insufficient.
MS. RITTER: have done since the time your
Honors hearing, search not the Mayors
office, but different departments similar e-mails
with additional search terms that think could
useful here. Those terms are Laquan spelled with
because sometimes its misspelled, found. The word
Burger King because the shooting occurred front
Burger King. The word Pulaski because the shooting
occurred Pulaski. its possible that someone
might have referred the Pulaski shooting.
Beyond that review tens thousands these
e-mails from different departments over the course
the past few years shows that they anything about
this incident does say Laquan Laquan McDonald it.
These other search terms dont you know, havent
been havent been finding that these search terms
are yielding hits that are related this incident.
However, that those search terms would something
would suggest might place start.
MS. SVENSON: may THE COURT: Yes.
MS. SVENSON: your Honor. still They agreed September 8th
actually provide with how many hits particular
search term generated. Thats her e-mail
September 8th. Thats when she says, Yes, have asked
our tech department pull that together and will
take few more days. never got our answer
that. And that was also not addressed Ms. Clarks
affidavit.
THE COURT: All right. guess, Ms. Svenson,
heres what willing do. you want stick those search terms?
MS. SVENSON: Yes.
THE COURT: And heres the reason why
appreciate that the Mayors office interested
suggesting those terms. have idea what Judicial
Watch wants. dont know theyre interested just
the Laquan McDonald videos theyre interested
dash-cam videos. dont know.
MS. RITTER: dont know either.
THE COURT: dont know. And its their decision make. Its their FOIA request, okay. theyre
more interested seems that theyre more interested the word release, its their search terms.
When can you get the information that they
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have requested their September e-mail about the
number hits that are yielded the combination
the terms release exclamation and then the other word?
MS. RITTER: Just if, your Honor, youre
referring simply the first search term all nine
them?
THE COURT: Which ones did you want?
MS. SVENSON: All them. Because agreed think there are nine them.
THE COURT: All nine?
MS. SVENSON: Right.
MS. RITTER: can can have Ms. Clark run that
immediately the Courts order. One hitch
that theres apparently two system mean, its just technical problem, which will have overcome.
So, yes, can get her that. Today Wednesday, Unfortunately Friday holiday. Monday
she can get that hit term.
Now let Let just clarify what
were all looking for. Are looking for number
hits per custodian, per each the nine terms? Because
thats going take lot time.
MS. SVENSON: could even probably work something
out where would be, you know, half them just have some idea where go.
THE COURT: Let ask you this, right. the
number hits right now, limited the
custodians?
MS. RITTER: fact, its limited the three
sample custodians that Ms. Clark mentions her
affidavit. Because she said this going
hundreds thousands hits and its going shut our
system down. Unfortunately dont have great,
modern system. She asked THE COURT: great what?
MS. RITTER: Modern system.
THE COURT: Okay. just want the record
clean.
MS. RITTER: Certainly. apologize.
She asked identify sampling
custodians that she could run the search those
samples first. THE COURT: Heres what were going Ms. Were going Were going keep the
three, three custodians for the nine combination.
Does the nine combination also include the
four original search terms?
MS. RITTER: No.
THE COURT: Can it?
MS. RITTER: Let make sure understand what
youre asking. you mean can also add the four
original several more ...
THE COURT: Layers.
MS. RITTER: guess want make sure
understand what you mean layers. you mean that
the terms would have include those terms and these
terms?
THE COURT: Yes.
MS. RITTER: let Again, just want
make sure understanding. When she runs the search
for these nine search terms, were going hit
count opposed just search for e-mails, the way
hit count works is, for example, No. release and
video, shell able determine, you know, how many
e-mails Mr. Collins had for that; how many e-mails
Ms. Mitchell had for that; and how many e-mails Ms.
(Indecipherable) suggested had for that term. And then she gets the second one, release and dash, shell the same. Now, the difference between running all
these nine terms together versus doing hit count, mentioning that youre going get
duplicates.
THE COURT: Sure.
MS. RITTER: the same e-mail, probably quite
few may have release and video and also release and dash it, will look like theres two separate items. the hit count probably going add
significantly more than the actual number e-mails;
although think she can figure that out too.
But this question for the Court.
then you want other words, No. would Laquan
and then how many hits that just that word alone has?
THE COURT: No. saying this inquiry.
MS. RITTER: Okay.
THE COURT: Can this done? Because think this
will limit the number hits. Can you release
exclamation and video and Laquan?
MS. RITTER: Yes. But let explain, your Honor,
that weve already produced all those e-mails that
say Laquan Van Dyke those would the
e-mails weve already produced. say for
this You know, this e-mail this was e-mail,
this what holding and said release the video
about Laquan it, weve already produced that e-mail
because says Laquan and weve already produced all
the e-mails from these custodians that say Laquan.
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 says THE COURT: And how many were originally produced?
MS. RITTER: few thousands.
THE COURT: What does that mean?
MS. RITTER: Well, the question tough because
when you have chains e-mails when produce
dedup (phonetic) it, which means that you might get
hit like 5,000 initially. But the time Its
produced actually courtesy that its not just
bazillion pages; take out chain just produces
the top the chain. think was THE COURT: All right. think getting your
point now.
So, Ms. Svenson, heres questions you.
The FOIA request that was sent limited
October 14th 2014 through December 7th 2015, and
the language the FOIA request is, Any and all records communications sent and from officials the
Office the Mayor, comma, including but not limited
Mayor Rahm Emanuel, comma, regarding, comma, concerning relating police dash-cam recording the
October 20th, 2014 shooting Laquan McDonald, comma,
including but not limited the release any such
video recordings the public. inquiry you, are you interested
any other e-mails that not relate the
October 20th, 2014 shooting Laquan McDonald that have
the words release, video, dash cam?
MS. RITTER: Recording.
THE COURT: Recording any those nine search
terms?
MS. SVENSON: guess confused. Are you saying
are not interested those?
THE COURT: Are you interested those?
MS. SVENSON: Yes.
THE COURT: Why? How does that fall into the FOIA
request?
MS. SVENSON: Ill have you look the language
again. sorry. know you just read me.
THE COURT: Here.
MS. SVENSON: Thank you.
THE COURT: you understand question?
other words, the nine search terms are going yield
more theyre going reveal more communications that
are not related the October 20th, 2014 shooting
Laquan McDonald.
And the purpose meaning the FOIA
request limited the October 20th shooting?
MS. SVENSON: And its aftermath, yes, and the
dash-cam recording about it.
THE COURT: Fine.
MS. SVENSON: Right.
THE COURT: But its limited that incident,
then e-mails that are not related any sorry,
its not just Any communication that includes those
search terms that not related that incident not
responsive your FOIA request.
MS. SVENSON: Related the incident and its
aftermath.
THE COURT: Right.
MS. SVENSON: Correct.
THE COURT: And these search terms are overbroad
thats why youre getting Theyve already produced
e-mails that are would include the words release,
video, dash cam; all those combinations they
include the word Laquan, Van Dyke, Van, slash
space Dyke and
MS. SVENSON: But dont know how many hits each
one these ...
THE COURT: understand that. appreciate that.
MS. SVENSON: Right.
THE COURT: And you wont.
But there is, for example, e-mail
concerning the red light camera and release that now
responsive your FOIA request. Would you agree?
MS. SVENSON: agree.
THE COURT: Its going come the search
terms for that because falls into that parameter.
And its increasing the hits. And your FOIA
request targeted limited the October 20th
shooting Laquan McDonald, why cant limit that
search term just Laquan McDonald and those Havent
you already received that?
MS. SVENSON: think have except for have
not searched these terms. And agreed with them
these terms. mean, its just nine more terms.
THE COURT: are you saying theres possibility
that Yeah, but youre going get The terms are
too Its too much.
MS. SVENSON: Well, thats what dont would
argue that dont know. Because could just get number hits related each one, would
better position respond.
THE COURT: Can Ms. Clark, based what youve
already tendered cross-reference how many these are
duplicative? answering that Did ask that
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017
question appropriately?
MS. RITTER: Yeah. believe understand. Let
see can rephrase that. know this confusing,
your Honor.
Youre right everything you said that, you
know, says Laquan it, its already been
produced whether not talks about releasing
video. what think Ms. Clark can is, for
example, search term No. release exclamation and
video, and she can search also that includes and
not Laquan and not and not Van Dyke because those
terms have already been those e-mails that would have
those words have already been produced. then what have hit count e-mails
that have the words release and video them that dont
reference Laquan McDonald Jason Van Dyke. This
why few minutes ago suggested And sorry
wasnt clear why sometimes the the search
terms gets little bit confusing. That were
going broaden the search terms, other
references that people might have Laquan McDonald.
Sometimes they spelled his name wrong. fact, think
even some the pleadings the civil case his
named instead since
realized that. that, think, would another
appropriate search term. already have all the
e-mails that say can add that the
e-mail that say
Another one mentioned Pulaski because
the shooting was Pulaski. And people are
referring it, especially days just after the
incident, they might not You know, the name the
victim unfortunately wasnt, you know, known
now. They may have referred that shooting
Pulaski. trying suggest words that would
encompass other ways people would refer Laquan
McDonald even just McDonald. Although weve run that
before other departments and found that its almost
never responsive. People dont just call McDonald
opposed Laquan McDonald. Because your Honor
rightly points out, all youre getting would these
terms. And this what Ive been trying tell
counsel all this THE COURT: Well, quite frankly, Ms. Ritter, you the communication hasnt been that great.
MS. RITTER: understand that. But did have
phone calls about this where said this very thing.
THE COURT: The communication has not been that
great.
MS. RITTER: Okay.
THE COURT: Just accept that.
MS. RITTER: do. Thank you. your Honor stated, all youre getting with
running these terms e-mails that dont reference
Laquan McDonald that have these terms, which our
argument its not responsive the FOIA request
which why discourage this search. Its too broad search and needs narrowed.
THE COURT: needs narrowed.
MS. SVENSON: this helpful. This the
first time Ive heard anything about Pulaski Laquan
spelled the wrong way. this really helpful and learning this today. Its November 8th ...
THE COURT: Okay. think those terms are much
more likely get more better results than some the other terms. Because there were other issues
going the same time.
MS. SVENSON: Right.
THE COURT: All right. going give the City opportunity come with additional search terms
within one week.
MS. RITTER: can today, your Honor.
happy confer with counsel directly after this today.
What suggest, based other searches again
said that run for City departments since weve made
the initial production that have yielded can pull additional e-mails than just searching for Laquan.
MS. SVENSON: Can sorry interrupt.
Can find out how many hits these generate that possible?
MS. RITTER: dont know can answer that
question.
THE COURT: Which hit?
MS. SVENSON: The nine that the search terms
that had, you know, back and forth via e-mail.
THE COURT: Its going over hundred
thousand.
MS. SVENSON: No. Well, talking each
individual one though.
THE COURT: What difference does make?
MS. SVENSON: Well, because what one them
only has like 5,000? Thats question. Thats
point.
THE COURT: She can that.
MS. RITTER: can She can definitely that.
THE COURT: that well.
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017
Ms. Ritter, youre not quite off the hook yet
either.
MS. RITTER: hear you.
THE COURT: want know when you first requested
Ms. Clark the search.
MS. RITTER: Okay.
THE COURT: And not going happy
wasnt shortly after March when you all came this
agreement.
MS. RITTER: Yes, was March.
Your Honor, how would you like THE COURT: Anything that she can validate.
MS. RITTER: Okay.
THE COURT: mean, its computer system. know
that theyre time stamped. Theres validations.
Theres all kinds ways that the City can validate
when something was requested. sure that theres
some e-mail from you her. You know, you dont just
pick the phone and say, hey, can you this,
Ms. Clark.
MS. RITTER: sure can find some THE COURT: Theres some request form that you used get her get her this. Because not going happy there was long delay.
All right. for purposes today, not
going make ruling petitioners the
plaintiffs second rule show cause. going ask
the parties again confer and try come with some
search terms that will yield workable result. did receive the index from the June CD, and guess well have deal with that later thats
going something that plaintiff going
contesting those are appropriate exemptions not; whether not need in-camera inspection
and well take from there.
MS. SVENSON: Okay.
THE COURT: dont know how much more can
stress. Ive reached limit.
MS. RITTER: Your Honor, when would you like Would you like mean, THE COURT: like you guys come week.
Okay. How about next Thursday. Oh, no, thats not
good. Wait, let see.
Thursday the 16th Friday the 17th?
MS. SVENSON: out town for conference Thursday and Friday.
THE COURT: How about the following week the
20th 21st?
MS. SVENSON: And then gone for Thanksgiving.
THE COURT: That whole week?
MS. SVENSON: Well, leave Monday morning.
Its Yeah, parents are out town. Theyre
elderly its hard THE COURT: get it.
MS. RITTER: next Wednesday not available?
THE COURT: good the 15th.
MS. SVENSON: Yeah, would love could
that.
THE COURT: The 15th fine.
MS. SVENSON: Oh, that would great. Thank you.
THE COURT: Okay.
MS. SVENSON: Thanks, Counsel.
What time?
THE COURT: 9:30.
MS. SVENSON: Okay. Thanks for accommodating.
THE COURT: Any questions?
MS. RITTER: No. Its clear. Thank you.
THE COURT: Okay.
MS. SVENSON: Thanks, all.
(Which were all the proceedings had the above-entitled cause.) STATE ILLINOIS SS. COUNTY COOK Terry Barfield, being first duly sworn, oath says that she Certified Shorthand Reporter doing business the City Chicago, County Cook and the State Illinois; That she reported shorthand the proceedings 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. ________________________________
TERRY BARFIELD, CSR CSR No. 084-004536 SUBSCRIBED AND SWORN
before this 14th day November A.D., 2017.
_______________________________ NOTARY PUBLIC
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017
Index: 1..combination
30,000 25:18
addressed 29:7
advice 23:8
3rd 18:14 19:2 26:8
3:19 17:9
advising 26:16
affidavit 5:9,13 14:21 33:9
100,000 18:23
10th 4:24 24:11 17:1,6
11th 4:9
5,000 25:18 34:8
12:49 18:14
12th 5:15,21 6:7,8
afraid 26:18
41:20
5th 5:5 6:10
14th 34:16 15:3,13
afternoon 2:1,2,12,
attaches 17:3
attachment 14:4
August 17:9,12 18:6
22:22 25:2,9,11
authored 7:9
avenue 6:14
agree 6:12 12:9 37:3,4
agreed 11:17 18:12
6:1 7:5 9:12 11:1
14:22 16:19,20 26:7
14,15
29:1 30:8 37:13
17th 24:11,13 43:20
aftermath 36:1,11
agreeable 13:1
15th 6:9 44:8,11
16th 43:20
15:4,6,21 16:7,8,14
26:14 29:8 31:7
attached 4:12 5:9,13
agreement 12:14
23:22 42:9
back 2:5 7:2,5 9:4
11:6 16:3 18:4 25:8,11
41:13
based 19:18 26:2
37:22 41:2
ahead 2:4,7 4:19 21:5
bazillion 34:10 26:8 32:15 38:9
75,000 25:16
Akesha 18:15
begin 5:15
2000 18:9
7th 34:16
allowed 4:14 6:19
behalf 2:16 3:6,9
35:3,21
2015 10:7 21:3 34:16
8th 8:20 29:1,4 40:15
2016 9:6 11:13,15
9:30 44:16
20th 10:6 34:22 35:3,
21,24 37:8 43:24
15:17 20:9 22:2 26:6
31:3 33:24
21st 43:24
22nd 17:9,12 18:6
amount 11:24 20:18
22:11
23rd 9:6 25:11
24th 6:9
28th 24:10
29th 19:21,22 24:1,2
above-entitled 44:23
accept 40:3
accommodating
44:17 17:1,6 26:8
case 4:23 8:14 10:10
13:16 38:23
caseload 4:11
cases 5:11
catch 10:10
20:20 21:1 24:3,6
25:13 43:6
chain 34:10,11
chains 34:6
chambers 3:22
character 13:16
Chicago 3:4
Christine 2:3,15 3:8
26:21
big 15:18 17:11
biggest 6:6
bit 2:18 38:19
19:22
City 2:13 3:4,12 12:7
13:9 14:15 40:21 41:3
42:16
blown 6:11
Citys 15:7
boolean 13:12,14
citywide 15:9
answers 24:9
breath 7:8
civil 38:23
apologies 3:21
breathe 21:24
claiming 24:24
briefing 4:17 7:24 8:9
clarify 10:23 30:19
broad 7:1 19:10,16
Clark 14:22 15:7 16:2
8:7 12:19 17:15,18
22:18 26:1 31:15
apparently 30:14
appears 18:11
account 4:17
appropriately 38:1
accurate 5:22
arguments 4:16,17
11:10,14 12:8,12 28:6
40:22 41:5
address 4:15
18:3 25:22 26:8 30:12
31:6 37:22 38:8 42:5,
burdensome 16:10
Clarks 19:18 29:7
Burger 28:9,10
clean 31:14
argument 7:10 40:8
addition 13:7 23:1
broaden 38:20
argue 6:16 7:23 37:19
add 32:3 33:5 39:3
22:10 26:4 40:9
April 20:13
additional 4:22
carefully 16:12
and/or 16:7
actual 6:19 33:6
22:22 25:9
card 13:16
apologize 4:11 6:12
2017 12:3 17:12 18:7, 10:2,5,15 12:3 13:9
20:13
cameras 21:16
answering 37:24
18:10 23:21
11,14,24 19:2,19 20:2
22:23 23:22 24:4 26:3
Amber 2:12 3:3 19:21
21:10 23:11,13 37:2 10:24 11:5,6,9 10:7 15:3
2014 10:6 34:16,22
camera 14:9,11,12
clear 38:18 44:19
clerk 10:18
call 39:15
Clerks 8:15,18
called 6:2 14:6
client 19:24 26:21
Assistant 3:6
calling 10:13,14
Collins 32:17
attach 26:14
calls 19:7 39:23
combination 30:2
8:2
cam 14:12 35:4 36:17
31:21,22
Judicial Watch Office Mayor
Hearing 11/08/2017
combinations 36:17
comfortable 26:21
comma 34:19,20,22
communicated
17:19,22
communication 19:3
23:13 36:7 39:21,24
counsel 2:17 3:6
4:15,24 5:1 10:17,20
11:18 12:24 13:2
16:19 19:8 24:2,18
39:19 41:1 44:14
counsels 17:2,7
count 32:14,15,22
33:5 38:14
communications
couple 5:5 9:2 19:1
19:14 27:21 34:18
35:20
court 2:2,4,7,14,17,
completed 23:9
completely 20:3,10
compliance 23:20
24:15
comply 22:12
computer 42:14
concern 6:6 15:22
25:22
conduct 5:23
confer 41:1 43:4
conference 43:21
conferences 24:19
conferred 12:23
23:21
conformed 12:8,10
confused 35:8
confusing 38:3,19
connected 22:7
20,23 3:1,11,16,24
4:2,19 6:6,13,14 7:6,
12,17,18 8:6,8,19,23
9:1,6,9,15,19 10:5,21, 11:2,9,13,16,18,20
12:2,5,7,11,13,17,20
13:5,14 14:20 15:1,5, 16:1,6,11,14,22
17:4,12,17,23 18:2,7,
9,21 19:20 20:13,19, 21:5,6,18,20 22:15,
17,21 23:18,23 24:17
25:5,21 26:7,19 27:4,
8,14,17 28:1,23 29:9,
13,20 30:7,10 31:2,11,
13,19 32:1,5,10 33:1,
8,11,13 34:2,4,12
35:6,10,12,16,18 36:3,
5,12,14,22,24 37:5,15, 39:20,24 40:3,11,
16,21 41:11,14,18,22, 42:4,7,12,14,22
43:13,17,23 44:2,6,8,
11,13,16,18,20
Courts 12:8 23:20
30:13
constituting 22:10
courtesy 34:9
contempt 26:24
cover 11:1 24:4
contesting 43:9
created 18:17
conversation 23:10
cross-reference
copy 8:23
Corporation 3:6
correct 3:14 10:21
11:2,12,16 12:3,4,6
21:2 36:13
correctly 9:4 18:11,
correspondence
9:20
Index: combinations..figure
37:23
custodian 11:24
25:16 30:21
custodians 9:22
10:16 12:3 13:9 15:17
20:10 22:2 26:6 31:4,
6,17,21 33:24
discussed 26:5
dash 14:8,11,12 32:20
33:3 35:4 36:17
dash-cam 29:18
34:21 36:2
date 5:21 10:23 26:1,
10,12
dated 17:8
day 15:11 19:24 24:1
25:8
days 5:5,16 14:19
29:6 39:7
deadline 5:10 6:11
deal 43:7
dealing 4:4
December 10:7 21:3
Emanuel 34:20
discussing 23:4
employees 10:1
discussion 25:6
encapsulated 7:4
disk 10:5
encompass 13:20
dismiss 9:7
disrespectful 7:17,
document 2:24 26:9,
deep 7:8
deeply 4:9
defendant 3:7 24:11
defendants 4:21
defendants 24:12
definition 22:3
delay 42:24
Demacopoulos 6:10
department 14:14,15
15:7 29:5
departments 28:5,14
39:14 41:3
determine 9:8 32:16
dialogue 21:7
difference 32:21
41:18
difficult 14:17
directly 8:17 41:1
discourage 40:9
8:8
evidently 5:14
dozens 21:11
due 4:24 5:16 6:7
exact 15:15 19:12
26:1
exchanges 26:3
15:14,15
duplicates 32:24
excited 22:19
duplicative 37:24
exclamation 13:11,
Dyke 10:8,9 11:22,23
13:8 22:3 33:18 36:18, 38:11,16
17,21 14:1,3,7 30:3
33:15 38:9
exemptions 11:5
24:7 25:12 43:9
decision 29:20
dedup 34:7
entertained 12:11
entire 4:23 7:19,24
18,19
34:16
decisions 8:3,10
39:12
e-filing 17:6
e-mail 14:2,4,5 15:8, 17:8,15,18 18:11,
12,24 19:4 22:15,20,
21,22 23:1,21 24:2,14, 25:3 26:2 27:15,17
29:3 30:1 33:2,20,22
37:1 39:4 41:13 42:18
e-mailed 4:24 5:1
25:8
e-mails 7:1,5,8 9:12, 10:17 11:4 14:16
16:7,17,18 17:3 18:15, 19:13,20 20:4,15,
16,23 21:4,7,23 22:2,5
23:17 24:12 26:24
27:2 28:5,14 32:14,17, 33:6,17,19,24 34:6
35:2 36:6,16 38:12,14
39:3 40:6 41:5
earlier 17:14,19,22
exhibit 6:1,2 14:23
exhibits 7:5 26:8
explain 33:16
explained 19:9
explaining 5:9
explains 15:6
expressed 19:15
22:8
extension 2:21 3:17, 4:5,13,18 5:4,5
6:15 7:22
extent 15:16
fact 6:22 21:23 31:5
38:22
fall 35:12
falls 37:6
22:23 26:2
fault 4:10
early 16:5
feel 26:21
elderly 44:5
felt 9:9
elicit 21:10
figure 33:7
Judicial Watch Office Mayor
Hearing 11/08/2017
file 3:17 4:14 5:3,18
6:15,19 7:21 8:12,16,
17,21 24:14
filed 3:19,22 4:10 7:4
8:14,15,19 21:20
filings 9:3
finally 24:3,13
find 11:4 16:23 41:7
42:21
finding 28:18
fine 7:20,22 36:3
Index: file..March
23:14,15 27:9 40:21
giving 14:14 20:5
good 2:1,2,12,14,15
5:7,8,17 43:19 44:8
granted 5:18
great 20:18 31:9,11
39:21 40:1 44:12
guess 4:4 6:6 10:22
25:21 26:19 29:9 32:6
35:8 43:7
guys 2:17 43:17
12:15 14:24 16:21
20:17 27:23 28:24
30:4 33:16 38:4 39:16
40:5,24 42:11 43:15
flippant 8:5
language 34:17 35:14
Honors 12:21 28:4
inquiry 33:11 35:1
Laquan 10:7,13 11:22
hook 42:1
inspection 43:10
huge 22:1
instanter 8:19,21
hundred 6:24 7:3
insufficient 28:2
10:1 17:21 19:11 22:4
23:4,16 25:1,10 41:14
hundreds 31:8
floor 8:21
hand 15:3
fly 8:3
handed 10:23
FOIA 9:11 11:21 22:12
29:21 34:15,17 35:12, 36:9 37:3,7 40:8
follow 11:3 27:9
handled 4:23
happy 6:15 7:15
27:20 41:1 42:7,24
follow-up 19:20
hard 44:5
force 24:14
head 15:15 23:18
form 42:22
hear 8:2 24:15 42:3
formal 21:20
heard 24:16 40:13
format 20:1
hearing 5:6 8:20
found 11:8 28:8 39:14
fourth 14:9
24:17 28:4
helpful 23:8 25:17
27:7 40:12,14
intending 5:3
interested 13:4 26:23
29:14,16,17,22 35:1,9,
13:7 19:17 22:3,6
28:7,16 29:17 33:9,15,
18,22,23,24 34:22
35:3,22 36:18 37:9,10
38:6,11,16,21 39:12, 40:7,13 41:5
large 15:16
lawsuits 23:14
interesting 5:14
layers 32:5,7
interpretation 16:9
learning 40:15
interrupt 27:6 41:6
leave 5:18 8:16 44:3
identified 9:21
involved 10:3
letter 11:1 13:19 23:2
identify 3:2 9:22
issue 10:6 25:12
half 30:24
innovation 15:8
input 15:11
44:11
flavor 15:18
initially 27:22 34:8
idea 27:7,9,15 29:15
31:1
15:17 31:16
immediately 30:13
important 8:13
issues 21:15 40:18
items 33:4
in-boxes 9:24
in-camera 43:10
inaudible 27:24
Jason 38:16
incident 10:12,13,14
judge 2:10,24 6:10
22:7 28:16,19 36:5,8, 39:8
include 20:5,6 31:22
32:8 36:16,18
24:5
letters 13:18
light 21:17 23:13 37:2
limit 33:14 37:9 43:14
limited 11:23 31:3,5
34:15,19,23 35:24
36:5 37:8
linked 15:5
Listen 16:12
7:20
judgment 5:11
judicial 2:16 3:10
7:19 29:15
long 15:11 22:24
42:24
lot 19:23 25:14 30:22
frankly 27:21 39:20
hey 42:19
includes 36:7 38:10
July 24:11,13
lots 21:14
Friday 18:13 20:1
hit 30:18 32:13,15,22
including 22:9 34:19,
June 9:15,16,17,20
love 44:9
30:17 43:20,22
33:5 34:8 38:14 41:11
front 27:23 28:9
hitch 30:13
increasing 37:7
function 13:12
hits 6:2,5 7:3 17:21
indecipherable
gave 10:19 15:12 20:7
generate 25:14 41:7
19:11 21:11 22:4,5
23:5,7,12 25:1,4,10,
13,16 26:17 28:19
29:2 30:2,21 31:3,8
33:10,14 36:20 37:7, 41:7
generated 29:3
Hold 11:18,20 25:5
generates 25:18
holding 26:24 33:21
give 2:21 6:14 7:22
holiday 30:17
9:4 14:23 15:18 16:2,
15,21 20:2 21:13
Honor 2:1,5,12 4:6
17:16 32:19
index 43:6
10:4,17 11:6 12:2,3
20:2,4,20 21:1 24:4,10
43:6
jury 5:11
made 24:21 41:3
magnitude 14:16
individual 41:17
inform 9:16
kinds 42:16
information 18:5
King 28:9,10
23:2 29:24
informed 8:3 14:16
initial 16:20 26:4,13
41:4
knowing 25:15
15:19
make 8:2,10 9:3
18:13,18 19:4 29:21
32:2,6,12 41:18 43:2
March 6:22,23 18:9,
11,14 19:2,19,21,22
20:2 23:21 24:1,2 26:3
42:8,10
Judicial Watch Office Mayor
Hearing 11/08/2017
Mayor 3:13 34:19,20
Index: Mayor..recall
morning 44:3
Mayors 3:3,13,15,16
motion 3:17 4:5,13,18
4:5 9:23 21:15 26:24
28:4 29:14
5:23 6:17,21 7:4 9:7
Mcdonald 19:17
28:16 29:17 34:22
35:3,22 37:9,10 38:16, 39:13,15,16 40:7
move 2:18
order 4:8 12:8,13,21,
moving 23:5
multiple 22:8
means 13:15 14:2
memorialization
18:22
memorialized 19:3
24:23
mentioned 13:7 21:7
named 3:6 38:24
narrow 22:14 23:6
27:12
narrowed 40:10,11
39:23 42:19
phonetic 14:22 18:15
39:16
option 14:6
35:23
Melissa 14:22 15:7
opposed 26:16 32:14
motions 5:11
meaning 19:5 24:6
34:7
phone 19:7,9 22:9,16
40:22
19:9 20:1 34:7
pick 42:19 18:9 23:20 30:13
piece 5:24
ordered 9:7 11:10,15
place 28:21
12:9
plaintiff 2:16 3:9 6:17,
original 21:3 26:5
31:23 32:4
originally 6:3 9:10,24
20:7,9 34:2
overbroad 36:14 9:22 12:9 13:2
18:22 19:15 20:17
21:8 22:8 23:19 43:8
plaintiffs 3:12 8:11
12:24 17:7 19:8 43:3
production 21:3 41:4
program 23:14
proper 6:13
propose 23:5
proposed 4:12
proposition 4:3
provide 29:2
provided 12:13
public 34:24
Pulaski 28:10,11,12
39:5,6,11 40:13
nature 25:1
normal 14:10
plan 20:1
pull 29:5 41:4
pleadings 38:23
overcome 30:15
pulling 24:8
point 5:20 9:21 13:11,
purpose 7:24 8:8
17,21 14:1,3,5,7 23:23
34:13 41:21
25:19 35:23
purposes 15:22
notably 25:7
p.m. 17:9 18:14
mentioning 32:23
noted 20:23
pages 34:10
pointed 23:24
November 5:5 6:10
paper 6:1
points 19:1 39:17
pursuant 24:2
mentions 31:6
par- 14:23
police 34:21
put 19:24
paragraph 15:3,13
position 7:13 37:21
paragraphs 22:24
possibility 37:15
parameter 37:6
prepared 8:1,2,9
23:9 39:5
merits 6:16,20 7:14
8:13 9:1
mess 12:18
met 5:10
40:15
number 6:2 19:11
26:17 30:2,20 31:3
33:6,14 37:20
numerous 11:4
Michael 18:15
parents 44:4
microcosmic 4:22
mid 5:2
minute 2:21 9:4
objection 2:20 3:19
8:11
part 17:2 20:11 24:7
partially 10:22
parties 3:1 9:7,14
23:21 43:4
10:19
previous 4:8
print 5:24 26:13
printed 6:4 26:12
25:21 43:1
question 12:7 16:12, 26:18,20 33:8 34:5
35:18 38:1 41:10,20
questions 9:2 24:5
25:20 34:14 44:18
quoting 18:18
prints 26:16
minutes 38:17
occasions 11:4 22:8
missed 10:11
occurred 28:9,11
past 28:15
prior 18:5
missing 15:21 16:11,
October 4:24 5:2,15,
pause 2:11 9:5 16:24
problem 2:7 30:15
Rahm 34:20
people 10:3,5,12
proceedings 44:22
reached 23:22 43:14
process 7:19
read 2:23 13:3 35:15
produce 6:24 20:16
reading 9:3 18:13
misspelled 28:8
Mitchell 32:18
Mm-hmm 15:24
16:13 18:1 6:7,8,9 10:6 34:16, 35:3,21,24 37:8
office 3:3,13,15,16
8:15,18 9:23 21:15
26:24 28:5 29:14
34:19
modern 31:10,12
officer 10:8
moment 4:3 16:21
officials 34:18
Monday 3:22 30:17
opinion 5:18
44:3
months 11:7,8 25:12
opponents 7:18
opportunity 23:15
38:21 39:6,12,15
perform 14:18
period 10:6
person 5:13,14,23
15:7,9
petition 3:18 4:7,21
16:20 24:14
petitioners 43:2
Phillip 3:5
27:13 34:6
produced 10:4,15,16
13:2 20:15,19,22,24
22:1 33:17,19,22,23
34:2,9 36:15 38:7,13
produces 34:10
productable 19:24
realized 39:1
reason 29:13
reasonable 13:1
22:11
reasons 5:9 21:13
recall 19:7 24:19
Judicial Watch Office Mayor
Hearing 11/08/2017
receive 11:6 43:6
received 4:2 8:23
24:3 37:11
receiving 19:23
record 3:2 12:18 13:3
25:6 31:13
recording 14:1,4,10, 21:9 23:10 34:21
35:5,6 36:2
recordings 21:16
34:24
records 23:24 24:3
34:17
red 21:17 23:13 37:2
redacted 10:18
refer 10:12 39:12
reference 38:16 40:6
replacing 13:21
reply 3:18 4:15 5:1,3
6:18 7:4 16:19 17:2,7,
representations
24:21
represented 10:24
11:5,7 24:6,8
request 4:21 9:11
16:2,15 22:12 23:6
29:21 34:15,17 35:13, 36:9 37:3,8 40:8
42:22
requested 18:2 23:3
30:1 42:4,17
Index: receive..Svenson
29:19 30:4,12 31:5,12,
15,24 32:2,6,11 33:2,
12,16 34:3,5 35:5 38:2
39:20,22 40:2,4,24
41:9,23 42:1,3,6,10,
13,21 43:15 44:7,19
rule 3:12,18,20 4:7
9:13 16:1 24:15 43:3
ruled 28:1
ruling 43:2
run 19:6 20:9 26:3
30:12 31:17 39:13
41:3
running 32:21 40:6
runs 14:15 15:8 32:12
14:15 15:8,10 20:5,6
41:2
searching 22:11 41:5
seat 8:3
seconds 2:6
seek 5:4
send 27:15
sense 18:18 19:5
separate 33:4
September 4:9 9:6
11:11,15 18:10,24
23:20 29:1,4 30:1
24:18,24 26:22
respond 24:11,12
Sam 3:8
sample 31:6
samples 31:18
shooting 10:8 19:17
response 3:17,19
sampling 31:16
refiled 6:17
reflect 19:14
responsive 36:9 37:3
reflected 5:22 16:6
39:15 40:8
relate 26:15 35:2
result 43:5
related 28:19 35:21
results 40:17
36:6,8,10 37:20
relating 34:21
release 13:10,13,20, 14:3,7,8,9 29:23
30:3 32:15,20 33:3,14, 34:23 35:4 36:16
37:2 38:9,15
released 13:22
releases 13:22
releasing 13:22,23
38:7
remember 24:20
repeat 12:20
rephrase 38:3
reveal 35:20
review 28:13
reviewed 20:16
rightly 39:17
Ritter 2:4,12,13 3:3,15
4:6 5:20 6:7,12 7:6,11, 8:4,7,16,22 9:18,20
11:12,14 12:1,4,6,10,
17,19,21 13:6,15
14:21 15:2,6,22,24
16:3,8,13,16,23 17:1,
5,13,18,24 18:1,4,8,20
19:1 20:8,15,22 21:2,
5,6,19,22 22:16,18,22
25:9,22,24 26:11 27:6,
8,11,14,16,19 28:3
spelled 10:9 13:14
28:7 38:22 40:14
spelling 14:8,9,10
spoke 26:1
spring 16:3
stamped 17:5 42:15
start 2:8 4:3 15:17
18:18 19:5 28:21
step 2:4
responding 20:4
referring 30:5 39:7
21:16
stated 24:4 40:5
references 17:14
4:5,6,10,12,16,17,23
5:16,19 6:7,15,16,19
7:21 8:12,14 9:13
11:21 12:2,3 14:22
19:22 20:14 21:21
specifically 19:16
setting 7:24
sheet 6:4
39:10 23:11
started 19:19 21:24
responded 25:2
referred 16:18 28:12
specific 11:14 12:15,
set 4:7,8 21:9
referenced 22:23
38:21
speaking 19:7
shell 2:5 26:11 32:16,
respect 7:12 20:18
37:21
searches 9:10 11:24
28:9,10,12 34:22 35:3,
21,24 37:9 39:6,10
stick 7:12 29:11
stop 7:6
stress 43:14
strike 6:8
Santell 2:5,10,19 3:5
shortly 42:8
subjects 23:12
satisfy 9:11
show 3:12,18 4:7 6:2,
submit 21:6
scenario 10:4 9:13 16:1 18:2 43:3
schedule 4:8 8:1,9
shown 5:7,8,17
screen 26:13
shows 28:15
search 5:15,21,24
shut 31:8
6:3,4 7:1 9:8,9,23
10:7,15 11:10,15,22
12:5,8,12,14,16,22,23
13:6,9,12 14:14,17,18
15:11,12,16,19 16:4
17:10,20 18:16,22
19:6,10,16,18 20:23
21:8,9 22:5,9,13,14
23:3,22 24:8 25:17
26:4,5 27:12,22 28:4,
6,17,18,20 29:3,11,23
30:5 31:17,23 32:12,
13,14 35:6,19 36:8,14
37:5,10 38:9,10,18,20
39:2 40:9,10,22 41:12
42:5 43:5
searched 10:16 20:9
37:13
shuts 14:18
side 17:6
significantly 22:10
23:6 33:6
similar 28:5
simply 22:10 30:5
single 27:17
size 15:16
slash 36:18
Slow 12:17
sound 8:5
space 10:10 11:23
13:8 36:19
Subsequent 9:14
substance 7:9,14
substituted 13:18
sufficient 9:11
sufficiently 23:11
suggest 12:22 27:19
28:21 39:11 41:2
suggested 12:23
27:11,18,22 32:19
38:17
suggesting 29:15
summary 5:11
summer 16:5
supplied 23:2
Svenson 2:1,3,9,15, 3:8,21 4:1,19,20
7:13 8:24 10:22 11:3,
17,19 17:8 18:14
20:21 22:23 23:18,19
Judicial Watch Office Mayor
Hearing 11/08/2017
25:7 26:19 27:1 28:22, 29:9,12 30:8,11,23
34:14 35:8,11,14,17
36:1,4,10,13,20,23
37:4,12,18 40:12,20
41:6,12,16,19 43:12, 44:1,3,9,12,14,17,
system 13:13 30:14
31:9,10,12 42:14
systems 14:19
tailored 19:17
takes 4:17
talk 6:19
talking 16:4 41:16
talks 38:7
targeted 37:8
tech 29:5
Index: system..yields
Thanksgiving 44:1
unwelding 19:11
thing 4:4 21:6 39:23
updates 20:13
work 12:14 15:10
thinking 13:23
thought 10:3
thousand 6:24 7:3
17:21 19:12 20:15,16
21:4 22:4 23:4,16
25:1,10 41:15
thousands 21:10,11
23:12 28:13 31:8 34:3
Thursday 43:18,20,
validate 42:12,16
worked 9:22 10:2
validations 42:15
works 32:15
Van 10:8,9 11:22,23
written 6:19
13:7,8 22:3 33:18
36:18 38:11,16
Vicasia 19:9
time 2:21 3:17,20 4:5,
10,13,18,22 6:15 7:21
10:6 18:21 19:15
20:18,22 24:16 25:7
26:13,16 27:13 28:3
30:22 34:8 40:13,19
42:15 44:15
today 3:11,19,23 6:17
8:20 15:23 30:16
40:15,24 41:1 43:1
victim 39:9
years 24:20 28:15
Victor 3:9
yesterdays 23:2
video 14:7,10 32:16
yield 17:20 18:23
33:3,15,21 34:24 35:4
36:17 38:8,10,15
videos 29:17,18
viewing 2:24
voluminous 23:13
technology 15:8
tomorrow 19:23
teeth 24:8
top 15:15 34:11
telephone 24:19
tough 34:5
wait 2:6,8 43:19
telling 6:23 7:2 26:8
town 43:21 44:4
wanted 9:23 13:24
tendered 37:23
trials 5:12
tens 21:11 28:13
true 19:13 21:18
term 13:24 25:14,17
turned 9:15,16,17 11:10,15,22 12:5,9,
12,15,16,22,24 13:6, 14:14 15:12 16:4
18:12,16 19:10,16
20:6,9,23 21:8,9 22:5,
9,13,14 23:6,10,15,22
26:4,5 27:12,18,20,22
28:6,7,17,18,20 29:11,
15,23 30:3,21 31:23
32:8,9,13,22 35:7,19
36:8,14 37:6,13,14,16
38:12,19,20 39:18
40:6,7,16,18,22 41:12
43:5
wrong 38:22 40:14
versus 32:22
told 5:3 17:14
terms 7:1 9:8,10 10:7,
30:23
workable 43:5
technical 30:15
29:3 30:5,18 32:19
37:10 38:9 39:2
35:4,19 36:16 38:13, 39:11
typically 5:8
typos 10:11
understand 8:4 27:4
32:2,7 35:18 36:22
38:2 39:22
understanding
32:12
understood 27:21
unpredictable 4:11
unrelated 20:10
21:13 23:12
yielded 26:17 30:2
41:4
yielding 19:10 28:19
yields 17:20 23:4,7
25:1
15:16
Watch 2:16 3:10
29:16
ways 39:12 42:16
Wednesday 30:16
44:7
week 40:23 43:17,23
19:18 23:12 35:19
43:5
44:2
well-versed 15:10
wild 13:16
withheld 10:18
word 10:9 11:23 13:20
14:2,3,12 22:6 28:8,10
29:23 30:3 33:10
36:18
wording 15:15
words 13:19,23 14:5
21:9 22:2 23:15 33:9