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

JW vs Office of Mayor Hearing Nov 8, 2017 Full

JW vs Office of Mayor Hearing Nov 8, 2017 Full

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

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Tags:Mayor Rahm Emanuel, 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -22 MS. SVENSON: Sure. THE COURT: read it. (Judge viewing document.)
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Judicial Watch Office Mayor
Hearing 11/08/2017 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.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -13 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -12 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 -18 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?
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -17 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -12 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 -19 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.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -21 THE COURT: But whats missing from her affidavit, Ms. Ritter, and what concern for purposes today -24 MS. RITTER: Mm-hmm.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -11 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 -21 Let just Give moment, your Honor. THE COURT: Sure. MS. RITTER: can find them. (Brief pause.)
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -12 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -13 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.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -20 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 (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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -18 THE COURT: not sure that thats true. MS. RITTER: But this -20 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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: -18 MS. RITTER: No. sorry. apologize for getting excited here. But think the e-mail and its -21 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -12 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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?
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -14 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 -24 (inaudible).
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -23 THE COURT: Yes. MS. SVENSON: your Honor.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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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Judicial Watch Office Mayor
Hearing 11/08/2017 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
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Judicial Watch Office Mayor
Hearing 11/08/2017 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 -11 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. -19 THE COURT: Heres what were going Ms. -20 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.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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.
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Judicial Watch Office Mayor
Hearing 11/08/2017 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.
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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 -12 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.
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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?
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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.
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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 -20 THE COURT: Well, quite frankly, Ms. Ritter, you -21 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
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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.
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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 -12 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.
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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, -17 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?
YVer1f
Judicial Watch Office Mayor
Hearing 11/08/2017 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.)
Judicial Watch Office Mayor
Hearing 11/08/2017 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
Judicial Watch Office Mayor
Hearing 11/08/2017
29th 19:21,22
actual 6:19 33:6
appears 18:11
add 32:3 33:5 39:3
24:1,2 26:8
Index: 1..Citys
appropriately
addition 13:7 23:1
additional 4:22 33:9
100,000 18:23
10th 4:24 24:11 17:1,6 26:8
30,000 25:18
3:19 17:9
11th 4:9
12:49 18:14
3rd 18:14 19:2
14th 34:16
addressed 29:7
advising 26:16
affidavit 5:9,13
15th 6:9 44:8,11 17:1,6
16th 43:20
5,000 25:18 34:8
43:20
address 4:15
advice 23:8
12th 5:15,21 6:7,8
17th 24:11,13
11:10,14 12:8,12
28:6 40:22 41:5
41:20
5th 5:5 6:10
14:21 15:4,6,21
16:7,8,14 26:14
29:8 31:7
afraid 26:18
aftermath 36:1,11
afternoon 2:1,2,
12,14,15 26:8 32:15 38:9 15:3,13
37:3,4
2000 18:9
2014 10:6 34:16,22
35:3,21
2015 10:7 21:3
34:16
2016 9:6 11:13,15 10:7 15:3
75,000 25:16
7th 34:16
2017 12:3 17:12
8th 8:20 29:1,4
40:15
22:22 25:9
23rd 9:6 25:11
24th 6:9
28th 24:10
ahead 2:4,7 4:19
Akesha 18:15
Amber 2:12 3:3
amount 11:24
20:18 22:11
April 20:13
argue 6:16 7:23
argument 7:10 8:2
Assistant 3:6
attach 26:14
attached 4:12 5:9, 6:1 7:5 9:12
11:1 14:22 16:19, 26:7
attaches 17:3
attachment 14:4
August 17:9,12
18:6 22:22 25:2,9,
calls 19:7 39:23
cam 14:12 35:4
36:17
camera 14:9,11, 21:10 23:11,13
37:2
cameras 21:16
carefully 16:12
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
bazillion 34:10
case 4:23 8:14
10:10 13:16 38:23
caseload 4:11
cases 5:11
catch 10:10 10:24 11:5,6,9
20:20 21:1 24:3,6
25:13 43:6
begin 5:15
chain 34:10,11
behalf 2:16 3:6,9
chains 34:6
26:21
accept 40:3
apologies 3:21
blown 6:11
accommodating
apologize 4:11
boolean 13:12,14
apparently 30:14
calling 10:13,14
avenue 6:14
bit 2:18 38:19
accurate 5:22
called 6:2 14:6
card 13:16
answers 24:9
account 4:17
call 39:15
authored 7:9
biggest 6:6
6:12 8:7 12:19
17:15,18 22:18
26:1 31:15
16:10
arguments 4:16,
answering 37:24
44:17
broaden 38:20
Burger 28:9,10
40:8
big 15:18 17:11
44:23 22:10 26:4 40:9
burdensome
37:19
and/or 16:7
above-entitled
8:9
broad 7:1 19:10,
38:1
agreement 12:14
19:21 20:13
9:30 44:16
13:9 15:17 20:9
22:2 26:6 31:3
33:24
22nd 17:9,12 18:6
18:12 29:1 30:8
37:13
allowed 4:14 6:19
35:3,21,24 37:8
43:24
21st 43:24
agreed 11:17
21:5
20th 10:6 34:22 10:2,5,15 12:3
agreeable 13:1
23:22 42:9
18:10 23:21
18:7,11,14,24
19:2,19 20:2 22:23
23:22 24:4 26:3
agree 6:12 12:9
briefing 4:17 7:24
breath 7:8
breathe 21:24
chambers 3:22
character 13:16
Chicago 3:4
Christine 2:3,15
3:8 19:22
City 2:13 3:4,12
12:7 13:9 14:15
40:21 41:3 42:16
Citys 15:7
Judicial Watch Office Mayor
Hearing 11/08/2017
citywide 15:9
civil 38:23
claiming 24:24
clarify 10:23 30:19
Clark 14:22 15:7
16:2 18:3 25:22
26:8 30:12 31:6
37:22 38:8 42:5,20
Clarks 19:18 29:7
clean 31:14
clear 38:18 44:19
clerk 10:18
Clerks 8:15,18
client 19:24 26:21
Collins 32:17
combination 30:2
31:21,22
combinations
36:17
comfortable
26:21
comma 34:19,20,
communicated
17:19,22
communication
19:3 23:13 36:7
39:21,24
communications
19:14 27:21 34:18
35:20
conference 43:21
conferences
24:19
conferred 12:23
23:21
conformed 12:8,
confused 35:8
confusing 38:3,
connected 22:7
constituting
22:10
contempt 26:24
contesting 43:9
conversation
23:10
copy 8:23
cover 11:1 24:4
11:2,12,16 12:3,4, 21:2 36:13
correctly 9:4
18:11,13
correspondence
9:20
counsel 2:17 3:6
4:15,24 5:1 10:17, 11:18 12:24
13:2 16:19 19:8
24:2,18 39:19 41:1
44:14
count 32:14,15,22
comply 22:12
computer 42:14
concern 6:6 15:22
25:22
conduct 5:23
confer 41:1 43:4
23:20 30:13
correct 3:14 10:21
completely 20:3,
23:20 24:15
Courts 12:8
Corporation 3:6
counsels 17:2,7
compliance
15:1,5,21 16:1,6,
11,14,22 17:4,12,
17,23 18:2,7,9,21
19:20 20:13,19,24
21:5,6,18,20
22:15,17,21 23:18, 24:17 25:5,21
26:7,19 27:4,8,14, 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
37:5,15,22 39:20, 40:3,11,16,21
41:11,14,18,22,24
42:4,7,12,14,22
43:13,17,23 44:2,
6,8,11,13,16,18,20
courtesy 34:9
completed 23:9
Index: citywide..entire
33:5 38:14
couple 5:5 9:2
19:1
court 2:2,4,7,14,
17,20,23 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 10:5,21,23
11:2,9,13,16,18,20
12:2,5,7,11,13,17, 13:5,14 14:20
created 18:17
cross-reference
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
deadline 5:10
6:11
deal 43:7
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
15:14,15
duplicates 32:24
December 10:7
duplicative 37:24
21:3 34:16
decision 29:20
decisions 8:3,10
Dyke 10:8,9 11:22, 13:8 22:3 33:18
36:18,19 38:11,16
dedup 34:7
deep 7:8
deeply 4:9
e-filing 17:6
defendant 3:7
e-mail 14:2,4,5
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
directly 8:17 41:1
discourage 40:9
dash 14:8,11,12
due 4:24 5:16 6:7
dealing 4:4
difficult 14:17
dozens 21:11
discussed 26:5
discussing 23:4
discussion 25:6
disk 10:5
dismiss 9:7
disrespectful
7:17,18,19
document 2:24
26:9,12
15:8,10 17:8,15,18
18:11,12,24 19:4
22:15,20,21,22
23:1,21 24:2,14,23
25:3 26:2 27:15,17
29:3 30:1 33:2,20, 37:1 39:4 41:13
42:18
e-mailed 4:24 5:1
25:8
e-mails 7:1,5,8
9:12,14 10:17 11:4
14:16 16:7,17,18
17:3 18:15,23
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
32:14,17,18 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, 22:23 26:2
early 16:5
elderly 44:5
elicit 21:10
Emanuel 34:20
employees 10:1
encapsulated 7:4
encompass
13:20 39:12
entertained 12:11
entire 4:23 7:19,24
Judicial Watch Office Mayor
Hearing 11/08/2017
finally 24:3,13
8:8
evidently 5:14
exact 15:15 19:12
find 11:4 16:23
41:7 42:21
finding 28:18
26:1
exchanges 26:3
excited 22:19
exclamation
13:11,17,21 14:1,
3,7 30:3 33:15
38:9
exemptions 11:5
24:7 25:12 43:9
exhibit 6:1,2 14:23
exhibits 7:5 26:8
fine 7:20,22 36:3
flavor 15:18
flippant 8:5
floor 8:21
fly 8:3
FOIA 9:11 11:21
22:12 29:21 34:15, 35:12,23 36:9
37:3,7 40:8
follow 11:3 27:9
explained 19:9
follow-up 19:20
explaining 5:9
force 24:14
explains 15:6
form 42:22
expressed 19:15
formal 21:20
format 20:1
extension 2:21
3:17,20 4:5,13,18
5:4,5 6:15 7:22
extent 15:16
found 11:8 28:8
fourth 14:9
39:20
31:5 38:22
fall 35:12
30:17 43:20,22
front 27:23 28:9
function 13:12
falls 37:6
felt 9:9
figure 33:7
file 3:17 4:14 5:3, 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
granted 5:18 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
33:21
half 30:24
hand 15:3
Honor 2:1,5,12 4:6
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
Honors 12:21
28:4
huge 22:1
10:1 17:21 19:11
22:4 23:4,16 25:1, 41:14
hundreds 31:8
handled 4:23
happy 6:15 7:15
27:20 41:1 42:7,24
inform 9:16
information 18:5
23:2 29:24
informed 8:3
14:16
initial 16:20 26:4, 41:4
initially 27:22 34:8
hook 42:1
handed 10:23
index 43:6
individual 41:17
holiday 30:17
hundred 6:24 7:3
innovation 15:8
input 15:11
inquiry 33:11 35:1
inspection 43:10
instanter 8:19,21
insufficient 28:2
intending 5:3
interested 13:4
idea 27:7,9,15
29:15 31:1
26:23 29:14,16,17, 35:1,9,10
hard 44:5
identified 9:21
interesting 5:14
identify 3:2 9:22
interpretation
hear 8:2 24:15
42:3
hearing 5:6 8:20
24:17 28:4
helpful 23:8 25:17
27:7 40:12,14
hey 42:19
fault 4:10
feel 26:21 5:7,8,17 43:19
44:8
heard 24:16 40:13
Friday 18:13 20:1
fact 6:22 21:23
good 2:1,2,12,14,
holding 26:24
head 15:15 23:18
39:14
frankly 27:21
giving 14:14 20:5
great 20:18 31:9,
44:11
explain 33:16
22:8
Index: evidently..June
gave 10:19 15:12
20:7
generate 25:14
41:7
generated 29:3
generates 25:18
give 2:21 6:14
7:22 9:4 14:23
15:18 16:2,15,21
20:2 21:13 23:14, 27:9 40:21
hit 30:18 32:13,15, 33:5 34:8 38:14
41:11
hitch 30:13
hits 6:2,5 7:3
15:17 31:16
immediately
30:13
16:9
interrupt 27:6
41:6
important 8:13
involved 10:3
in-boxes 9:24
issue 10:6 25:12
in-camera 43:10
issues 21:15
inaudible 27:24
incident 10:12,13,
40:18
items 33:4 22:7 28:16,19
36:5,8,10 39:8
include 20:5,6
31:22 32:8 36:16,
17:21 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
37:7,20 41:7
includes 36:7
Hold 11:18,20 25:5
17:16 32:19
38:10
including 22:9
34:19,23
Jason 38:16
judge 2:10,24 6:10
7:20
judgment 5:11
judicial 2:16 3:10
7:19 29:15
increasing 37:7
July 24:11,13
indecipherable
June 9:15,16,17, 10:4,17 11:6
Judicial Watch Office Mayor
Hearing 11/08/2017
12:2,3 20:2,4,20
21:1 24:4,10 43:6
lots 21:14
love 44:9
jury 5:11
made 24:21 41:3
King 28:9,10
knowing 25:15
language 34:17
35:14
Laquan 10:7,13
11:22 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 39:12,16
40:7,13 41:5
large 15:16
lawsuits 23:14
layers 32:5,7
learning 40:15
leave 5:18 8:16
44:3
letter 11:1 13:19
23:2 24:5
letters 13:18
light 21:17 23:13
37:2
limit 33:14 37:9
43:14
limited 11:23 31:3, 34:15,19,23
35:24 36:5 37:8
magnitude 14:16
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
Mayor 3:13 34:19,
Mayors 3:3,13,
15,16 4:5 9:23
21:15 26:24 28:4
29:14
Mcdonald 19:17
28:16 29:17 34:22
35:3,22 37:9,10
38:16,21 39:13,15, 40:7
meaning 19:5
24:6 35:23
means 13:15 14:2
34:7
memorialization
18:22
memorialized
19:3 24:23
mentioned 13:7
21:7 23:9 39:5
Listen 16:12
mentions 31:6
long 15:11 22:24
merits 6:16,20
30:22
7:14 8:13 9:1
mess 12:18
met 5:10
number 6:2 19:11
26:17 30:2,20 31:3
33:6,14 37:20
numerous 11:4
mid 5:2
pages 34:10
paper 6:1
par- 14:23
paragraph 15:3,
minute 2:21 9:4
minutes 38:17
missed 10:11
missing 15:21
16:11,14
misspelled 28:8
Mitchell 32:18
Mm-hmm 15:24
16:13 18:1
modern 31:10,12
moment 4:3 16:21
Monday 3:22
30:17 44:3
months 11:7,8
25:12
motion 3:17 4:5,
13,18 5:23 6:17,21
7:4 9:7
motions 5:11
move 2:18
moving 23:5
multiple 22:8
named 3:6 38:24
narrow 22:14 23:6
27:12
narrowed 40:10,
nature 25:1
3:19 8:11
occasions 11:4
occurred 28:9,11
October 4:24 5:2,
15,21 6:7,8,9 10:6
34:16,22 35:3,21, 37:8
office 3:3,13,15,16
8:15,18 9:23 21:15
26:24 28:5 29:14
34:19
officer 10:8
opinion 5:18
opponents 7:18
opportunity
23:15 40:22
opposed 26:16
32:14 39:16
option 14:6
order 4:8 12:8,13,
21,22 18:9 23:20
30:13
ordered 9:7 11:10, 12:9
original 21:3 26:5
31:23 32:4
originally 6:3
9:10,24 20:7,9
34:2
overbroad 36:14
notably 25:7
overcome 30:15
noted 20:23
6:10 40:15
parameter 37:6
parents 44:4
part 17:2 20:11
22:8
normal 14:10
November 5:5
paragraphs 22:24
objection 2:20
officials 34:18
morning 44:3
15:7
mentioning 32:23
lot 19:23 25:14
microcosmic
Melissa 14:22
linked 15:5
42:24
Michael 18:15
4:22
kinds 42:16
Index: jury..plaintiffs
p.m. 17:9 18:14
24:7
partially 10:22
parties 3:1 9:7,14
23:21 43:4
past 28:15
pause 2:11 9:5
16:24
people 10:3,5,12
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, 16:20 24:14
petitioners 43:2
Phillip 3:5
phone 19:7,9
22:9,16 39:23
42:19
phonetic 14:22
18:15 19:9 20:1
34:7
pick 42:19
piece 5:24
place 28:21
plaintiff 2:16 3:9
6:17,22 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
Judicial Watch Office Mayor
Hearing 11/08/2017
plan 20:1
provided 12:13
pleadings 38:23
public 34:24
point 5:20 9:21
Pulaski 28:10,11,
13:11,17,21 14:1,
3,5,7 23:23 34:13
41:21
pointed 23:24
points 19:1 39:17
police 34:21
position 7:13
37:21
possibility 37:15 39:5,6,11 40:13
pull 29:5 41:4
pulling 24:8
purpose 7:24 8:8
25:19 35:23
purposes 15:22
25:21 43:1
pursuant 24:2
put 19:24
prepared 8:1,2,9
previous 4:8
printed 6:4 26:12
prints 26:16
prior 18:5
problem 2:7 30:15
proceedings
question 12:7
16:12,17 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
process 7:19
15,16 13:2 20:15,
19,22,24 22:1
33:17,19,22,23
34:2,9 36:15 38:7,
Rahm 34:20
reached 23:22
43:14
read 2:23 13:3
35:15
reading 9:3 18:13
produces 34:10
realized 39:1
productable
reason 29:13
19:24
production 21:3
41:4
program 23:14
reasonable 13:1
22:11
reasons 5:9 21:13
recall 19:7 24:19
proper 6:13
receive 11:6 43:6
propose 23:5
received 4:2 8:23
proposed 4:12
5:1,3 6:18 7:4
16:19 17:2,7,8
recordings 21:16
representations
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
references 17:14
38:21
referred 16:18
28:12 39:10
referring 30:5
39:7
refiled 6:17
reflect 19:14
16:6
relate 26:15 35:2
produce 6:24
produced 10:4,
reply 3:18 4:15
10,11 21:9 23:10
34:21 35:5,6 36:2
reflected 5:22
44:22
20:16 27:13 34:6
recording 14:1,4,
referenced 22:23
10:19
print 5:24 26:13
Index: plan..search
24:3 37:11
proposition 4:3
receiving 19:23
provide 29:2
record 3:2 12:18
13:3 25:6 31:13
related 28:19
35:21 36:6,8,10
37:20
24:21
represented
10:24 11:5,7 24:6,
request 4:21 9:11
16:2,15 22:12 23:6
29:21 34:15,17
35:13,24 36:9
37:3,8 40:8 42:22
requested 18:2
23:3 30:1 42:4,17
respect 7:12
20:18 24:18,24
26:22
respond 24:11,12
37:21
responded 25:2
responding 20:4
response 3:17,19
4:5,6,10,12,16,17, 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
running 32:21
40:6
runs 14:15 15:8
32:12
Sam 3:8
sample 31:6
Santell 2:5,10,19
3:5
review 28:13
scenario 10:4
reviewed 20:16
schedule 4:8 8:1,
releases 13:22
Ritter 2:4,12,13
replacing 13:21
30:12 31:17 39:13
41:3
satisfy 9:11
rightly 39:17
rephrase 38:3
run 19:6 20:9 26:3
reveal 35:20
released 13:22
repeat 12:20
ruling 43:2
sampling 31:16
results 40:17
remember 24:20
ruled 28:1
samples 31:18
result 43:5 38:7
9:13 16:1 24:15
43:3
37:3 39:15 40:8
release 13:10,13,
releasing 13:22,
rule 3:12,18,20 4:7
responsive 36:9
relating 34:21
20,24 14:3,7,8,9
29:23 30:3 32:15, 33:3,14,21
34:23 35:4 36:16
37:2 38:9,15
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
29:19 30:4,12
31:5,12,15,24
32:2,6,11 33:2,12, 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
3:3,15 4:6 5:20
6:7,12 7:6,11,16
8:4,7,16,22 9:18, 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, 19:1 20:8,15,22
screen 26:13
search 5:15,21,24
6:3,4 7:1 9:8,9,23
10:7,15 11:10,15, 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,
Judicial Watch Office Mayor
Hearing 11/08/2017
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, 30:5 31:17,23
32:12,13,14 35:6, 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
searches 9:10
11:24 14:15 15:8, 20:5,6 41:2
searching 22:11
41:5
seat 8:3
seconds 2:6
seek 5:4
send 27:15
significantly
22:10 23:6 33:6
similar 28:5
simply 22:10 30:5
single 27:17
Slow 12:17
summer 16:5
sound 8:5
supplied 23:2
space 10:10 11:23
Svenson 2:1,3,9,
13:8 36:19
speaking 19:7
specific 11:14
12:15,22 23:11
specifically 19:16
21:16
spelled 10:9 13:14
28:7 38:22 40:14
September 4:9
spring 16:3
32:16,20
sheet 6:4
shooting 10:8
19:17 28:9,10,12
34:22 35:3,21,24
37:9 39:6,10
shortly 42:8
show 3:12,18 4:7
27:11,18,22 32:19
38:17
summary 5:11
spoke 26:1
shell 2:5 26:11
suggested 12:23
slash 36:18
separate 33:4
setting 7:24
27:19 28:21 39:11
41:2
suggesting 29:15
spelling 14:8,9,10
set 4:7,8 21:9
suggest 12:22
size 15:16
sense 18:18 19:5
9:6 11:11,15
18:10,24 23:20
29:1,4 30:1
Index: searched..video
stamped 17:5
42:15
start 2:8 4:3 15:17
18:18 19:5 28:21
15,22 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
25:7 26:19 27:1
28:22,24 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, 41:6,12,16,19
43:12,21 44:1,3,9,
12,14,17,21
system 13:13
30:14 31:9,10,12
42:14
systems 14:19
started 19:19
21:24
stated 24:4 40:5
tailored 19:17
step 2:4
takes 4:17
stick 7:12 29:11
talk 6:19
stop 7:6
talking 16:4 41:16
stress 43:14
talks 38:7
strike 6:8
targeted 37:8
subjects 23:12
tech 29:5
submit 21:6
technical 30:15
shown 5:7,8,17
Subsequent 9:14
technology 15:8
shows 28:15
substance 7:9,14
teeth 24:8
shut 31:8
substituted 13:18
telephone 24:19
shuts 14:18
sufficient 9:11
telling 6:23 7:2
side 17:6
sufficiently 23:11
6:2,5 9:13 16:1
18:2 43:3
26:8
tendered 37:23
tens 21:11 28:13
term 13:24 25:14, 29:3 30:5,18
32:19 37:10 38:9
39:2
terms 7:1 9:8,10
10:7,15 11:10,15, 12:5,9,12,15,
16,22,24 13:6,10
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, 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
Thanksgiving
44:1
thing 4:4 21:6
39:23
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
6:17 8:20 15:23
30:16 40:15,24
41:1 43:1
told 5:3 17:14
tomorrow 19:23
top 15:15 34:11
tough 34:5
town 43:21 44:4
trials 5:12
true 19:13 21:18
turned 9:15,16,17
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
unwelding 19:11
updates 20:13
thousands 21:10, 23:12 28:13
31:8 34:3
Thursday 43:18,
20,22
time 2:21 3:17,20
4:5,10,13,18,22
6:15 7:21 10:6
18:21 19:15 20:18, 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
validate 42:12,16
validations 42:15
Van 10:8,9 11:22, 13:7,8 22:3
33:18 36:18 38:11,
versus 32:22
Vicasia 19:9
victim 39:9
Victor 3:9
video 14:7,10
32:16 33:3,15,21
Judicial Watch Office Mayor
Hearing 11/08/2017
34:24 35:4 36:17
38:8,10,15
yesterdays 23:2
videos 29:17,18
19:18 23:12 35:19
43:5
viewing 2:24
voluminous
23:13 25:1
yield 17:20 18:23
yielded 26:17 30:2
41:4
yielding 19:10
28:19
yields 17:20 23:4,
wait 2:6,8 43:19
wanted 9:23 13:24
15:16
Watch 2:16 3:10
29:16
ways 39:12 42:16
Wednesday
30:16 44:7
week 40:23 43:17, 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 35:4,19
36:16 38:13,15
39:11
work 12:14 15:10
30:23
workable 43:5
worked 9:22 10:2
works 32:15
written 6:19
wrong 38:22
40:14
years 24:20 28:15
Index: videos..yields