Part 2 - May Through October

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Attachments:
Rottner, Jennifer E. <[email protected]>

Friday, May 01, 2015 5:14 PM
Collins, Adam;Rountree, Janey;Rasmas, Chloe
CPD FOIA#15-2111 Jeremy Gorner (Chicago Tribune)
FOIA#15-2110 Walsh.pdf; FOIA#15-2111 Van Dyke.pdf
Follow Up Flag:
Flag Status:
Follow up
Completed
Just FYI-this was approved by OLA, but I don't believe it has gone out. I reached out FOIA and am waiting for
confirmation on the status.
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Collins, Adam
Friday, May 01, 2015 7:11 PM
Jim Roussell;Rountree, Janey
Fwd: FOIA response on Gorner McDonald FOIA response
Follow Up Flag:
Flag Status:
Follow up
Completed
FYI for you both

-------- Original message -------From: "Holden, John" <[email protected]>
Date: 05/01/2015 5:49 PM (GMT-06:00)
To: "Maloney, Martin" <[email protected]>
Cc: "Breymaier, Shannon" <[email protected]>, "Collins, Adam"
<[email protected]>, "Darling, Leslie" <[email protected]>
Subject: FOIA response on Gorner McDonald FOIA response
HiMarty
JustwantedtocirclebackonourconversationinthepasthourtoremindyouandourMPOcolleaguesthatLawwill
sendanoticeouttoalloftheofficersnamedintheCityssettlementagreementontheLaQuanMcDonaldcaseatthe
samewesendouttheresponsetotheFOIAtoJeremyGorner(sometimeearlynextweekpresumably).Wewillalso
sendoutnoticestotheFOP,andsergeantsandlieutenantsunions,whicheachwillalsogetcopiesofthesettlement
agreement.
PerLyndaPeters,thispracticeisconsistentwithhowCPDhashandledsimilarsituations.
Letmeknowifyouhaveanyquestions.
Haveagreatweekendandletshopeforrelativecalmforourmenandwomeninblue.
JohnHolden
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Subject:
Roussel)
Friday, May O1, 2015 7:13 PM
Price; Ralph M.; Maloney; Martin
Sedevic; Mark T.
Fw: Fwd: FOIA response on Gorner McDonald FOIA response
Gentlemen, FYI below...

From: Collins, Adam [mailto:Adam.CollinsC~cityofchicago.org]
Sent: Friday, May 01, 2015 07:10 PM
To: Roussel), James M.; Rountree, Janey <]aney.RountreeCa~ciryofchicago.org>
Subject: Fwd: FOIA response on Gorner McDonald FOIA response
FYI for you both

-------- Original message -------From: "Holden, John" <John.Holden(a~cityofchicaco.org>
Date: 05/01/2015 5:49 PM(GMT-06:00)
To: "Maloney, Martin" <Martin.Malone~(cr~,chica~opolice.org>
Cc: "Breymaier, Shannon" <Shannon.Bre i~ier(a~cityofchica~oorg>, "Collins, Adam"
<Adam.Collins(c~cityoufchica~oorg>, "Darling, Leslie" <Leslie.Darlin~(a,cityofchica~o.org>
Subject: FOIA response on Gorner McDonald FOIA response
Hi Marty
lust wanted to circle back on our conversation in the past hour to remind you and our MPO colleagues that Law will
send a notice out to all of the officers named in the City's settlement agreement on the LaQuan McDonald case at the
same we send out the response to the FOIA to Jeremy Gorner(sometime early next week presumably). We will also
send out notices to the FOP, and sergeants and lieutenants unions, which each will also get copies of the settlement
agreement.
Per Lynda Peters, this practice is consistent with how CPD has handled similar situations.
Let me know if you have any questions.
Have a great weekend and let's hope for relative calm for our men and women in blue.
John Holden
This e-mail, and any attachments thereto, is intended only for use by the addressees) named herein and may
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Holden, John
Monday, May 04, 2015 3:36 PM
Patton, Stephen;Darling, Leslie
Breymaier, Shannon;Collins, Adam
WSJ and Zekman inquiries on police settlements
HelloAll
IgotaphonecallthisafternoonfromWallStreetJournalreporterZushaElinsonwhoinformedmeheispartofateam
workingonastoryaboutwhatthetop15lawenforcementagenciesinthenation(policeandsheriffsdepartments)
havebeenpayingoutinsettlementsandjudgmentsstemmingfromallegedpolicemisconduct.
Hehadalreadybeenonourwebsitelookingatthesettlementandjudgmentdatawepostedandinquiredastothe
meaningofsomeofthenomenclatureweareusingonthespreadsheet,CPDSAandCPDPP.(Ihavenotsharedthisyet,
butFYI,thetermsstandforCPDSquadAccidentandCPDPolicePractice.)
ElisonalsohadseenpastnewscoverageoftheLaQuanMcDonaldsettlementandsaidhehadafewquestionsonthat
matterincluding,whywesettledbeforeasuitwasfiledandwhywehaveprecludedthereleaseofthevideo,bothof
whichwehaveansweredpreviouslyandtowhichwrittenanswerscanbesupplied.
Finally,heaskediftherewereanyrecentorcurrenteffortsunderwaytotrytominimizetheCitysexposureonalleged
policemisconductcases.
MinuteslaterIgotacallfromPamZekmanaskingaboutthesameexactcodesontheCityswebsite.Shealsoasked
throughwhichdepartmentclaimsaresubmittedbecauseshewasplanningtoFOIAtheoriginalclaimsthatwerefiled.I
toldherIwouldseewhatIcouldlearn.
John
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Attachments:

Monday, May 04, 2015 8:30 PM
Fw: FOIA Request 15-2313 Gorner
15-2313 Gorner b,c, div.doc; file redacted.pdf
Follow Up Flag:
Flag Status:
Follow up
Completed
FYI
From: Haughey, Thomas R.
Sent: Monday, May 04, 2015 07:55 PM
To: Diaz, Martha-Victoria <[email protected]>
Cc: Maloney, Martin; Rottner, Jennifer E.
Subject: FOIA Request 15-2313 Gorner
Good evening:
Please review the attached letter to Mr. Jeremy Gorner, Chicago Tribune. Mr. Gorner requested the entire personnel file
of Officer Jason Van Dyke #9465.
P.O. Thomas Haughey

Office of Legal Affairs, Unit 114
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Cc:
Subject:
Holden, John
Wednesday, May 06, 2015 6:35 PM
Breymaier, Shannon
Wall Street Journal story will not run tomorrow
ThereportersaidtheyhavebeenheldupwaitingforinformationfromtheCityofPhoenix,butheisstillhopefulthat
theywillhavethatresolvedtomorrowandthatthestorywouldrunFriday.
HealsoinformedmethattheLaQuanMcDonaldsettlementwillbefeaturedinthestory,andthattheyhavetalkedto
independentobserversincludingtriallawyersandacademicsaboutthesizeofthesettlementandthatsomehave
opinedthatthecurrentclimateinthenationandthepowerofvideosmaybemakingsettlementsmuchhigherforallin
theyearsahead.
HeaskedifitwouldbepossibletogetStevestestimonyfromtheFinanceCommitteeonthematteroratthevery
leasttheportionofthetestimonythatmightaddresswhythematterwassettledwithoutsuitandtheysizeofthe
settlement.ForconsiderationinresponsetothatisthepassagebelowfromtheconclusionofStevespresentationto
theFinanceCommittee:
TheproposedsettlementwasinitiatedbythecounselfortheEstate,whoexpressedthedesiretoresolvethecase
withoutlitigation.Itiscomparabletoothersettlementsinfatalshootingsinwhichtheevidenceinsupportofliability
weighedstronglyinfavorofthedecedent.Thesettlementavoidslongandcostlylitigation,includingsubstantial
attorneysfeesandotherlitigationcosts.
Ilookforwardtoyourthoughts.
From:
Sent:
To:
Subject:
Holden, John
Breymaier, Shannon;Darling, Leslie
Re: Wall Street Journal story will not run tomorrow
Itoldhimthatwaslikelythecase.Soitsjustthehighlightedpassagewearelookingatfortheresponse.
From:Breymaier,Shannon
Sent:Wednesday,May6,20157:30:08PM
To:Darling,Leslie
Cc:Holden,John
Subject:Re:WallStreetJournalstorywillnotruntomorrow
Thenthat'stheanswer,
From:Darling,Leslie
To:Breymaier,Shannon
Cc:Holden,John
Subject:Re:WallStreetJournalstorywillnotruntomorrow
OnMay6,2015,at7:24PM,Breymaier,Shannon<[email protected]>wrote:
Wedon'tusuallysharethefullscript.I'llhavetogettheexcerptapprovedintheAM
From:Holden,John
Cc:Darling,Leslie
Subject:RE:WallStreetJournalstorywillnotruntomorrow
ShannonStevewaso.k.withtheexcerptofhisquotefromhisFinanceCommitteepresentationonthe
McDonaldcase.(Highlightedbelow.)Healsowasfinewithsendingtheentiretextofhispresentation
unlessyouand/orLesliehadconcerns.
From: Holden, John

Sent: Wednesday, May 06, 2015 6:34 PM
To: Breymaier, Shannon
Cc: Patton, Stephen; Darling, Leslie
Subject: Wall Street Journal story will not run tomorrow
ThereportersaidtheyhavebeenheldupwaitingforinformationfromtheCityofPhoenix,butheisstill
hopefulthattheywillhavethatresolvedtomorrowandthatthestorywouldrunFriday.
HealsoinformedmethattheLaQuanMcDonaldsettlementwillbefeaturedinthestory,andthatthey
havetalkedtoindependentobserversincludingtriallawyersandacademicsaboutthesizeofthe
settlementandthatsomehaveopinedthatthecurrentclimateinthenationandthepowerofvideos
maybemakingsettlementsmuchhigherforallintheyearsahead.
HeaskedifitwouldbepossibletogetStevestestimonyfromtheFinanceCommitteeonthematter
orattheveryleasttheportionofthetestimonythatmightaddresswhythematterwassettledwithout
suitandtheysizeofthesettlement.Forconsiderationinresponsetothatisthepassagebelowfromthe
conclusionofStevespresentationtotheFinanceCommittee:
TheproposedsettlementwasinitiatedbythecounselfortheEstate,whoexpressedthedesireto
resolvethecasewithoutlitigation.Itiscomparabletoothersettlementsinfatalshootingsinwhichthe
evidenceinsupportofliabilityweighedstronglyinfavorofthedecedent.Thesettlementavoidslong
andcostlylitigation,includingsubstantialattorneysfeesandotherlitigationcosts.
Ilookforwardtoyourthoughts.
This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named
herein and may contain legally privileged and/or confidential information. If you are not the
intended recipient of this e-mail (or the person responsible for delivering this document to the
intended recipient), you are hereby notified that any dissemination, distribution, printing or
copying of this e-mail, and any attachment thereto, is strictly prohibited. If you have received
this e-mail in error, please respond to the individual sending the message, and permanently delete
the original and any copy of any e-mail and printout thereof.
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Subject:
Collins, Adam
Thursday, May 07, 2015 8:46 AM
Marty Maloney
Fwd: (NEWS) NY TIMES: Chicago to Pay $5 Million to Victims of Police Abuse
Follow Up Flag:
Flag Status:
Follow up
Flagged
I think we handled this right

-------- Original message -------From: NewsClips <[email protected]>
Date: 05/07/2015 8:33 AM (GMT-06:00)
To:
Subject: (NEWS) NY TIMES: Chicago to Pay $5 Million to Victims of Police Abuse
ChicagotoPay$5MilliontoVictimsofPoliceAbuse
NYTIMES//MitchSmithandMonicaDavey//May6,2015
Fordecades,theyhadwaitedforanapology.Thisgroupofblackmen,somenowgrayingandbentbyage,had
complainedofviolentabuseatthehandsofthepoliceinthe1970sand80sonthiscitysSouthSide.They
saidtheyhadbeensuffocatedwithplasticbags,beatenwithphonebooks,shockedwithcattleprods
torturetacticsmeanttoextractconfessionstocrimes.
OnWednesday,afteryearsofinvestigation,publicdebateandlitigation,theCityofChicagoexpressed
remorse.CityCouncilmembersvotedwithoutdissenttopay$5.5millioninreparationstovictimsoftorture
andabusebyagroupofofficersknownastheMidnightCrewandoverseenbyanotoriouspolice
commander,JonBurge.
Forthoseaffected,therewerealsopromisesofamemorial,psychologicalcounselingandjobtraining,and
assurancesthattheirstorywouldbetaughtinChicagoschools.
Thisisanotherstep,butanessentialstep,inrightingawrong,removingastainonthereputationofthis
greatcityandthepeoplewhomakeupthisgreatcity,MayorRahmEmanuelsaid.
Forthevictims,likeAnthonyHolmes,whospent30yearsinprisonfora1973murderhesayshefalsely
confessedtoafterbeingtortured,itmeanttheprospectofrelief.
Idontcarehowyoutrytoforgetit,howyoutrytoputittotheside,Mr.Holmessaid.Itsalwaysthereand
attimesitcomesoutonyou.Youmightbreakdownandstartcrying.
AsabroadconversationaboutpoliceconductandraceplaysoutincitieslikeBaltimoreandFerguson,Mo.,
Chicagoans,too,arereexaminingrelationswiththepolice,includingepisodesmorerecentthanthosetiedto
Mr.Burge.
OnWednesday,theCityCouncilapproveda$415,000settlementwithawomanwhosaidshehadbeen
sexuallyassaultedin2011bytwoondutypoliceofficers,whohavesinceresignedandpleadedguiltyto
criminalchargesofofficialmisconduct.Protestershaveobjectedtoadecisionlastmonthbyajudgetodrop
chargesagainstanoffdutyChicagopoliceofficerwhoshotandkilledanunarmedblackwoman,RekiaBoyd,
in2012.AndmanysaytheyareawaitingthefateofapoliceofficerwhoshotandkilledLaquanMcDonald,
whowas17andcarryingaknifewhenhewasshot16timeslastfall.
Overthepastdecade,theCityofChicagohasspentmorethan$500milliononsettlements,judgments,fees
andothercostsrelatedtopolicemisconduct,accordingtoa2014investigationbytheBetterGovernment
1
Association,anonpartisanwatchdoggroup.AndyShaw,wholeadstheassociation,saidthecitycouldhave
usedthemoneytohiremorepoliceofficersorteachers,ortobalancethecitystroubledbudget.
Morethan20yearsafterMr.BurgewasfiredfromtheChicagoPoliceDepartment,somepeopleinthecitys
toughestneighborhoodssaythatdealingswiththepolicehavegrowntense,particularlyinthelastfewyears
ascityofficialsworkedtotampdownahighhomicideratelinkedtoapervasivegangproblem.
Idontseethetimesbeingbetteratall,saidMarkClements,50,atorturevictimwhosenamewasreadat
theCouncilmeetingonWednesday.Iseethesetimesmoresoasbeingtimesofnearriot.
Latelastmonth,GarryMcCarthy,thecityspolicesuperintendent,announcedplansforatouraroundthecity
aimedatbuildingtrustbetweenpoliceandresidents.Andpoliceofficialssaytheyhaveworkedtomakeother
improvements,too:expandingbikeandfootpatrolsinneighborhoods,creatingcommunitypolicingofficesin
allpolicedistricts,andlaunchingapilotprogramforbodycameras.
Inastatement,theChicagoPoliceDepartmentsaid:JonBurgesactionsareadisgracetoChicago,tothe
hardworkingmenandwomenofthepolicedepartment,andmostimportantlytothosehewasswornto
protect.MayorEmanuelandSuperintendentMcCarthyhavezerotoleranceforanymisconduct.
ThecasesrelatedtoMr.Burgeandtheofficersunderhiscommandhadplaguedthiscityfordecades.In2010,
specialprosecutorsissuedareportcorroboratingtheabuseclaims.Bythen,though,statutesoflimitationon
abusechargeshadrunout.Instead,Mr.Burgewasconvictedin2010ofperjuryandobstructionofjustice;he
completedhisprisonsentencethisyear.
ReachedbyphoneathishomeinFlorida,Mr.Burgedeclinedtocommentonthereparations.
From:
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To:
Subject:
Attachments:

Friday, May 08, 2015 3:18 PM
FW: FOIA Request 15-2313
file redacted.pdf; 15-2313 Gorner b,c, div.pdf
Follow Up Flag:
Flag Status:
Follow up
Completed
Just FYI-this is going out.

To: Maloney, Martin; Rottner, Jennifer E.; Harris, David G.
Subject: FOIA Request 15-2313
Good afternoon:
Attached is the letter and responsive record concerning Officer Van Dyke #9465. Mr. Jeremy Gorner, Chicago Tribune,
requested the entire personnel file of the Officer. The file and letter have been approved by DOL and OLA and will be
delivered to the requestor momentarily.
P.O. Thomas Haughey

Rahm Emanuel
Mayor
Department of Police City of Chicago

3510 S. Michigan Avenue Chicago, Illinois 60653
Garry F. McCarthy
Superintendent of Police
May 4, 2015
Jeremy Gorner
c/o: Chicago Tribune
[email protected]
RE:
NOTICE OF RESPONSE TO FOIA REQUEST

REQUEST DATE:
April 24, 2015
FOIA FILE NO.:
15-2313
Mr. Gorner:
The Chicago Police Department is in receipt of your Freedom of Information Act (FOIA) request in which you
state:
"I'm filing a request under the Illinois Freedom of Information Act for the entire personnel file for
Chicago Police Officer Jason Van Dyke (Star# 9465). I've already requested records pertaining
to Van Dyke's complaint history (FOIA-15-056-118), which I'm still awaiting. But now, I'm also
requesting all records in his personnel file. This request includes, but is not limited to, any
awards, commendations and complementary letters from citizens or other law enforcement
personnel."
A request by this Office was delivered to the Human Resources Division, Chicago Police Department, for the
file you sought which yielded (46) pages of documents responsive to your request. The request was timely
responded to and an extension request of five days was delivered. You are now timely provided with the
partially redacted responsive documents.
Upon review, it was determined that your request is granted in part and denied in part, requiring certain
redactions. The redacted information is exempt from disclosure under the following provisions of the FOIA:
5 ILCS 140/7 (1)(b) Private information, unless disclosure is required by another provision of this Act, a
State or federal law or a court order.
5 ILCS 140/2(c-5) "Private information" means unique identifiers, including a person's social
security number, driver's license number, employee identification number, biometric identifiers,
personal financial information, passwords or other access codes, medical records, home or
personal telephone numbers, and personal email addresses. Private information also includes
home address and personal license plates, except as otherwise provided by law or when
compiled without possibility of attribution to any person.
5 ILCS 140/7 (1)(c) Personal information contained within public records, the disclosure of which would
constitute a clearly unwarranted invasion of personal privacy.
Information withheld under 7(1)(b) is the home addresses, personal telephone numbers, and biometric
Emergency and TTY: 9-1-1 Non Emergency and TTY: (within city limits) 3-1-1 Non Emergency and TTY: (outside city limits) (312) 746-6000
E-mail: [email protected] Website: www.cityofchicago.org/police
identifiers of private individuals. The unique computer logon identifiers and employee numbers of Department
personnel have also been withheld under this section. Information withheld under 7(1)(d)(iv) are the names
of private individuals who aided in law enforcement investigations (i.e., references provided in background
investigations). And, dates of birth, the names and addresses of former employers, and Social Security
numbers have been withheld, as well as the photocopy of the subject's birth certificate contained in the file
being withheld in full in accordance with 7(1)(c). The release of the information withheld under 7(1)(c) would
be a clear violation of the subject's privacy and would serve no legitimate purpose if released.
If you require further assistance, you may contact this office at (312) 745-5308, or by mail at the below
address.
Chicago Police Department
Attention: Freedom of Information Officer
Office of Legal Affairs Unit 114
3510 S. Michigan Ave.
Chicago, IL 60653
To the extent that you consider this a denial, you have a right of review by the Illinois Attorney Generals Public
Access Counselor (PAC). You can file a request for review by writing to:
Public Access Counselor
Office of the Attorney General
500 S. 2nd Street
Springfield, Illinois 62706
Phone: 312-814-5526 or 1-877-299-FOIA (1-877-299-3642)
Fax: 217-782-1396 E-mail: [email protected]
If you choose to file a Request for Review with the PAC, you must do so within 60 calendar days of the date of
this letter. 5ILCS 140/9.5(a). When filing a Request for Review, you must include a copy of the original FOIA
request and this letter. You may also seek judicial review of a denial under 5 ILCS 140/11.
_________________________
P.O. T. Haughey #6300
Freedom of Information Officer
3510 S. Michigan Ave.
Chicago, IL 60653
From:
Sent:
To:
Subject:
Rottner
Friday, May 08, 2015 3:50 PM
Price; Ralph M.; Maloney; Martin; Roussell; lames M.
Re: FOIA Request 15-2313
Thanks!
From: Price, Ralph M.
To: Maloney, Martin; Roussell, James M.
Cc: Rottner, Jennifer E.
Subject: FW: FOIA Request 15-2313
FYI, this is going out today
To: Price, Ralph M.
FYI
P.O. Thomas Haughey


Good afternoon:
delivered #o the requestor momentarily.
P.O. Thomas Haughey

From:
Sent:
To:
Cc:
Subject:
Attachments:
Price
Friday, May 08, 2015 3:40 PM
Maloney; Martin; Roussell; James M.
Rottner; Jennifer E.
FW: FOIA Request 15-2313
file redacted.pdf; 15-2313 Gorner b,c, div.pdf
FYf, this is going out today

To: Price, Ralph M.
FYI
P.O. Thomas Haughey


Good afternoon:
delivered to the requestor momentarily.
P.O. Thomas Haughey

From:
Sent:
To:
Subject:
Roussel)
Monday, May 11, 2015 1:38 PM
Rivera; Juan J.; Welch Iii; Eddie L.; Klimas; Robert J.; Deenihan; Brendan D.
Fw: FBI?
Gentlemen, Please see below...

From: Collins, Adam [mailto:Adam.CoilinsCa~cityofchicago.org]
To: Roussel), James M.; Maloney, Martin
Subject: FBI?
Know anything about this? I know the ST ran something last year and it was wrong...
FOP's monthly newsletter states that the FBI is conducting an apparently wide-ranging investigation into past policeinvolved shootings. The item says FBI agents have been showing up at the homes of Chicago Police officers and trying to
interview them. Apparently, this is not limited to LaQuan McDonald. Can you ask Steve whether he can confirm that
there is, in fact, an FBI investigation of police-involved shootings that goes beyond the LaQuan McDonald case. On
deadline ASAP. Hope all is well.
This e-mail, and any attachments thereto, is intended only for use by the addressees) named herein and may
contain legally privileged and/or confidential information. If you are not the intended recipient ofthis e-mail (or
From:
Sent:
To:
Cc:
Subject:
Collins, Adam
Monday, May 11, 2015 2:02 PM
Breymaier, Shannon;Franklin, Liza
Patton, Stephen;Darling, Leslie;Platt, Thomas;Holden, John;Quinn, Kelley;Rountree,
Janey
RE: Fran on police investigations?
Ok.IlldoitOTR,unlesstheressomeburningreasonpeopleseetodootherwise
From: Breymaier, Shannon

To: Collins, Adam; Franklin, Liza
Cc: Patton, Stephen; Darling, Leslie; Platt, Thomas; Holden, John; Quinn, Kelley; Rountree, Janey
Subject: RE: Fran on police investigations?
I nominate you since you have the info

Shannon Breymaier
O: 312-744-9045 C:
[email protected]
From: Collins, Adam
To: Franklin, Liza
Cc: Breymaier, Shannon; Patton, Stephen; Darling, Leslie; Platt, Thomas; Holden, John; Quinn, Kelley; Rountree, Janey
JusttalkedtoRoussellatCPDwhoconfirmedthisisnottruejustlikeitwasntwhentheSTheardthisfromsourceslast
fall.
WhogetstocallFran?
From: Franklin, Liza

To: Collins, Adam
Subject: Re: Fran on police investigations?
TheonlytimeIheardofthisiswhenIreadtherumoronSecondCityCop.
SentfrommyiPhone
OnMay11,2015,at1:36PM,Collins,Adam<[email protected]>wrote:
RoussellatCPDalsohasnotheardofthis.Heischecking.
1

Franneedstobecarefulhere.
From: Collins, Adam

To: Breymaier, Shannon; Patton, Stephen; Darling, Leslie; Franklin, Liza; Platt, Thomas
Cc: Holden, John; Quinn, Kelley; Rountree, Janey
ImonthephonewithIPRArightnow.Larryisnotaware,butIllaskScottAndotoo.
Franshouldbereallycarefulhere.TheSTranastorythatmadesimilarallegationslastfallandDOJ
actuallyissuedastatementsayingitwasnottruewhichisreallyunprecedented.

To: Patton, Stephen; Darling, Leslie; Franklin, Liza; Platt, Thomas
Cc: Holden, John; Collins, Adam; Quinn, Kelley; Rountree, Janey
+Janey
Shannon Breymaier
O: 312-744-9045 C:
[email protected]

To: Patton, Stephen; Darling, Leslie ([email protected]); Franklin, Liza
([email protected]); Platt, Thomas
Cc: [email protected]; Collins, Adam ([email protected]); Quinn, Kelley
Subject: Fran on police investigations?
We just got the following from Fran. Any idea what this is about? Doubt were in a position to
confirm, but please advise.
Thanks,
Shannon
FOPsmonthlynewsletterstatesthattheFBIisconductinganapparentlywideranginginvestigationinto
pastpoliceinvolvedshootings.TheitemsaysFBIagentshavebeenshowingupatthehomesofChicago
Policeofficersandtryingtointerviewthem.Apparently,thisisnotlimitedtoLaQuanMcDonald.Can
youaskStevewhetherhecanconfirmthatthereis,infact,anFBIinvestigationofpoliceinvolved
shootingsthatgoesbeyondtheLaQuanMcDonaldcase.OndeadlineASAP.Hopealliswell.
Shannon Breymaier
O: 312-744-9045 C:
[email protected]
From:
Sent:
To:
Cc:
Subject:
Quinn, Kelley
Monday, May 11, 2015 2:14 PM
Collins, Adam;Breymaier, Shannon;Franklin, Liza
Patton, Stephen;Darling, Leslie;Platt, Thomas;Holden, John;Rountree, Janey
RE: Fran on police investigations?
Follow Up Flag:
Flag Status:
Follow up
Completed
Great
From: Collins, Adam

To: Breymaier, Shannon; Franklin, Liza
Shesoffthe(non)story

To: Collins, Adam; Franklin, Liza
I nominate you since you have the info

Shannon Breymaier
O: 312-744-9045 C:
[email protected]
From: Collins, Adam
To: Franklin, Liza
JusttalkedtoRoussellatCPDwhoconfirmedthisisnottruejustlikeitwasntwhentheSTheardthisfromsourceslast
fall.
WhogetstocallFran?

To: Collins, Adam
Subject: Re: Fran on police investigations?
CHAIN CONTINUES AS
PREVIOUSLY PRODUCED
From:
Sent:
To:
Cc:
Subject:
Ando, Scott <[email protected]>

Monday, May 11, 2015 3:36 PM
Collins, Adam
Rountree, Janey;Merritt, Larry
RE: URGENT - FBI?
Follow Up Flag:
Flag Status:
Follow up
Completed
Theres nothing attached at the bottom.

Im guessing its an exaggeration. They are investigating the Van Dyk McDonald shooting, as we all know. I
know they are also looking into one from 2013 that the SAO told them they might want to take a look at, which
is one with involved member PO Marco Proano; there were tow subjects injured (not deceased), Delqualtis
BATES and David HEMMANS, both around 15 yrs old at the time. It happened 12/22/2013 at appr. 9451 S.
LaSalle. A broken replica gun was recovered. If they are looking at any other than those two at this time, Im
not aware of it.
ScottM.Ando
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privilegedand/orconfidentialinformation.Ifyouarenottheintendedrecipientofthisemail(orthepersonresponsiblefor
deliveringthisdocumenttotheintendedrecipient),youareherebynotifiedthatanydissemination,distribution,printingorcopying
ofthisemail,andanyattachmentthereto,isstrictlyprohibited.Ifyouhavereceivedthisemailinerror,pleaserespondtothe
individualsendingthemessage,andpermanentlydeletetheoriginalandanycopyofanyemailandprintoutthereof.
From: Collins, Adam [mailto:[email protected]]

To: Ando, Scott
Cc: Rountree, Janey; Merritt, Larry
Subject: URGENT - FBI?
HeyScott
Wereceivethebelowmediainquiry,buthavenotheardanythinglikethis.Haveyou?IknowtheSunTimesranasimilar
storylastfallandtheyhadtobacktrackbecauseitwasnttrue.Tryingtofigureoutifthisisthesamekindofissue..
FOPsmonthlynewsletterstatesthattheFBIisconductinganapparentlywideranginginvestigationintopastpolice
involvedshootings.TheitemsaysFBIagentshavebeenshowingupatthehomesofChicagoPoliceofficersandtryingto
interviewthem.Apparently,thisisnotlimitedtoLaQuanMcDonald.IsthereinfactanFBIinvestigationofpolice
involvedshootingsthatgoesbeyondtheLaQuanMcDonaldcase.
1
From:
Sent:
To:
Subject:
Breymaier, Shannon
Tuesday, May 12, 2015 10:04 AM
Holden, John;Martin Maloney;Collins, Adam
Re: Media Inquiry - NBC5
Follow Up Flag:
Flag Status:
Follow up
Flagged
No,Stevedoesn'tneedtoapprove.
From:Holden,John
Sent:Tuesday,May12,20159:54:10AM
To:Maloney,Martin;Collins,Adam;Breymaier,Shannon
Subject:RE:MediaInquiryNBC5
Thisisallstuffthathasbeensaidbefore.IdontthinkIneedtorunitbyaveryswampedSteveP.,butcantryifits
thoughttobeessential.
From: Maloney, Martin [mailto:[email protected]]

Sent: Tuesday, May 12, 2015 9:50 AM
To: Holden, John; Collins, Adam; Breymaier, Shannon
Subject: RE: Media Inquiry - NBC5
Thoughts?
The incident involving Laquan McDonald continues to be investigated by prosecutors, and as a result we cannot offer any
further comment.
The Chicago Police Department has, and continues to cooperate with external investigators and any comment could
interfere with the open criminal investigation into this high profile incident. The officer involved in the shooting has been
stripped of his police powers and remains on desk duty pending the outcome of these investigations.
From: Holden, John [mailto:[email protected]]

To: Maloney, Martin; Collins, Adam; Breymaier, Shannon
AttachedistheletterthatwassenttoGorneronFriday.Ihavehighlightedtherelevantlanguageontheissueofwhat
cantbeturnedovernowandwhy.
FYI,Ihavenotyetheardbackfromhimontheissueofnarrowinganyareasofhisrequest.

To: Collins, Adam; Breymaier, Shannon; Holden, John
Yeah, Ill send it over shortly.
1

To: Maloney, Martin; Breymaier, Shannon; Holden, John
Canyouaddsomethinginhereabouthowwewouldntwanttointerferewiththeinvestigation?
LetsgetalinewereokwithandJohnshouldrunitbyPatton

It runs tonight.
Based on my conversation with Don, it sounds like they talked to alleged witnesses who claim their statement was not
taken at the scene.
He said hes anticipating that we cant say much but wanted to reach out.

To: Breymaier, Shannon; Maloney, Martin; Holden, John
AgreeonCPDanswering.
Itssweeps,andImcuriouswhattheirstorywillsay.Idontthinktheresanynewinfooflate.Possiblyaninterviewwith
arelativeoralawyer?

To: Martin Maloney; Collins, Adam; Holden, John
Subject: Re: Media Inquiry - NBC5
Idon'tthinkthatisthelanguageweused.John,canyoupleasepullwhatwassaidpreviously?AndI'dprefercpdto
answer,notlaw,sincealltheQsareaddressedtocpd.
From:Maloney,Martin<[email protected]>
To:Collins,Adam;Holden,John;Breymaier,Shannon
Subject:MediaInquiryNBC5
Please see the questions below from Carol and Don. Not sure if we can say anything about this beyond
what I have below, but wanted to check with you
Let me know what you think. Obviously the Supt. wont be doing an interview. But I think Holden
addressed this at some point and didnt know if DOL could/should provide Carol with that info.
2
From: [email protected]
Date: May 12, 2015 at 9:17:32 AM CDT
To: [email protected]
Cc: [email protected]
Subject: Channel 5 story
Marty,
Carol Marin and I are working on a story that we anticipate will air early this week regarding the Laquan
McDonald shooting. And we have a a couple of questions:
1: Are the dashboard cameras that CPD uses in its vehicle equipped with audio recording devices?
2: Did the dashboard camera that captured video of the incident at 41st and Pulaski involving CPD
officers and McDonald have audio?
3: We would like to interview the Superintendent regarding the officer-involved shooting that night. Is that
possible?
4: If it is not, does CPD have a statement regarding the shooting and the subsequent investigation by the
FBI and the Cook County State's Attorneys office?
5: Has CPD been served with subpeonas regarding the investigation?
If you have questions you can contact me (773-793-1566) or Carol (312-545-6813).
As always, many thanks,
Don Moseley
Marin Corp Productions
NBC5 News
DePaul Documentary Project
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Subject:
Maloney
Escalante; John J.
RE: A couple of specifics about tonight's story
312-745-6110
From: Escalante, John J.

To: Maloney, Martin
Subject: Re: A couple of specifics about tonight's story
I stopped at Academy. What number can I call you at.
Sentfron7 any I~'erizon u'irele,ss -~G LTF, DROID
"Maloney, Martin" <Martin.Maloney~c~chica~opolice.org> wrote:

Ok,just take a look when you're out. Thanks.

To: Maloney, Martin
OK at Memorial Board right now.
.Sent,from n7y Verizon T~'ir~eless 4G LTE DROID
"Maloney, Martin" <Martin.Maloney~a

e,chicagopolice.org> wrote:
John,
assume this is nonsense, but wanted to get your take?
Thanks
Marty
From: dmose92480@aoLcom [mailto:[email protected]]

To: Maloney, Martin; carolmarinCa~aol.com
Subject: A couple of specifics about tonight's story
Marty,
The attorneys for the McDonald family claim:
Police officers threaten witnesses on the scene at 41st and Pulaski with arrest if they did not leave and failed to take
names or phone number from those witnesses;
further they state some witnesses were taken to Area One where "they were screamed at and told to change their
story." They also say officers did not video or audio tape those witness statements.
And one of our original questions remains about whether or not the dashboard camera on the unit that recorded the
events that night is equipped with an audio-capturing device.
Thanks,
Don
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
From: Carol Marin [mailto:carolmarinCo)aol.com]

To: Maloney, Martin
Subject: Fwd: Channel 5 story
Marty,
Below is Don Moseley's email to you.
We look forward to a response as soon as possible.
Best, CM
Carol Marin
mobile 312.545.6813
email carolmarin(a~aol.com
Political Editor/NBCS News
Political Columnist/Chicago Sun-Times
Contributor/WTTW "Chicago Tonight"
-----Original Message----From: Don Moseley <dmose92480(a~aol.com>

To: Carol Marin <[email protected]>
Sent: Mon, May 11, 2015 4:49 pm
Don Moseley
Begin forwarded message:
z
From: dmose92480(c~aol.com
Date: May 11, 2015 at 9:17:32 AM CDT
To: Martin.Maloney(a~chicagopolice.orq
Cc: Carolmarin(a~aol.com
Marty,
possible?
If you have questions you can contact me(773-793-1566) or Carol (312-545-6813).
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Subject:
Escalante
Roy; Eugene J.
FW: A couple of specifics about tonight's story
I just talked to Marty. I explained to him you were Commander of Central at the time and have good working knowledge
of what happened. I was at CPMF Board this morning. I'm at Academy now working from here and then going to PERF
Meeting at noon at County Hospital.
John J. Escalante
Chief
Bureau of Detectives
312-745-6001
From: Maloney, Martin

To: Roy, Eugene J.
Cc: Escalante, John J.
Subject: FW: A couple of specifics about tonight's story
Gene,
John said you might know more about this. I'm assuming iYs all nonsense, but wanted your take.
Thanks.
From: dmose92480Cc~aol.com [mailto:[email protected]]

Marty,
Police officers threaten witnesses on the scene at 41 st and Pulaski with arrest if they did not leave and failed to take
Thanks,
~.,
Don Moseley
NBCS News

773-793-1566
www.carolmarin.com
-----Original Message----From: Maloney, Martin <Martin.Maloney(a~chicagopolice.orq>

To: 'Carol Marin' <carolmarin(c~aol.com>
Cc: DMose92480 <DMose92480(cr).aol.com>
Sent: Tue, May 12, 2015 9:03 am
Subject: RE: Channel 5 story
I'll have something today.
Thanks.
From: Carol Marin [mailto:[email protected]]

To: Maloney, Martin
Marty,
Best, CM
Carol Marin
mobile 312.545.6813
email carolmarin~a,aol.com
Contributor/VVTTW "Chicago Tonight"
To: Carol Marin <carolmarin(a~aol.com>
Sent: Mon, May 11, 2015 4:49 pm
Don Moseley
From: dmose92480na.aol.com
Date: May 11, 2015 at 9:17:32 AM CDT
To: Martin.Maloney(c~chicagopolice.orq
Cc: CarolmarinCcc7aol.com
Marty,
possible?
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Cc:
Subject:
Roy
Maloney; Martin
Escalante; John J.
Short answer yes, it is nonsense.

The case has been settled and a Federal investigation is underway into the shooting officer's actions. Perhaps thaYs a
polite way to decline responding to these spurious allegations.
Nobody was threatened or coerced.
Next, Moseley claims that "police officers" made "witnesses" leave the area of the shooting, and then he claims that these
"witnesses" were taken to the Area where they were screamed at and told to change their story, and that no video or
audio recordings were made. This is contradictory on its face.
There is no statutory requirement for witness statements to be audio or videotaped at this time. I do not believe that there
was an audio recording device on the camera we obtained the footage from.
am reaching out to the Sgt. who handled the case get more specific details on the points that Moseley inquires about.

To: Roy, Eugene J.

Gene,
Thanks.
From: [email protected] [mailto:[email protected]]

To: Maloney, Martin; carolmarinCo~aol.com
Marty,
Police officers threaten witnesses on the scene at 41 st and Pulaski with arrest if they did not leave and failed to take
Thanks,
Don
Don Moseley
NBC5News
773-793-1566
www.carolmarin.com
-----Original Message----From: Maloney, Martin <Martin.Maloney(a~chicagopolice.org>

To:'Carol Marin' <carolmarin(a~aol.com>
Cc: DMose92480 <DMose92480(c~aol.com>
Sent: Tue, May 12, 2015 9:03 am
Thanks.
From: Carol Marin [mailto:carolmarinCa~aol.com]

To: Maloney, Martin
Marty,
Best, CM
Carol Marin
mobile 312.545.6813
email carolmarin(a~,aol.com
-----Original Message----From: Don Moseley <dmose92480(c~aol.com>

To: Carol Marin <[email protected]>
Sent: Mon, May 11, 2015 4:49 pm
Don Moseley
2
Begin forwarded message

From: dmose92480Cc~aol.com
Date: May 11, 2015 at 9:17:32 AM CDT
To: Martin.MalonevC~chicagopolice.orc~
Marty,
possible?
Don Moseley
NBC5 News
773-793-1566
www.caroimarin.com
From:
Sent:
To:
Subject:
Roy
Escalante; John J.
10-4. Due to the fact that there's an ongoing investigation, I think we should issue a generic statement and politely decline
to discuss specifics.

To: Roy, Eugene J.
Subject: FV1/: A couple of specifics about tonight's story
I just talked to Marty. I explained to him you were Commander of Central at the time and have good working knowledge
of what happened. I was at CPMF Board this morning. I'm at Academy now working from here and then going to PERF
Meeting at noon at County Hospital.
John ]. Escalante
Chief
312-745-6001

To: Roy, Eugene J.
Gene,
Thanks.
From: dmose92480C~aol.com [mailto:dmose92480Ca~aol.com]

Marty,
Thanks,
Don
Don Moseley
NBC5News
773-793-1566
www.carolmarin.com
-----Original Message----From: Maloney, Martin <Martin.MalonevC~chicagopolice.orq>

To:'Carol Marin' <carolmarin(a~aol.com>
Cc: DMose92480 <DMose92480~aol.com>
Sent: Tue, May 12, 2015 9:03 am
Thanks.
From: Carol Marin [mailto:carolmarinCc~aol.com]

To: Maloney, Martin
Cc: DMose92480Ca~aol.com
Marty,
Best, CM
Carol Marin
mobile 312.545.6813
email carolmarin(a~,aol.com
To: Carol Marin <carolmarin(a~aol.com>
Sent: Mon, May 11, 2015 4:49 pm
2
Don Moseley
From: dmose92480(a~aol.com
Date: May 11, 2015 at 9:17:32 AM CDT
To: Martin.Maloney(a~chicagopolice.orq
Cc: Carolmarin(c~aol.com
Marty,
possible?
Don Moseley
NBCSNews
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Subject:
Collins, Adam
Maloney, Martin;Breymaier, Shannon;Holden, John
Follow Up Flag:
Flag Status:
Follow up
Flagged
CanyoupullallthestuffintooneemailthatIcansendaroundoverhereforawareness?Alongwithouranswer?Thanks

So Don followed up with more info (see below).
I talked to some detectives who believe this is all nonsense,

To: Maloney, Martin; [email protected]
Marty,
Thanks,
Don
1
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Subject:
Holden, John
Tuesday, May 12, 2015 12:05 PM
Patton, Stephen;Darling, Leslie;Notz, Jane
FYI on NBC5 story on Laquan McDonald investigation
JustwantedtoletyouknowthatCarolMarinatChannel5ispreparingastoryontheaftermathoftheMcDonald
investigation.CPDhasbeencontactedwiththefollowingquestionsandisfollowingupwiththestatementatthe
bottom.

Subject: Media Inquiry - NBC5
Don Moseley and Carol Marin have asked CPD a number of questions related to the Laquan McDonald shooting for a
story they are airing tonight.
The angle of their story appears to be that the attorneys for the McDonald family claim police officers threatened
witnesses on the scene at 41st and Pulaski with arrest if they did not leave and failed to take names or phone number
from those witnesses; further they state some witnesses were taken to Area One where "they were screamed at and told
to change their story." They also say officers did not video or audio tape those witness statements.
Additional questions include:
2: Did the dashboard camera that captured video of the incident at 41st and Pulaski involving CPD officers and McDonald
have audio?
3: We would like to interview the Superintendent regarding the officer-involved shooting that night. Is that possible?
4: If it is not, does CPD have a statement regarding the shooting and the subsequent investigation by the FBI and the
Cook County State's Attorneys office?
CPD detectives deny anyone was threatened to leave or told to change their story. However, due to pending litigation,
here is our proposed response:
The incident involving Laquan McDonald continues to be investigated by prosecutors, and as a result we cannot offer any
further comment.
The Chicago Police Department has, and continues to cooperate with external investigators and any comment could
interfere with the open criminal investigation into this high profile incident. The officer involved in the shooting has been
stripped of his police powers and remains on desk duty pending the outcome of these investigations.
From:
Sent:
To:
Cc:
Subject:
Maloney, Martin <[email protected]>

Collins, Adam
Breymaier, Shannon;Holden, John
Re: Media Inquiry - NBC5
Follow Up Flag:
Flag Status:
Follow up
Flagged
I'm good
Sent from my iPhone
On May 12, 2015, at 12:11 PM, "Collins, Adam" <[email protected]> wrote:
Whataboutthisforaresponse?Thefirstandsecondsentencesseemrepetitive
Ifthisworks,Illsenditaround
TheChicagoPoliceDepartmentcontinuestocooperatewithprosecutorsinvestigatingthisincident,and
wecannotofferanycommentasdoingsocouldinterferewiththeopencriminalinvestigation.The
officerinvolvedintheshootinghasbeenstrippedofhispolicepowersandremainsondeskduty
pendingtheoutcomeoftheseinvestigations.

Subject: Media Inquiry - NBC5
Don Moseley and Carol Marin have asked CPD a number of questions related to the Laquan McDonald
shooting for a story they are airing tonight.
The angle of their story appears to be that the attorneys for the McDonald family claim police officers
threatened witnesses on the scene at 41st and Pulaski with arrest if they did not leave and failed to take
names or phone number from those witnesses; further they state some witnesses were taken to Area
One where "they were screamed at and told to change their story." They also say officers did not video or
audio tape those witness statements.
Additional questions include:
possible?
CPD detectives deny anyone was threatened to leave or told to change their story. However, due to
pending litigation, here is our proposed response:
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Update_List
RE: Q&A for WTTW
WTTW.doc
Follow Up Flag:
Flag Status:
Follow up
Completed
Updatedwithprocurement
From: Collins, Adam

Sent: Tuesday, May 12, 2015 2:27 PM
To: Update_List
Subject: Q&A for WTTW
AttachedisthecurrentQ&AforWTTW.Iwanttocalloutthepensionsitemspecifically.Lisa,areyouokwiththis
languageordoyouwanttorunitbylaw?
PENSIONS/FINANCES

ruling had no effect on the citys pension reforms.
We av worked to solve Chicagos pension crisis in a way that protects taxpayers and ensures the
retirem
rved.
o
otiation and partnership on pension reforms for the

Unlike the state plan, ours was the result of negotiation and partnership with 28 unions to protect
the retirements of 61,000 city workers and retirees.

Our plan fully complies with the State constitution because it preserves and protects worker
g them.
e the State plan only reduced benefits, we increased City funding to save both funds from
certain insolvency within the next ten to fifteen years and ensure they are secured over the long
term.

Lets not get ahead of ourselves.
Fridays ruling had no effect on the citys pension reforms.
From:
Sent:
To:
Cc:
Subject:
Darling, Leslie
'Maloney, Martin';Collins, Adam;Update_List;Patton, Stephen
Rountree, Janey
RE: Press inquiry: NBC on Laquan McDonald
Follow Up Flag:
Flag Status:
Follow up
Completed
+StevePatton.

To: Collins, Adam; Update_List
Cc: Rountree, Janey; Darling, Leslie
Subject: RE: Press inquiry: NBC on Laquan McDonald
Don keeps calling on this. Barring objections, Ill move this in 10 minutes.
Thanks.

To: 'Collins, Adam'; Update_List
Cc: Rountree, Janey; Leslie Darling
Subject: RE: Press inquiry: NBC on Laquan McDonald
Any issues here? I need to get back to them soon, thanks.

To: Update_List
Cc: Rountree, Janey; Maloney, Martin; Leslie Darling
Subject: Press inquiry: NBC on Laquan McDonald
DonMoseleyandCarolMarinatNBC5areaskingCPDanumberofquestionsrelatedtotheLaquanMcDonaldshooting
forastorytheyareairingtonight.TheangleoftheirstoryappearstobethattheattorneysfortheMcDonaldfamily
claimpoliceofficersthreatenedwitnessesonthesceneat41standPulaskiwitharrestiftheydidnotleaveandfailedto
takenamesorphonenumberfromthosewitnesses.TheyarealsosayingsomewitnessesweretakentoAreaOnewhere
"theywerescreamedatandtoldtochangetheirstory."Theyalsosayofficersdidnotvideooraudiotapethosewitness
statements.
Theirotherquestionsinclude:
1:ArethedashboardcamerasthatCPDusesinitsvehicleequippedwithaudiorecordingdevices?
2:Didthedashboardcamerathatcapturedvideooftheincidentat41standPulaskiinvolvingCPDofficersand
McDonaldhaveaudio?
3:WewouldliketointerviewtheSuperintendentregardingtheofficerinvolvedshootingthatnight.Isthatpossible?
1
4:Ifitisnot,doesCPDhaveastatementregardingtheshootingandthesubsequentinvestigationbytheFBIandthe
CookCountyState'sAttorneysoffice?
5:HasCPDbeenservedwithsubpoenasregardingtheinvestigation?
CPDdetectivesdenyanyonewasthreatenedtoleaveortoldtochangetheirstory,however,thisistheCPDproposed
response
Anyissues?
TheChicagoPoliceDepartmentcontinuestocooperatewithprosecutorsinvestigatingthisincident,andwecannotoffer
anycommentasdoingsocouldinterferewiththeopencriminalinvestigation.Theofficerinvolvedintheshootinghas
beenstrippedofhispolicepowersandremainsondeskdutypendingtheoutcomeoftheseinvestigations.
From:
Sent:
Subject:
Maloney
Tomorrow's News
CBS2: Pam Zekman is partnering with Patrick Rehkamp at BGA on a story about CPD officers that have retired from the
force and come back in civilian positions across city government, including the police department. We answered her
inquiries about various employees and she was told that these civilian positions were filled, not created for former CPD
employees, and that they cannot collect a second pension so there are not additional costs to the taxpayer.
NBCS: Carol Marin is doing a story on the Laquan McDonald shooting for a story they are airing tonight. The angle of
their story appears to be that the attorneys for the McDonald family claim police officers threatened witnesses on the
scene at 41st and Pulaski with arrest if they did not leave and failed to take names or phone number from those
witnesses. CPD told her The Chicago Police Department continues to cooperate with prosecutors investigating this
incident, and we cannot offer any comment as doing so could interfere with the open criminal investigation. The officer
involved in the shooting has been stripped of his police powers and remains on desk duty pending the outcome of these
investigations.
From:
Sent:
To:
Subject:
Holden, John
Maloney, Martin;Collins, Adam;Breymaier, Shannon
RE: Media Inquiry - NBC5
Follow Up Flag:
Flag Status:
Follow up
Flagged
StevehaspubliclysaidatFinanceCommitteethatitisbeinginvestigatedbystateandfederalprosecutorsandIPRAand
thathasbeenwidelyreported.
Onarelatednote,pleaserememberthatGornergotaFOIAresponselastFridayofasettlementagreementthathadthe
namesofthecopsinvolved,includingdetectives,soitispossiblethatshoemayfallinthepressatanytime.(Eachofthe
officersandtheappropriatebargainingunitsgotnoticelastFridaythattheinformationwasbeingreleased.)Alsonote
thatKimJanssenatSunTimesFOIAdanysubpoenaswemighthavereceivedonthecase.Wesenthimanoresponsive
documentsresponselastweek,butIalsoinformedhimthatwewouldnotexpecttheneedforsubpoenasasweare
fullycooperatingandturningoveranythinginvestigatorsneed.
Regardingthenews,IbelievetheplaintiffslawyerwasexpectedtolaylowandLMsmotherhasbeenprettyadamant
aboutnotwantingtotalk.

Thats the language CPD provided at one point when everyone was inquiring.
I can call Don to see what I can get out of him.

arelativeoralawyer?

To: Martin Maloney; Collins, Adam; Holden, John
Subject: Re: Media Inquiry - NBC5
Idon'tthinkthatisthelanguageweused.John,canyoupleasepullwhatwassaidpreviously?AndI'dprefercpdto
answer,notlaw,sincealltheQsareaddressedtocpd.
From:Maloney,Martin<[email protected]>
To:Collins,Adam;Holden,John;Breymaier,Shannon
Subject:MediaInquiryNBC5
Please see the questions below from Carol and Don. Not sure if we can say anything about this beyond
what I have below, but wanted to check with you all:
The shooting that led to Laquan McDonald's death continues to be investigated by prosecutors,
and as a result we cannot offer any further comment.
Let me know what you think. Obviously the Supt. wont be doing an interview. But I think Holden
addressed this at some point and didnt know if DOL could/should provide Carol with that info.
From: [email protected]
Date: May 12, 2015 at 9:17:32 AM CDT
To: [email protected]
Marty,
possible?
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
2
From:
Sent:
To:
Subject:
Holden, John
Collins, Adam;Maloney, Martin;Breymaier, Shannon
Follow Up Flag:
Flag Status:
Follow up
Flagged
WehavelanguageweusedinapastFOIAresponseaboutwhywewouldnotwanttoreleasethevideowhile
investigationispending.Letmedigitupandsenditaround,thoughitprobablywouldjustbeforinternalinformation
only.Iftheyaresayingwitnessstatementswerenottaken,thenperhapsthatlanguagewouldnotbehelpfulhere.
From: Collins, Adam


It runs tonight.
taken at the scene.

arelativeoralawyer?

CHAIN CONTINUES AS
PREVIOUSLY PRODUCED
From:
Sent:
To:
Subject:
Attachments:
Holden, John
Maloney, Martin;Collins, Adam;Breymaier, Shannon
Gorner McDonald settlement letter 050815.docx
Follow Up Flag:
Flag Status:
Follow up
Flagged
AttachedistheletterthatwassenttoGorneronFriday.Ihavehighlightedtherelevantlanguageontheissueofwhat
cantbeturnedovernowandwhy.
FYI,Ihavenotyetheardbackfromhimontheissueofnarrowinganyareasofhisrequest.

Yeah, Ill send it over shortly.


It runs tonight.
taken at the scene.

CHAIN CONTINUES AS
PREVIOUSLY PRODUCED
From:
Sent:
To:
Subject:
Attachments:
Platt, Thomas
Bazarek, William;Price, Ralph M.
McDonald settlement
Signed Release and POA.pdf
Settlementdocs
ThomasJ.Platt
DeputyCorporationCounsel
FederalCivilRightsDivision
30N.LaSalleStreet,Suite900
Chicago,Illinois60602
3127444833
Thisemail,andanyattachmentsthereto,isintendedonlyforusebytheaddressee(s)namedhereinandmaycontain
legallyprivilegedand/orconfidentialinformation.Ifyouarenottheintendedrecipientofthisemail(ortheperson
responsiblefordeliveringthisdocumenttotheintendedrecipient),youareherebynotifiedthatanydissemination,
distribution,printingorcopyingofthisemail,andanyattachmentthereto,isstrictlyprohibited.Ifyouhavereceived
thisemailinerror,pleaserespondtotheindividualsendingthemessage,andpermanentlydeletetheoriginalandany
copyofanyemailandprintoutthereof.
1N THE MATTER OF THE ESTATE OP

LaQUAN McDONALD also lrnown as
LeQUAN McDONALD,deceased, by its
Independent Administrator, Tina Hunter
)
) Na. 14 P 7092
1
~
v.
CITY OF CHICnGO
REI.~AS~ AND SETTLEMENT AGREEMENT
Tina Hunter, mother of decedent LaQuan McDonald (also known as LeQuan McDonald),
and independent administrator of the Estate of LaQuan McDonald,(heccafter,"the Estate of
LaQuan McDonald"), by her attorneys, Jeffrey J. Neslund and Michael D. Robbins and City of
Chicago, by its attorney, Stephen R. Patton, Cocporatian Counsel of the City of Chicago, Thomas
J, Platt, Deputy Corporation Counsel, herein stipulate and agree to the following:
1.
The Estate of LaQuan McDonald 14 A 7092, Circuit Court of Coolc County, has
brought a claim against City of Chicago and its employee, Chicago Police Officer Jason Van
Dyke, Star 9465, Of~cec .Tossph Walsh, Star 12865, Detective David March, Star 20563,
Sergeant Daniel Gallagher, Star 1303, Lieutenant Anthony Wojcik, Star X81, Detective Richard
Hagen, Star 20606 and other Chicago Police officers and employees of'the City of Chicago
arising out of the fatal shooting of LaQuan McDonald on October 20, 2014 for which the Estate
of LaQuan McDonald claims damages.
City of Chicago denies Estate of LaQuan McDonald's allegations of wrongdoing
and further denies any liability.
The parties and their respective attorneys acknowledge that settlement of this
claim is not an admission of liability, or of unconstitutional or illegal conduct by oj on the part of
the City of Chicago of its future, current or former officers, agents and employees, and shall not
serve as evidence of any wrongdoing by oc on the part of the City of Chicago or its future, current
or former officers, agents and employees. The parties and their respective attorneys fujther
acknowledge that settlement is made to avoid the uncertainty of the outcome of any litigation and
the expense in time and money of litigation and for the purpose ofjudicial economy.
4,
In consideration of the he~~einafter indicated settlement entered pursuant to t11is
Release and Settleil~ent Agreement, and upon advice of counsel, the estate of LaQuan McDonald
agrees not to ale any lawsuit, claim oc cause of action of any kind at any time in any jurisdiction,
including, but not limited to, any claims under the Illinois Wrongful Death Act, the Illinois
Survival Act and claims under 42 U.S.C. 1983 against City of Chicago, Officer Jason Van
Dylce, Star 9465, Officer Joseph Walsh, Star 12865, Detective David March, Star 20563,
Sergeant Daniel Gallagher, Star 1303, Lieutenant Anthony Wojcik, Star 481, Detective Richard
Hagen, Star 20606 or of any its current, future or former officers, agents and employees with
respect to the incident set forth in paragraph one of this Release and Settlement /\greement
except solely in the event that the Chicago City Council rejects the he~einaftec indicated
settlement, with each party bearing its own costs and attorneys' fees. The Cstate of Laquan
McDonald agrees it will be required to execute this Release and Settlement agrccment prior to
the City's presentation of the settlement agreement to the Chicago City Council and that the
estate of LaQuan McDonald's offer to settle on these terms shall not be revolted ot otherwise
repudiated unless the Chicago City Council rejects the settlement agreement.
5.
The City of Chicago and Estate of LaQuan McDonald agree that the fact or
existence and terms of this settlement agreement, including but not limited to this Release and
Settlement Agreement, shall remain confidential until the Chicago City Council approves an
ordinance authorizing this agreement. The City of Chicago and Estate of i,aQuan McDonald and
its attorneys fu~~ther acknowledge and agree that there is an ongoing criminal investigation by the
federal and state authorities of the incident which is the subject of this elease and settlement
agreement ("incident"), and that potential evidence and materials ("materials") relating to this
investigation and potential criminal charges, were obtained by the Estate of LaQuan McDonald
in response to subpoenas issued in the matte of Estate of LaQuan McDonald, 14 P 7092, Circuit
Court ai'Cook County. The City of Chicago submits that relcasc or dissemination of these
materials could interfere with and have an adverse impact on the ongoing criminal investigation
and potential charges brought with respect to this incident. Estate of LaQuan McDonald and its
attorneys therefore agree not to publicly release, disclose or disseminate the materials obtained
through subpoenas issued in 14 P 7092("materials"), until the completion of the pending
criminal investigations and, if criminal charges ace brought, the conclusion of such criminal
charges by way of plea agreement, trial or dismissal, unless these materials are otherwise publicly
disclosed oc disclosed as required by law or court order. Cstate of LaQuan McDonald and its
attorneys agree that they will not make any copies oc distribute these materials to any other
persons or entities and will provide seven days written notice to the City ot'Chicago, its attorneys
oc successors prior to any publication, dissemination of release of the above mentioned materials.
6.
Estate of L,aQuan McDonald accepts a settlement fiom defendant, City of
Chicago, in the total amount of FIVC MILLION DOLLARS AND NO/100 DOLLARS
($5,000,000.00), inclusive of all costs and attorney's fees.
7.
"The City's obligations pursuant to this Release and Settlement Agreement are
conditioned upon approval of the settlement agreement by the Chicago City Council. The City
wi11 not be obligated to perform its obligations pursuant to this Release and Settlement
Agreement until the following events occur: (1)the City receives a copy of this Release and
Settlement Agreement executed by the estate of LaQuan McDonald and its attorney;(2) the
Chicago City Council enacts an ordinance authorizing settlement and payment of the funds
agreed upon in this Release and Settlement Agreement.
8.
The City agrees to pay plaintiff the total settlement amount as specified in
paragraph 5 herein within thirty (30)days of receipt by the Corporation Counsel's Office of a
fully executed settlement agreement and an ordinance of the City Council authorizing the
settlement as described in paragraph 6. This sum shall be payable solely by the City of Chicago,
and Estate of LaQuan McDonald and its attorneys agree that they will not seek payment from any
source other than the City of Chicago. The settlement check will be made payable to Estate of
LaQuan.McDonald and its attorneys and any lien claims of which the City has notice. The City
states it has no notice of any liens. Subject to court approval, the Estate may designate all or a
portion of the funds as damages on account of personal injuries oc sickness within the meaning of
Section 104(a)(2) of the Internal Revenue Code, as amended.
9.
In consideration of this settlement entered pursuant to this Release and Settlement
Agreement, Estate of L,aQuan McDonald agrees to indemnify and hold harmless the City of
Chicago, and its futu~e, current, or former officers, agents and employees including, but not
limited to, Officer Jason Van Dyl<e, Star 9465, Officer Joseph Walsh, Stac 12865, Detective
David March, Star 20563, Sergeant Daniel Gallagher, Stat 1303, Lieutenant Anthony Wojcik,
Star 481 and Detective Richard Hagen, Star 20606 from any claims, losses, damages or expenses,
including attorneys' fees and costs, incurred, or which may be incurred, by reason of any lien or
any other claim or interest held by any person, entity oc corpo~ation against any moneys received
or to be received by Estate of LaQuan McDonald under this settlement entered pursuant to this
Release and Settlement Agreement,
10.
Estate of LaQuan McDonald, upon advice of counsel, understands and agrees that
in consideration of the settlement entered pursuant to this Release and Settlement Agreement,
Estate of LaQuan McDonald does hereby release and forever discharge on behalf of himself and
his heirs, executors, administrators and assigns, all claims he had or has against Officer Jason
Van Dyke, Star 9465, Officer Joseph Walsh, Star 12865, Detective David March, Star 20563,
Sergeant Daniel Gallagher, Stac l 303, Lieutenant Anthony Wojcik, Star 481 and Detective
Richard Hagen, Star 20606 and the City of Chicago, and its future, current oc former officers,
agents and employees, including but not limited to all claims he had, has, or may have in the
future, under local, state, or federal law, arising either directly or indirectly out of the incident
whicl~ was the basis of this claim and any potential litigation, and that such release and discharge
also is applicable to any and all unnamed agents, employees, offcers or persons affiliated with
the City of of Chicago.
1 l.
This Release and Settlement Agreement and any documents that may be executed
under paragraph 13 herein contain the entice agreement between the parties with regard to the
settlement of this claim, and shall be binding upon and inure to the benefit of the panties hereto,
jointly and severally, and the heirs, executors, administrators, personal representatives,
successors, and assigns of each.
12.
This Release and Settlement Agreement is entered into in the State of Illinois and
shall be construed and interpreted in accordance with its laws. Terms contained herein shall not
be construed against a party mea~ely because that party is or was the principal drafter.
13.
In entering into this Release and Settlement Agreement, Estate of LaQuan
McDonald represents that it has relied upon the advice of its attorney, who is the attorney of its
choice, and that the terms of this Release and Settlement Agreement have been intei~pceted,
completely read and explained to the independent administrator by its attorney, and that those
terix~s are fully understood and voluntarily accepted by the Estate of LaQuan McDonald, Estate of
LaQuan McDonald also represents and warrants that no other person or entity has or has had any
5
interest in the claims or causes of action referred to herein, that the independent administrator
and its attorney have the sole right and exclusive authority to execute this Release and Settlement
Agreement and receive the sums specified herein, and that they have not sold, assigned,
transferred, conveyed, or otherwise disposed of any oi'the claims oi causes of action ceferrcd to
herein.
14.
All pairties agree to cooperate fully and to execute any and all supplementary
documents and to take all additional actions which are consistent with and which may be
necessary oc appropriate to give full force and effect to the basic terms and intent of this Release
and Settlement Agreement including compliance with any orders of the Circuit Court of Cook
County with regard to any payment or disposition of funds.
Estate of LaQuan McDonald, d~ eased

by its Indedpendent Adminstrator, Tina
/~
Hunter
~a~~~~"
Gress:
/j"
A
l'
Date of b rt
*SSN:
n J-~3
-----~-
City of Chicago
a Municipal Corporation
Stephen Patton
Corporation Counsel
Atto~ney City of Chi
~
'
.~
* aviding SSN is voluntary
hind Attainey for state

Jeffs y
of LaQuan ` cDonald
Law Offices of Jeffrey J. Neslund
20 N. Wacker Drive, Suite 3710
Chicago, Illinois 60606
(312)223-1 l00
FEIN:~ ~^~~ `'~ `~~~./
DATE: 1 ,... '-~
BY:
Thomas Platt
Attorney for City of Chicago
Deputy Corporation Counsel
30 N. LaSalle St., Suite 900
(312)744-4833
~~ ~~~ o !
Michael D. Robbins
Michael ll. Robbins and Associates
Attorney foc Estate of LaQuan McDonald
(3]2)223-1100
FEIN:
DATE:
04/68/2615
13:59
PAGE
3127819123
Lr~z~~~row~,R of.~~c o~v~

I, TINA, HUNTER,the .+ldmiz~~strator of the Estate of Laqua~ McDonald, agree to
and do
attorneys,
appoint MICIIA,EL D. ItOBBINS and JEFFREY J, NESLUNT~ as my tz~ue and lawFul
potential
and in nn.y name and stead to endozse any and all checl~s o,r drafts received. to settle all
d that could be
claims against all responsible parri.~s arising out of the death of Laquan McDonal
them in a~n.
brought against the City ofChicago and any otlaex responsible party, ar~d deposit
Attorney Client Funds 1lccount; giving and granting unto MICHAEL T~. ROBBINS and JEFFREY
d act,
3. NESLUNJ~ said attorney's, full power end au.tharity ~o do azzd perform tk~e above reference
and. to disburse those funds pursua~.t to an Au.thori~ation to Settle.
and.
This Limited. Power of Attoz~rxey will also grant; unto MICH~L A. ROBB~NS
J~FFRFY J. NLSLLTND said ~xtto~rneys, full power and. Authorization to sign any .Release ar~d
Settlement Agreements on ztty behalf.
IN 7'E5'Z"ZMONY WHEREOF, having .read the foregoing, and uzxderstand,ing ad agreeing
to same,I have set my hand. and seas. this ~ ~ day of March,2015.
~~~~~,,
TINA HUNTER,Administrator ofthe

Fstat~ of Laquan McDonald
02/02
CITY OI'CHICAGO
DIPAIt'1'MENT OF PROCUREMENT SERVICES
FINANCIAL. MANAGCMGNT PROCUREMENT SYSTTM(FMPS FORM F-SA}
R~OUEST FOR SUPPLIER CODF, NUMBER
OR
NEW/ADDED SUPPLIER INFORMATION
INSTRUCTIONS;
USE 'PHIS FORM TO RF,QUEST ADDING A NEW SUPPLIF.K OR JOINT VENTURE TO 7'HE FMPS SUPPLIER
FI[.E. A
UNIQUE SUPPLICR NUMBER WILL BE ASSIGNED. N07'F: FORWARD RF,QUEST
TO DEPARTMENT OF
PROCUIt~MENT SERVICES, UA'fA ENTRY/CODING SECTION, ROOM 403, CITY HALL, 121 NORTH.
GASALLP,,
CF#ICAGO, IL., 60620,TELEPWONE (312)744-7664 or(3l2)744-0728. FAX Nl1MBER (312)742-5597.
RF,OU~STING DENARTMF,NT INI'OR11~A'1'ION

REQUES'P DATE: April 8, 2015
RCQUF,S'I' BY: Lorraine McGregor
Ur;pnR.rm~NT Law-FCRL
'fF.I.EPIiONE N0.312-744-8977
I~AX NO.312-744-6566
ppnREss' 30 N. LaSalle, 900
SUPPLIER NO. Lorraine.mogregorQcityofchicago.org

(ASSIC=NED BY PNOCUREMENT DATA ENTRX/COOING SECTION)
~,
*NEW OR ADDF.11 SITE (Please Circic Only One)
SUPPLIER S[TC REQUEST INrORMATION
*1099 Reportin: Y
BOX 3
~ ~)~ ~ L}~ ~~ t ~1~/"}

~
j
~~'
BOX 7
BOX
Law Ofc of Jeffrey J. Neslund/Michael D. Robbins &Assoc./Esleta of La~uan McDonald by Special Admin., Tl~a Hunter
*SUPPL[EK(COMPANY or INUIVCDUAL)NAM
~I'FIN NUMBF.WSOCIAL SECURITY Nl1MBCR:
*SUPPLIER AnDRESS: 20 N, Wacker Drive, Suite 3710

*(CITY,STATE AND 7.,IP CODE): Chicago, IL 60606
"SITE NAME
(I.E.: OFFICE, HH:ADQUAIiTERS OR SALF,S): Office
SUPPLIGx:
*IEEEPNONI: NO.312-223-1100
FAX NO.
EMAIL ADDRESS'
SUP!'i.TGR CONTACT PERSON INFORMATION

SUPPLIER CUNTAC"R'PERSON NAME
with PREFIX (Mr., Mrs., Miss):
CON7'AC'I'PERSON TITLE.:
Jeffrey J. Nesiun
D. Robbers-_ -~. ~f~ .30?~
.- y~-- 33~
Attorneys
CONTACT PERSgN:
*7'GLEPHONE NO. 312-223-1100
FAX NO.
PAYMENT'ADDRESS IIF SAME.INll1CATG "SAME AS ABOVE"1

"SUPPLIER NAME I~OR PAYMCNT:
581110 8S 8bOV8
"'ACCOUNT NUMBER (1(' API'LICABLF.~:
Same as above
"SUPPLIER ADDREss: ~0 N. Wacker Drive, Suite 3710

(('ITY,STATE AND ZIP CODE):
"ASTER/SIti DENOTES REQUIRED INFORMATION"
Rev. 01/15/09
nI;l'AR'f:~Ti:N'i' C)F L,AW
CJI'I'Y OF CI-IICAGO
April H, 2Q1S
Michael D. Robbins
Michael D. Rpbbins and Associates
Jeffrey J. Neslund
Law Offices of Jeffrey J. Nes(und
Settlement in the Matter of Fstate ofLaQuan McDonald, 14 P 7092
Re:
Dear Mr. Robbins and. Mr. Neslund:

The City of Chicago's Law Department will presenC the settlement recommendation
reached in the above named case to the City Council's Finance Committee an April 13, 2015 For
approval ofthe Release and Settlement Agreement signed by all parties. If the Finance
Committee approves the agreement, it is expected that it will be presented to the full council for
approval on April l5, 2015. Corporation Counsel Stephen R. Paton is fully committed to
presenting this settlemc;nt and has advised all the perti~aent individuals of his intent. Mr. Patton
will personally present this matter to the lainance Committee on Monday assuming we have a
signed Release and Settlement Agreement.
If you have any questions or need anything further, please contact me.
Very truly yours,
i
Thomas J. Flan
City o~Chicago, Department of Law
(312)-744-4833
Pl~:i)I RAL CIVIL, R(C.:1-I'I'5 X.("t"I(>A"PION DIVt,51<)N, 8U :~, L,A3ALI,r: S't', SGI?'E ~JUA, CFTTCACO, II, f>0602
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Update_List;david spielfogel ([email protected])
Udpated WTTW Q&A
WTTW v2.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
AttachedisanupdatedQ&Afortonight.
Thebiggestchangeisonapossibletemporarybridgetorevenuefromacasino,whichIworkedwithRendinaon.Please
letmeknowifyouhaveanyquestions.Thanks
From:
Sent:
To:
Cc:
Subject:
Attachments:
Holden, John
Peters, Lynda;Rasmas, Chloe;Darling, Leslie
Breymaier, Shannon
FW: Another request.
Gorner McDonald settlement letter 050815.pdf
AnotherFOIAfromGorneronMcDonaldvideo.
Isuspectthatheisjustnotclearthatourpriorresponse(attached)tohimcoversthevideo.Doesthisrequireanother
FOIAresponseorjustaquickmessagetoJeremynotingthatthevideoiscoveredinthepriorletterasadocument.
From: Gorner, Jeremy [mailto:[email protected]]

To: Holden, John
Subject: Another request.
Importance: High
Hey John,
I'm filing a request under the Illinois Freedom of Information Act for any and all exhibits relating to the
settlement between the City of Chicago and the estate of LaQuan McDonald (Tina Hunter, his mother, is the
administrator). The settlement was for $5 million and it's a Cook County probate case under Case No. 14P7092.
The exhibits requested include, but are not limited to, any and all dashboard camera video footage from
Chicago police vehicles that captured McDonald getting shot.
If in your view any of the above records contain information you deem to be exempt from disclosure
under the privacy 7(1) (c) or work product 7 (1) (f) provisions of the Freedom of Information Act please
redact that portion of the record and provide the remainder, specifying the precise nature of the redacted
information and the specific exemption on which you would rely in the event I was to ask for its
disclosure.
Jeremy Gorner
Reporter Chicago Tribune
O: 312-222-4569
C: 312-912-3967
1
May 8, 2015
Response via email
Jeremy Gorner
[email protected]
City of Chicago
Rahm Emanuel,
Mayor
Department of Law
Stephen R. Patton
Corporation Counsel
121 North LaSalle
Street
Suite 600
(312) 744-6900
(312) 742-0277 (FAX)
(312) 744-2693 (TTY)
www.cityofchicago.org
Dear Mr. Gorner:

This letter is in response to your Freedom of Information Act (FOIA) request to
the City of Chicago Law Department which was received in our offices on
April 16, 2015. In that request, you state the following:
I'm filing a request under the Illinois Freedom of Information

Act for any and all documents relating to the settlement
between the City of Chicago and the estate of LaQuan
McDonald (Tina Hunter, his mother, is the administrator). The
settlement was for $5 million and it's a Cook County probate
case under Case No. 14P7092.
If in your view any of the above records contain information
you deem to be exempt from disclosure under the privacy 7(1)
(c) or work product 7 (1) (f) provisions of the Freedom of
Information Act please redact that portion of the record and
provide the remainder, specifying the precise nature of the
redacted information and the specific exemption on which you
would rely in the event I was to ask for its disclosure.
The Law Department filed a timely extension, and you kindly agreed to
provide the Law Department further time to timely respond.
Two documents responsive to your request, a copy of the settlement
agreement and a copy of a body chart prepared by the Cook County Medical
Examiners Office, are provided along with this letter. One home address
and one date of birth have been redacted from the settlement agreement,
consistent with Section 7(1) of the FOIA.
Section 7(1)(b) exempts from disclosure [p]rivate information, unless
disclosure is required by another provision of this Act, a State or federal law
or a court order, and the FOIAs definition of private information
specifically includes home address[es] , except as otherwise provided by
law or when compiled without possibility of attribution to any person. 5
ILCS 140/7(1)(b); 5 ILCS 140/2(c-5). The home address appears directly
below the signature of the representative for the estate of Mr. McDonald,
thereby making it attributable to a person. Additionally, there are no laws or
court orders which require disclosure of this private information.
The date of birth of the signatory has been withheld consistent with 5 ILCS 140/7(1)(c). Section
7(1)(c) exempts:
Personal information contained within public records, the disclosure of which
would constitute a clearly unwarranted invasion of personal privacy, unless the
disclosure is consented to in writing by the individual subjects of the information.
"Unwarranted invasion of personal privacy" means the disclosure of information
that is highly personal or objectionable to a reasonable person and in which the
subject's right to privacy outweighs any legitimate public interest in obtaining the
information.
An individuals date of birth is the quintessential type of highly personal information
encompassed within the Section 7(1)(c) exemption, and the individuals right to privacy of this
information clearly outweighs any public interest in its revelation.
The Law Department is in possession of certain documents gathered by one of its clients, the
Independent Police Review Authority (IPRA), pursuant to an administrative investigation into a
potential disciplinary case. The documents regarding the McDonald shooting were obtained by
IPRA from the Chicago Police Department, the Chicago Fire Department and the Office of
Emergency Management & Communications. At this time, the Law Department is unable to
provide you with any of these documents that are responsive to your request for the reasons
outlined below.
Each and every gathered document pertains to an open criminal investigation being conducted by
the Cook County States Attorneys Office and an open and active investigation being conducted
by the Federal Bureau of Investigation (FBI). At this time, all of the documents are exempt from
release pursuant to Section 7(1)(d)(vii) because disclosure of the documents would obstruct an
ongoing criminal investigation. 5 ILCS 140/7(1)(d)(vii).
Release of the requested documents could interfere with the open criminal investigation into this
high profile incident which has garnered much media attention. Among other things, the suspect
could become aware of the identity of witnesses and the specific details of their statements, and
of the evidence that has collected as of the date the documents were generated. Public disclosure
of this information could impede and obstruct the ongoing criminal investigation.
In addition, witnesses named in the documents could feel intimidated by the public release of
their identity and identifying information, which is otherwise exempt under 5 ILCS
140/7(1)(d)(iv), which permits the withholding of [r]ecords in the possession of any public
body created in the course of administrative enforcement proceedings to the extent that
disclosure would: unavoidably disclose the identity of persons who provide information to
administrative, investigative, law enforcement, or penal agencies. Disclosure could lead to the
failure of those witnesses to continue cooperating with the FBIs active criminal investigation.
In addition, the above-referenced document obtained from the Chicago Fire Department, an
ambulance record, is a medical record which is exempt under 5 ILCS 140/7(1)(b). Section
7(1)(b) provides for the withholding of [p]rivate information, unless disclosure is required by
another provision of this Act, a State or federal law or a court order. No such requirement of
2
disclosure exists here. The definition of private information under 5 ILCS 140/2(c-5)
specifically includes medical records, and it has been determined that documents containing
information about a persons medical condition and/or treatment for an injury are medical
records. See: Plain Dealer Publishing Company v. U.S. Department of Labor, 471 F.Supp. 1023,
1027 (D.D.C. 1979).
Further, the Law Department is in possession of an advisory memorandum sent by the Law
Department to the City Councils Finance Committee, however, this memorandum is exempt in
its entirety from disclosure pursuant to 5 ILCS 140/7(1)(m). Section 7(1)(m) provides:
Communications between a public body and an attorney or auditor representing
the public body that would not be subject to discovery in litigation, and materials
prepared or compiled by or for a public body in anticipation of a criminal, civil or
administrative proceeding upon the request of an attorney advising the public
body, and materials prepared or compiled with respect to internal audits of public
bodies.
The Illinois Supreme Court has determined that a public body that relies upon this FOIA
exemption is required to establish both the existence of an attorney-client relationship and that
the communications would not be "subject to discovery in litigation," meaning that the
communications fall within the attorney-client privilege. Illinois Education Association v.
Illinois State Board of Education, 204 Ill.2d, 456, 791 N.E.2d 522, 528-9 (2003). One of the
functions of the Corporation Counsel and the Citys Law Department is to provide legal advice
to the Citys officials, such as the Aldermen who serve on the City Councils Finance
Committee. This memorandum, prepared to communicate the mental impressions and advice of
the Citys Law Department regarding the McDonald shooting incident clearly qualifies as a
privileged communication which is exempt under Section 7(1)(m).
In addition, draft versions of this memorandum have been withheld in their entirety in
accordance with 5 ILCS 140/7(1)(f) as they constitute pre-decisional internal discussions and
deliberations between attorneys in the Law Department. Section 7(1)(f) exempts:
[p]reliminary drafts, notes, recommendations, memoranda and other records in
which opinions are expressed, or policies or actions are formulated, except that a
specific record or relevant portion of a record shall not be exempt when the record
is publicly cited and identified by the head of the public body.
5 ILCS 140/7(1)(f). The U.S. Supreme Court has determined that the deliberative process
exemption under the FOIA focuses on documents that reflect advisory opinions,
recommendations and deliberations comprising part of a process by which governmental
decisions and policies are formulated. NLRB v. Sears and Roebuck, 421 U.S. 132, 150-151
(1975). The purpose is to encourage frank discussion of legal or policy matters such that
employees in government feel free to express their opinions before a final legal or policy
decision is made. Memoranda where preliminary opinions are expressed and actions are
formulated are expressly exempt from production under Section 7(1)(f) of the FOIA.
Finally, your FOIA request is unduly burdensome to the extent it includes e-mails (i.e., electronic
communications which may include one or more document attachments). The FOIA provides in
5 ILCS 140/3(g) that requests for all records falling within a category shall be complied with
unless compliance with the request would be unduly burdensome for the complying public body
and there is no way to narrow the request and the burden on the public body outweighs the public
interest in the information. Your FOIA request seeks any and all documents relating to the
settlement between the City of Chicago and the estate of LaQuan McDonald. (Emphasis added.)
In order to effectively run an email search, the Law Department needs the names or email
accounts that you wish searched. The present email systems tool set cannot identify the
department where an email user works and, therefore, a search cannot be based on a department.
Parameters that would assist DOL in conducting an email search include: (1) the e-mail
address(es) of the account(s) you wish searched; (2) key words you wish to search for; and (3)
the timeframe to be searched.
It is therefore necessary that your FOIA request be narrowed and clarified to the extent you are
seeking emails. If you would like assistance in narrowing your request, please contact me, and I
will assist you. Otherwise, for the reasons provided above, the Law Department is unable to
fully respond to your FOIA request as currently drafted.
Please be advised that even if you were to narrow your request as outlined above, certain Law
Department records may be withheld from disclosure under the exemptions enumerated in the
FOIA, including but not limited to, exemptions set forth in 5 ILCS 140/7(1)(f) and 5 ILCS
140/7(m).
If you agree to narrow your request, you must submit a revised written request to my attention.
The Law Department will take no further action or send you any further correspondence unless
and until your current request is narrowed in writing. If we do not receive your narrowed request
within fourteen (14) calendar days of the date of this letter, your current request will be denied.
You have the right to have a denial reviewed by the Public Access Counselor (PAC) at the
Office of the Illinois Attorney General, 500 S. 2nd Street, Springfield, Illinois 62706, (877) 2993642. You also have the right to seek judicial review of your denial by filing a lawsuit in Cook
County Circuit Court.
Sincerely,
John M. Holden
Freedom of Information Officer
From:
Sent:
To:
Cc:
Subject:
Franklin, Liza
Peters, Lynda
Platt, Thomas;Holden, John
Re: Another request.
Thereweren'texhibitsattachedtotheagreement.
SentfrommyiPhone
OnMay13,2015,at4:28PM,Peters,Lynda<[email protected]>wrote:
Please see the below FOIA request from Trib reporter Jeremy Gorner.
Question are there any exhibits to the LaQuan McDonald settlement agreement?
Lynda A. Peters
City Prosecutor
Legal Information, Investigations & Prosecutions Division
City of Chicago Law Department
30 N. LaSalle, Suite 1720
Chicago, IL 60602
312-744-2816
Confidential and privileged communication.

To: Holden, John
Subject: Another request.
Importance: High
Hey John,
I'm filing a request under the Illinois Freedom of Information Act for any and all exhibits
relating to the settlement between the City of Chicago and the estate of LaQuan McDonald (Tina
Hunter, his mother, is the administrator). The settlement was for $5 million and it's a Cook
County probate case under Case No. 14P7092.
The exhibits requested include, but are not limited to, any and all dashboard camera video
footage from Chicago police vehicles that captured McDonald getting shot.
If in your view any of the above records contain information you deem to be exempt from
disclosure under the privacy 7(1) (c) or work product 7 (1) (f) provisions of the Freedom of
Information Act please redact that portion of the record and provide the remainder,
specifying the precise nature of the redacted information and the specific exemption on
which you would rely in the event I was to ask for its disclosure.
Jeremy Gorner
O: 312-222-4569
C: 312-912-3967
From:
Sent:
To:
Cc:
Subject:
Attachments:
Holden, John
Rasmas, Chloe;Breymaier, Shannon
Darling, Leslie
FW: NBC5 Chicago LaQuan McDonald FOIA
FOIACorporationCounsel.png
HiChloe
HereistheFOIAImentionedinmyphonemessage.Canyouadviseonwhethertheotherdepartmentsnamedinitalso
receivedsimilarrequests?
Thanks,
John
From: Stephanie Wade [mailto:[email protected]]

Sent: Wednesday, May 13, 2015 11:48 AM
To: LAWFOIA
Subject: NBC5 Chicago LaQuan McDonald FOIA
Good afternoon,
I have attached a FOIA request from NBC5 Chicago regarding the shooting of LaQuan McDonald.
What we are looking for is listed in the request.
Thank you,
Have a great day
Stephanie
Stephanie Wade
DePaul University
NBC5 Chicago
419.270.5960
1
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Schrader, Lisa
Public Safety memo
Memo for the Chief of Staff.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
Lisa,
Attachedisthetransitionmemoforthepublicsafetydepartments.Itlookslikealot,butIpromiseIlefta
bunchofstuffout!
Janey
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Schrader, Lisa;david spielfogel;Ewing, Clothilde;Quinn, Kelley;Rendina, Michael;Deal,
Joe;Fe Claypool
Re: Fran, Bill Q&A
Fran, Bill.docx
Loopingbacksoit'satthetopofinboxes.basedonherstorytoday,it'safairbetFranasksaboutvideo
gaming,commutertax,marijuana,etc.Ihavethoseallcoveredinhere.
Letmeknowwhatyouthink.Thanks
From:Collins,Adam
Sent:Wednesday,May13,201511:34PM
To:Schrader,Lisa;davidspielfogel;Ewing,Clothilde;Quinn,Kelley;Rendina,Michael;Deal,Joe;FeClaypool
Subject:Fran,BillQ&A
AttachedisaQ&Afortomorrow'sinterviews.It'slargelythesameaswhatwedidforWTTWIexpectalotof
carryoverbutIaddedsomepointsuptop.
Toplinemessagegoalsfortheinterviews
Greaterdetailonterm2
Questionsthey'veforeshadowed
Fiorettieventquestions
SpikeLee
Anyways,pleaseletmeknowfirstthingifanyonewantsadifferentdirection
Thanksmuch
From:
Sent:
To:
Subject:
Collins, Adam
Rountree, Janey
RE: Transition memos
Follow Up Flag:
Flag Status:
Follow up
Completed
You can drop chicsgo mag, criminal Regis and mental health.
-------- Original message -------From: "Rountree, Janey" <[email protected]>
Date: 05/13/2015 10:59 AM (GMT-06:00)
To: "Collins, Adam" <[email protected]>
Subject: Fw: Transition memos
Imworkingonthismemo,tryingtogetitfinishedbythedeadline.BelowismycurrentlistofpressandFOIA
issuesforthepublicsafetyagencies.Anythingyouthinki'mmissing?
a.
From:Schrader,Lisa
Sent:Tuesday,May12,20154:56PM
To:Schrader,Lisa;Deal,Joe;Rountree,Janey;Rivera,Arnaldo;Harte,Meghan;Bennett,Kenneth;Holt,Alexandra;Scott,
Lois
Cc:davidspielfogel;Ewing,Clothilde;Rendina,Michael;Negron,Michael;Koch,Steven
Subject:Re:Transitionmemos
Justflaggingtomakesureeveryonesawthis.Letmeknowifyouhavequestions.Thanks,all.
SentfrommyBlackBerry10smartphone.
From: Schrader, Lisa
To: Deal, Joe; Rountree, Janey; Rivera, Arnaldo; Harte, Meghan; Bennett, Kenneth; Holt, Alexandra; Scott, Lois
Cc: david spielfogel; Ewing, Clothilde; Michael Rendina ([email protected]); Negron, Michael; Koch,
Steven ([email protected])
Subject: Transition memos
Team
Canyoueachputtogetherashortmemolisting:
Keyprojects/initiativesinparticularMayoralprioritiesthatyouandyourdepartments/agenciesare
managingovernext612months;and
Keychallengesincludingcommunicationsorpoliticalfacingyourdepartments/agenciesovernext612
months(happytodiscussinpersonifyoureunsurewhattoinclude).
Itdoesntneedtobeallinclusive.PleasejustcoverthemostcriticalissuessoForrestcangetuptospeedmost
efficiently.
(Andtoavoidconfusionwithdepartment/agencyheadswhowereaskingtoputtogethersomeotheritems,Iwouldnot
reachouttothem.Shouldbethehighestlevelstuffthatyouaredealingwitheveryday.)
WouldlikethembyCOBWednesday.Also,pleasemarkthemdraftincasewewanttomakerevisions,andprovidethem
tomeinpaperform.
Thanks,all.
Lisa
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Friday, May 15, 2015 8:53 AM
Update_List;david spielfogel;Fe Claypool
RE: 5/15 - Daily TPs
DPG - 2015.05.15.docx
AddedinAndreaZoppfromSneed.Weshouldbegoodfromhere
From: Collins, Adam

Sent: Friday, May 15, 2015 6:33 AM
To: Update_List; david spielfogel; Fe Claypool
Subject: Re: 5/15 - Daily TPs
WithForrest
From:Collins,Adam
Sent:Friday,May15,20156:32AM
To:Update_List;davidspielfogel;Davis,Felicia
Subject:5/15DailyTPs
AttachedarethedailyTPsfortodayintheeventhehastoansweranyquestionsateitherevent.
Topicsinclude:
SpikeLee
Policerelationships/FBIinvestigatingasecondCPDshooting
NegotiationsinSpringfield
Creditdowngrade
TheS&Pdowngradehasn'tgottenmuchcoverageandIdon'tthinkhegetsaskedaboutit,butit'sinhereifhe
does.SamethingontheFBIstory.
I'llgivehimacopyby9unlessthereareobjections.
From:
Sent:
To:
Subject:
Attachments:
Fischler, Matt
Rountree, Janey;Hill, Kathleen;Iweagwu, Tony
RE: Public Safety To Do List_May 19.docx
Public Safety To Do List_May 20 MF KH adds (2).docx
UpdatedFellowProjectsubmissionsaredueFriday,June5
From: Rountree, Janey

To: Fischler, Matt; Hill, Kathleen; Iweagwu, Tony
Subject: RE: Public Safety To Do List_May 19.docx
Thankseveryone.Matt,willyouaddatthetopanoteaboutthesummerfellowswiththeduedateforproject
submissions?
From: Fischler, Matt

To: Hill, Kathleen; Rountree, Janey; Iweagwu, Tony
Subject: Re: Public Safety To Do List_May 19.docx
myeditsontopofkatie's
From:Hill,Kathleen
Sent:Tuesday,May19,20152:37PM
To:Rountree,Janey;Fischler,Matt;Iweagwu,Tony
Subject:RE:PublicSafetyToDoList_May19.docx
Myadds.

To: Hill, Kathleen; Fischler, Matt; Iweagwu, Tony
Subject: Public Safety To Do List_May 19.docx
Totheextentyoucanbefore3pm,pleaseaddanythingthatmaybemissinghere.
From:
Sent:
To:
Subject:
Breymaier, Shannon
Platt, Thomas;Franklin, Liza;Darling, Leslie
RE: NBC5 on police shooting
Great, will send to Steve to see what he thinks. Thanks!

Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Platt, Thomas
To: Franklin, Liza; Breymaier, Shannon; Darling, Leslie
Subject: RE: NBC5 on police shooting
IagreeShannonthatyourstatementaccuratelystateswhatweknow.

To: Breymaier, Shannon; Platt, Thomas; Darling, Leslie
Imfinewiththat.IreallythinkwehavetosaysomethingthatrefutestheideathatCPDerasedevidence.
LizaM.Franklin
FederalCivilRightsLitigation
3127420170

To: Platt, Thomas; Franklin, Liza; Darling, Leslie
Removing Steve until we have consensus as to final statement from CPD.

How about something like this?
There is no evidence that CPD purged or erased any surveillance video. Further, Burger King did not have a
surveillance camera that pointed in the direction of the shooting, making this a moot point.
1
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Platt, Thomas
To: Breymaier, Shannon; Franklin, Liza; Darling, Leslie; Patton, Stephen
Subject: Re: NBC5 on police shooting
Idonotwanttospeaktoosoonabouttheresultsoftheforensicinvestigationbecauseneitherhasofficiallysaid
anythingonthispoint.
To:Platt,Thomas;Franklin,Liza;Darling,Leslie;Patton,Stephen
Subject:RE:NBC5onpoliceshooting
Thanks, Tom.
So could CPD say the following?
Both IPRA and federal investigators seized and examined the hard drives associated with Burger Kings
surveillance cameras, and neither entity has suggested or concluded that CPD purged or erased any video.
Further, Burger King did not have a surveillance camera that pointed in the direction of the shooting, making
this a moot point.
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Platt, Thomas

To: Franklin, Liza; Breymaier, Shannon; Darling, Leslie
Subject: Re: NBC5 on police shooting
CPDdidnotpurgeorerasevideofromBurgerKing.BothIPRAandfedsseizedandexaminedtheharddrivesandneither
havesuggestedorconcludedanypurgeorerasing.TheonlyvideopointingonPulaskiRoadpointedawayfromthe
shooting.Therewasnocamerafromtherestuarantwhichpointedinthedirectionoftheshooting.
From:Franklin,Liza
To:Breymaier,Shannon;Darling,Leslie;Platt,Thomas
Subject:RE:NBC5onpoliceshooting
Ithinkweabsolutelyhavetopushbackonthis.Tomcanspeaktowhatactuallyhappened(heisincourt),butCPD
absolutelydidNOTeraseanyvideo.
LizaM.Franklin
FederalCivilRightsLitigation
3127420170

To: Darling, Leslie; Franklin, Liza; Platt, Thomas
Subject: NBC5 on police shooting
Leslie, Liza & Tom

NBC is doing a piece on the Laquan McDonald shooting, and they are asking CPD about the allegedly purged
Burger King surveillance video. NBC claims that CPD went into the restaurant, was given a password to access
the security video and erased a large chunk of it. While I understand our hands are tied due to the pending
investigation, can CPD push back at all on this?
Maybe with a statement like the following, perhaps on background?
While we take all allegations of police misconduct seriously, this appears to be a moot point. First, not only did
detectives collect video from other nearby surveillance cameras, the video from the police dash camera captured
the entire incident. In other words, since the police video captured the shooting in its entirety, any footage
recovered from other cameras would have been duplicative. Further, the Burger King surveillance cameras were
not even pointing in the direction of the shooting.
Please let me know what you think.

Thanks!
Shannon
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From:
Sent:
To:
Subject:
Attachments:
Fischler, Matt
Iweagwu, Tony;Hill, Kathleen;Rountree, Janey
notes from team meeting
Public Safety To Do List_May 20 notes.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
attached.Madenotesonourworkplan.
From:
Sent:
To:
Subject:
Escalante
Friday, May 22, 2015 12:37 PM
Maloney; Martin
RE: Follow up Laquan McDonald story for Ch. 5
No I don't. I know it has not come up and been brought to my attention that there may have been an issuc
John 7. Escalante
Chief
312-745-6001

To: Escalante, John J.
Subject: FW: Follow up Laquan McDonald story for Ch. 5
John we're not going to comment on it publicly but do you know if the officers that night followed directives in terms o
using their microphones, etc?

To: Maloney, Martin
Subject: Follow up Laquan McDonald story for Ch. 5
Hi Marty,
Carol and I are doing a followup story that could air Wednesday or Thursday and have a couple of questions:
1: Did the dashboard camera that was active the night of the shooting and captured the footage have the ability to record
audio?
2: What are the regulations regarding turning on or off the audio on CPD dashboard cameras?
3: Were officers wearing clip on microphones at the scene?
4: And what are the rules and regulations regarding the clip on microphones?
As always many thanks,
Don Moseley
NBC5News
DePaul Documen#ary Project
773-793-1566
www.carolmarin.com
-----Original Message----From: Maloney, Martin <[email protected]>

To:'[email protected]' <[email protected]>
Sent: Tue, May 12, 2015 4:37 pm
Subject: RE: A couple of specifics about tonighYs story
On background: yes, most are equipped with audio recording capabilities.
From: dmose92480(~aol.com [mailto:[email protected]]

To: Maloney, Martin
Many thanks.
Can we get an answer to one of the original questions:
Are the dashboard cameras installed in CPD vehicles equipped to capture audio?
Thanks
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
-----Original Message----From: Maloney, Martin <Martin.MalonevCu~chicagopolice.org>

To:'dmose92480~aol.com' <dmose92480(a~aol.com>
Sent: Tue, May 12, 2015 4:23 pm
Subject: RE: A couple of specifics about tonight's story
Here you go:
The Chicago Police Department continues to cooperate with prosecutors investigating this incident, and we cannot offer
any comment as doing so could interfere with the open criminal investigation. The officer involved in the shooting has
been stripped of his police powers and remains on desk duty pending the outcome of these investigations.

Marty,
Thanks,
Don
Don Moseley
NBCS News
773-793-1566
www.carolmarin.com
-----Original Message----From: Maloney, Martin <Martin.Maloney(a~chicagopolice.org>

To:'Carol Marin' <carolmarin(a.aol.com>
Cc: DMose92480 <DMose92480(a~aol.com>
Sent: Tue, May 12, 2015 9:03 am
Thanks.
From: Carol Marin [mailto:[email protected]]

To: Maloney, Martin
Cc: DMose92480C~aol.com
Marty,
Best, CM
Carol Marin
mobile 312.545.6813
email carolmarin(a,aol.com
Contributor/WTTVV "Chicago Tonight"
To: Carol Marin <carolmarin(c~aol.com>
Sent: Mon, May 11, 2015 4:49 pm
3
Don Moseley
From: dmose92480(a~aol.com
Date: May 11, 2015 at 9:17:32 AM CDT
To: Martin.Maloney(c~chicagopolice.orq
Marty,
possible?
Don Moseley
NBC5News
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Cc:
Subject:
Collins, Adam
Update_List
Rountree, Janey
FYI: Marin on CPD shooting investigations
Follow Up Flag:
Flag Status:
Follow up
Completed
FYI,CarolMarinisdoingastoryat10aboutinvestigationsintoCPDinvolvedshootings.
ShewilltalkabouttheLaquanMcDonaldcaseandsaythereareallegationsofmissingsurveillancevideo(whichIPRAhas
alreadysaidisnotthecase).
TheywillalsointerviewCandaceGorman,acivilrightsattorneywhoclaimsIPRAisnotindependentandhasapolicy
exoneratinganyofficer.
Againstmyrecommendation,IPRAhasalreadyprovidedthisresponsethatwasalittleantagonistic.Iveaskedthatthey
followupwiththisaswelltosoftenandreinforcetheirmessage:
Chicagoisuniqueamongmajorcities.IPRAactuallyhasmorepowertoinvestigatethaneventhevastmajorityofcivilian
oversightagenciesintheUS.IPRAhasprimaryinvestigativeauthorityandsubpoenapoweroverthemostseriouscases
ofpolicemisconductinChicago.Evenincitiesthathavesometypeofstillrarecivilianreview,mosthavetheirpolice
departmentsconducttheentireinvestigationandthenallowacivilianoversightboardtoreview.
From:
Sent:
To:
Cc:
Subject:
Collins, Adam
Merritt, Larry;Rountree, Janey
Ando, Scott
RE: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
Follow Up Flag:
Flag Status:
Follow up
Completed
I completely agree that we need to engage more, but if their focus is on specifics investigations we should tread
very lightly. This is about Laquan McDonald and we should not do interviews about open investigations.
-------- Original message -------From: "Merritt, Larry" <[email protected]>
Date: 05/26/2015 5:29 PM (GMT-06:00)
To: "Collins, Adam" <[email protected]>, "Rountree, Janey"
<[email protected]>
Cc: "Ando, Scott" <[email protected]>
Subject: FW: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
See below. So, Can anyone do an interview? I think we need to accept some of these opportunities. Lets discuss and let
me know how I should respond to Don. These stories are getting done with or without us.

To: Merritt, Larry
Subject: Re: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
Larry,
Not sure I can get that in tonight but we are interested in further exploration of IPRA. Can anyone do an interview on this?
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
-----Original Message----From: Merritt, Larry <[email protected]>

To: '[email protected]' <[email protected]>
Sent: Tue, May 26, 2015 5:19 pm
Subject: RE: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
Don,
Include also:
Chicago is unique among major cities. IPRA actually has more power to investigate than even the vast majority of civilian
oversight agencies in the US. IPRA has primary investigative authority and subpoena power over the most serious cases
1
of police misconduct in Chicago. Even in cities that have some type of still-rare civilian review, most have their police
departments conduct the entire investigation and then allow a civilian oversight board to review.

To: Merritt, Larry
Subject: Re: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
got it...thanks.
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com

Sent: Tue, May 26, 2015 3:40 pm
Subject: RE: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
Ms. Gorman could not be more wrong in her mistaken belief that it is the policy of IPRA to exonerate any
officer involved in a shooting. IPRA is a professional investigative civilian oversight agency. As such, IPRA
investigates every officer-involved shooting independently of the Chicago Police Department; IPRA does so
fairly, objectively and thoroughly. IPRAs policy is to reach the proper conclusion relative to the officers use
of deadly force based solely on the evidence. In any situation in which the use of deadly force is determined to
have been outside of policy or a violation of the law, IPRA has no qualms in saying so. If Ms. Gorman or any
Chicago police officer believes officers have complete impunity, they are sadly mistaken. Scott Ando
To: Merritt, Larry
Subject: NBC5 story that airs tonight at 10:00 lookking ofr one mroe response
Larry;
We are running our story on the Burger King video tonight at 10:00, including your response.
One other part of the story that we would like to interview someone from IPRA or get a statement is this:
We interviewed attorney Candace Gorman who claims in a lawsuit involving the shooting death of Divonte Young that
IPRA does not work as an independent voice in investigating police shootings. She states that the policy of IPRA is to
exonerate any off8icer in a shooting and police officers know they have complete impunity.
Please let me know.
Many thanks,
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
2

Sent: Fri, May 22, 2015 1:28 pm
Subject: BK Video
Don,
Here is a statement from IPRA regarding BK video:
We have no
credible evidence at this time that would cause us to believe CPD purged or
erased any surveillance video. Furthermore, Burger King did not have a
surveillance camera that pointed in the direction of the shooting, making this a
moot point.
From:
Sent:
To:
Subject:
Breymaier, Shannon
Breymaier, Shannon
Tomorrow's News
Follow Up Flag:
Flag Status:
Follow up
Completed
WEDNESDAY
Everyone:CoverageofCPDawardsceremony.
Everyone:CoverageofMREandSuptMcCarthy'sgaggleonawards,Springfieldactionandweekendviolence.
NBC5/Marin:StoryaboutIPRAinvestigations.WillsaythereareclaimsCPDerasedsurveillancevideooftheLaquan
McDonaldofficerinvolvedshootings(IPRAsaidnothingsupportsthisallegation),andthatIPRAisnotadequately
investigatingcases.
CBS2/Tellez:AnotherstoryabouthypodermicneedlesfoundinDouglasPark.Parkstaffremovedtheneedlestoday,and
parkssaidthatourstaffroutinelymonitorsandcleansparks,butpatronsshouldalertparkstafftoanyunsafe
conditions.
Bloomberg/Elizabeth,CT/Hal&Heather,Crains/Hinz,possiblyothers:Coverageofthecitysbondpricingasnextstepin
achievingfixedratesandmorefinancialsolidity.
CT/Hilkevitch,ST/Schlickerman:StoriesaboutnewCTACustomerCourtesycampaignlaunchingtomorrow,whichisthe
firstCTAcourtesycampaigninmorethanadecade.Thecampaignisbasedoncustomerfeedbackandobservationsand
isintendedasaconversational,friendlyreminderaboutcommonpublictransportationcourtesies,suchasnotlittering,
notblockingdoorsandnoteatingontrainsandbuses.
ST/Fitz,Crain's/Hinz:Storiesabout
electedofficials,LSCmembers,andparentsopposingNoblemovingintoabuildinginIrvingParkonthenorthside.
ST/Main&Janssen:StoryaboutaraciallychargedphotooftwoformerCPDofficerstakeninsideaWestSidepolice
stationbefore2003.Thephotoshowstheofficersposingwithgunsoveranunidentifiedproneblackmanwhoisdressed
upincostumedeerantlers,asifhewereahuntingtrophy.Oneofficerwasultimatelyarrestedforahostofother
charges,whiletheincidentledtotheotherofficer'sdismissallastyear.CPDprovidedastatementcondemningthe
photoandthebehaviordepictedinit.
ST/Brown:Storyonriverwalkandifwecanaffordit.CDOTpushedtheTIFIAfunding,repaidwithrevenuefromthetour
boatlicenseagreements,leasesandconcessionsofspaceontheriverwalk,andadvertisingrevenues.
ST&BGA/Shaw:ColumnonCPSandthe
solesourceprocess.
CT/Hilkevitch.StoryaboutconstructionstartingonDamen,ElstonandFullertonintersection.
Crains/Hinz:PlacedstoryonMREsnamingoftwocabinetpositions.
1

Crains/Gallun:Updateonthe101unitGoldblattsSeniorLivingProjectforwhichDPDhasallocatedvariousformsof
financing,includingarecent$2.5millionbondissuetoaccommodatecostoverrunsresultingfrompartnershipissues
andtheageofthebuilding.Piecemaysuggesttheoverrunsmaybepartlyduetomismanagementandmaybecritical
ofthecityiskickinginanother$2.5million.DPDreiteratedthatthefinancingisatnoexpensetothecityandthatthe
goalistocreatenew,affordableseniorhousingatahistoriclandmarkthat'sbeenunderutilizedforyears.
________________________________
From:
Sent:
To:
Subject:
Ralph M. Price
Wednesday, May 27, 2015 4:30 AM
Patton, Stephen
Missing Minutes From Security Video Raises Questions | NBC Chicago
http://www.nbcchicago.com/investigations/laquanmcdonaldinvestigation305105631.html#
From:
Sent:
To:
Subject:
Rountree, Janey
Wednesday, May 27, 2015 10:18 AM
Collins, Adam;Higgins, Jessica
RE: (NEWS) NBC5 News at 10PM: Chicago Police Department accused of deleting
footage of Laquan McDonald shooting
Follow Up Flag:
Flag Status:
Follow up
Completed
Iwasnteither.Jess,didyouknowtheywereauditingtheofficerinvolvedshootings?
From: Collins, Adam

To: Higgins, Jessica; Rountree, Janey
Subject: FW: (NEWS) NBC5 News at 10PM: Chicago Police Department accused of deleting footage of Laquan McDonald
shooting
GuessIdidntrealizetheIGwasdoinganIPRAaudit
From: NewsClips
Subject: (NEWS) NBC5 News at 10PM: Chicago Police Department accused of deleting footage of Laquan McDonald
shooting
NBC5Newsat10PM:ChicagoPoliceDepartmentaccusedofdeletingfootageofLaquanMcDonaldshooting
ANCHOR:Tonight,NBC5investigated.AclaimChicagopoliceofficersdeletedfootagefromasecuritycamera
locatednearwhere17yearoldLaquanMcDonaldwasshotandkilled.Eightysixminutesofvideoismissing
fromthenightasingleofficershotMcDonald16times.Thecityquicklysettledthecasewithoutalawsuitfor
$5million.NBC5sCarolMarincontinuestoherinvestigation.
MARIN:The86missingminutesofvideooccurredbetween9:13and10:39p.m.TheshootingofLaquan
McDonaldtookplaceat9:50p.m.AccordingtoadistrictmanagerforBurgerKing,policeenteredoneoftheir
restaurantsnotlongaftertheshootinganderasedfootagefromthecompany'ssecuritycameras.TheBurger
Kingsitsat40thandPulaskiandhasaseriesofoutsidesecuritycameras.OnthenightofOctober20th,
LaquanMcDonaldwastrailedbyChicagopoliceofficersthroughtheBurgerKingparkinglotafteracallabouta
manwithaknife.Justsouthoftherestaurant,McDonaldwasshot16timesafterpoliceonthescenesaidhe
posedaveryseriousthreat,aclaimdeniedbyattorneysforLaquanMcDonald'sfamilyandbysome
eyewitnessesthatnight.
JEFFNESLUND,MCDONALDFAMILYATTORNEY:Thiswitnesstoldus,youknow,thiswasanexecution.That's
hisword.
MARIN:Aftertheshooting,accordingtothedistrictmanagerforBurgerKing,fourtofivepoliceofficers
wearingblueandwhiteshirtsenteredtherestaurantandaskedtoviewthevideoandweregiventhe
passwordtotheequipment.Threehourslater,theyleft,hesaid.Thenextday,whenaninvestigatorforthe
IndependentPoliceReviewAuthority,IPRA,askedtoviewthesecurityfootage,theydiscoveredthatvideo
wasmissing.Inastatement,IPRAsaid,Wehavenocredibleevidenceatthistimethatwouldcauseusto
believeCPDpurgedorerasedanysurveillancevideo.ButaccordingtoJayDarshane,districtmanagerfor
BurgerKing,allofthecamerasandtherecorderwereonandworkingproperlythenightoftheshooting.So,
1
whathappened?Darshanebelieves,hesaid,thatoneoftheofficersdeletedfiles.Wehadnoideatheywere
goingtositthereanddeletethefiles,JayDarshanesaidbytelephoneonFriday.Imean,wewerejusttrying
tohelpthepoliceofficers.Theironyofthemissingvideo,allsidesagree,isthatitwouldnothaveshownthe
actualshooting.ButaccordingtolawyersfortheMcDonaldfamily,itcouldhaveshowneventsleadinguptoit.
NESLUND:OurfirsttimedownattheBurgerKingrestaurant,whenwerealizedvideohadbeendeletedoris
missing,absolutelyweknewsomethingwasup.
MARIN:WhilethevideofromtheBurgerKingismissing,theshootingofMcDonaldwascapturedonapolice
dashboardcamera,thoughthatvideohasnotbeenmadepublic.TheFBI,theUSattorneyandtheCook
Countystate'sattorney'sofficeareinvestigatingtheMcDonaldshooting,asistheIndependentPoliceReview
Authority.
CANDICEGORMAN,ATTORNEY:Idontregardthemasindependent,andIdontregardthemasinvestigators.
MARIN:AttorneyCandiceGormanrepresentsthefamilyofDevonteYoung,whowasshotandkilledbya
ChicagopoliceofficerinAugustof2012.ThatofficersaidhewasinfearofhislifeafterYoungshotathim.
ThoughtheIndependentPoliceReviewAuthoritysaiditwasajustifiedshooting,itnoted,however,No
weaponwasfoundonornearthesubject,soitwassurprisedthatacivilianhadremovedthegun.Inacivil
rightscasefiledinfederalcourt,GormancontendsIPRAsinvestigationsareawhitewash.
GORMAN:Theirpolicyistoexonerateeveryofficerwhosinvolvedinashooting,andtheofficersknowit.
MARIN:IPRArespondedthatitsinvestigationsaredonefairly,objectively,andthoroughlyandMs.Gorman
couldnotbemorewrong.ChicagoinspectorgeneralJosephFerguson,accordingtotheIG'swebsite,is
auditingtheaccuracyandcompletenessofIPRAsreportingofofficershootingsandinvestigations.A
spokeswomanfortheIG'sofficesaysthatauditisongoing.CarolMarin,NBC5News.
From:
Sent:
To:
Subject:
Escalante
Wednesday, May 27, 2015 1127 AM
Roy; Eugene J.
RE: Missing Minutes From Security Video Raises Questions ~ NBC Chicago
Thanks
John J. Escalante
Chief
312-745-6001
From: Roy, Eugene J.
To: Escalante, John J.
Subject: FW: Missing Minutes From Security Video Raises Questions ~ NBC Chicago
This is the other story I was mentioning to you.
-----Original Message----From: Price, Ralph M.
To: Roussell, James M.; Roy, Eugene J.
Subject: Missing Minutes From Security Video Raises Questions ~ NBC Chicago
h_t~/www.nbcchica~o.com/investigations/laquan-mcdonald-investigation-305105631.html#
From:
Sent:
To:
Subject:

Thursday, May 28, 2015 4:58 PM
Merritt, Larry;Collins, Adam
RE: FYI MSNBC
Follow Up Flag:
Flag Status:
Follow up
Flagged
Just so you know, nobody deleted anything off the video. Period.
Scott M. Ando
This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged
and/or confidential information. If you are not the intended recipient of this e-mail (or the person responsible for delivering this
document to the intended recipient), you are hereby notified that any dissemination, distribution, printing or copying of this e-mail,
and any attachment thereto, is strictly prohibited. If you have received this e-mail in error, please respond to the individual sending the
message, and permanently delete the original and any copy of any e-mail and printout thereof.
From: Merritt, Larry

Sent: Thursday, May 28, 2015 4:14 PM
To: 'Collins, Adam'; Ando, Scott
Subject: RE: FYI MSNBC
Do you want me to call and find out? If so, is there anything else I should ask Allison when I get her on the phone?

To: Merritt, Larry; Ando, Scott
Ok.Doyouknowhowmuchtimetheyaredevotingtothesegment?
From: Merritt, Larry [mailto:[email protected]]

To: Collins, Adam; Ando, Scott
The segment is airing tonight. The show comes on at 8pm EST.I dont know if theyre in town or not. My guess would be
that they are not.

Whenisitrunning?Aretheyintown?

To: Collins, Adam; Ando, Scott
All in with Chris Harris. The segment is about the missing chunk of video from the Burger King surveillance camera. Ms.
Koch says MSNBC has reported on this particular shooting before.

Whichshowdoessheproduceandwhatkindofsegmentaretheydoingonthis?

To: Ando, Scott; Collins, Adam
Subject: FYI MSNBC
Producer Allison Koch from MSNBC called to ask specific questions about the Laquan McDonald investigation related to
IPRA going on a canvass the next day to the Burger King and the video. She tried to get comment and I explained there
would be no comment. She does have the statement given to Carol Marin at NBC 5.
Larry L. Merritt
Director of Community Outreach & Engagement
Independent Police Review Authority
1615 W. Chicago Avenue, 4th Floor
Chicago, IL 60622
(312) 746-3609
This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain
legally privileged and/or confidential information. If you are not the intended recipient of this e-mail (or the person
responsible for delivering this document to the intended recipient), you are hereby notified that any dissemination,
distribution, printing or copying of this e-mail, and any attachment thereto, is strictly prohibited. If you have received this email in error, please respond to the individual sending the message, and permanently delete the original and any copy of
any e-mail and printout thereof.
From:
Sent:
To:
Subject:
Muellenbach, Eric <[email protected]>

Thursday, May 28, 2015 5:50 PM
Higgins, Jessica;Rountree, Janey
Re: IPRA and IG audits
Follow Up Flag:
Flag Status:
Follow up
Completed
IapologizeforthedelayI'moutoftheofficetoday.Icangiveyouacalltomorrowaround10:30ifthatworksforyou.
SentviaBlackberry.
From: Higgins, Jessica [mailto:[email protected]]
To: Rountree, Janey <[email protected]>; Muellenbach, Eric
Subject: RE: IPRA and IG audits
ThanksJaney.
EricImaroundandgenerallyavailabletomorrow,orwecansetupatimeforabriefcallnextweek.Justletmeknow
whatmightworkforyou.
JessicaHiggins
CityofChicago
121NLaSalleSt.,Room509
312.744.6501

To: Eric Mullenbach; Higgins, Jessica
Subject: IPRA and IG audits
Eric,
WillyouconnectwithJessHiggins,copiedhere,tobringheruptospeedontheIGauditintohowIPRAreportsofficer
involvedshootings?JessicahandlesallIGmattersfortheMayorsOffice.Thisparticularauditstartedbeforehertenure
andwasrecentlymentionedinanewsarticleabouttheLaquanMcDonaldshooting.
Thanks,
Janey
From:
Sent:
To:
Subject:
Collins, Adam
Friday, May 29, 2015 12:15 PM
Rountree, Janey;Ewing, Clothilde;Quinn, Kelley
RE: Announcing new Chair of the Police Board
Follow Up Flag:
Flag Status:
Follow up
Completed
I'm on the way back from an event, so not in my office.

We'll certainly do a thank you to Demetrius
Date: 05/29/2015 12:13 PM (GMT-06:00)
To: "Collins, Adam" <[email protected]>, "Ewing, Clothilde"
<[email protected]>, "Quinn, Kelley" <[email protected]>
Subject: RE: Announcing new Chair of the Police Board
Couplethings:
From: Collins, Adam

To: Rountree, Janey; Ewing, Clothilde; Quinn, Kelley
If it's in the short term the answer to any question should really be that she just got nominated and while she has
a deep background in public safety she's going to spend the next few weeks getting up to speed on the details.
Shouldn't do any interviews now though

Date: 05/29/2015 11:50 AM (GMT-06:00)
<[email protected]>, "Quinn, Kelley" <[email protected]>
1
IpromisedherIwouldgiveherguidanceonanyquestionsshemightgetasked(unlesswewanthernottorespondat
all).IthinkitwouldbestandardanswerstoLaquanMcDonald,recentcommentsbyMREaboutthepoliceboard,a
questionaboutthesaferreport,etc.Icanworkonitifwedontanythingputtogether.
From: Collins, Adam

To: Rountree, Janey; Ewing, Clothilde; Quinn, Kelley
Sort of. we could start with the fact sheet. Don't think we need to put Lori on the phone with Fran
Date: 05/29/2015 11:44 AM (GMT-06:00)
To: "Ewing, Clothilde" <[email protected]>, "Quinn, Kelley"
<[email protected]>, "Collins, Adam" <[email protected]>
Imworkingonit.Adam,doyouhaveapremadeQ&Aaboutcommonpolicedisciplineissues?
From: Ewing, Clothilde

To: Quinn, Kelley; Rountree, Janey; Collins, Adam
Importance: High
Janey,needyoursignoffandassumetherewouldbecallsthatneedtobemadeASAP
From: Quinn, Kelley

To: Ewing, Clothilde; Rountree, Janey; Collins, Adam
ThiswouldbeaneasyoneforFrantogetout,andshelovesLori.
From: Ewing, Clothilde

To: Rountree, Janey; Collins, Adam; Quinn, Kelley
AnyreasoninternallythatwecantdoLorisannouncementforSundaypaper?Wearenotgoingtogetthegreenlight
forSchoolboardwithenoughtimetogetthisplaced.
ItwouldmeanwewouldhavetoletFranstartreportingnow,butwecouldstillinsistonSaturdaynightembargo.
From: Stone, Jill

To: Rountree, Janey; Collins, Adam; Ewing, Clothilde; Quinn, Kelley
AnywordonwhetherwearegoingtoreappointElisaRodriguezandWilliamConlonwhosetermshavealsoexpired,but
arenotsubjecttotermlimits?
CanweincludealineinthereleasethankingDemetriusCarneyforhisyearsofservice.Canwelethimknowinadvance?
2

SharedwithFarzin,sohecanadviseAldermanReboyrasnewCityCouncilPublicSafetyChairinadvance,if
appropriate.
LorisappointmenttotheBoardasmemberissubjecttoCityCouncilapproval.ItisMayor,however,whodesignatesthe
Chair.

To: Collins, Adam; Ewing, Clothilde; Quinn, Kelley; Stone, Jill
Cc: Lightfoot, Lori
Subject: Announcing new Chair of the Police Board
Kelly,Adam,JillandClo,
IwantedtointroduceyoutoLoriLightfoot,apartneratMayerBrown,whomtheMayorhasselectedtobethenew
ChairofthePoliceBoard,replacingDemetriusCarney.WeareveryluckythatLoriagreedtocomebacktocityservice
youwillallreallyenjoyworkingwithher.Asyoumayalreadyknow,theMayorrequestedthatweannounceher
appointmentnextweek,andLoriisamenabletothattimeline.Iwantedtoconnecteveryonesowecandiscussthe
formatandtimingoftheannouncement.Lorihasanextensivebioonthefirmswebsite,thoughImsureshewouldbe
happytoprovideanyadditionaldetailyoumayneed.Ialsotoldherwewouldhelpprepareherforanyquestionsshe
willgetfrommedia.
LoriKelleyisthechiefSpokeswomanfortheMayor.AdamisaDeputyPressSecretarywhofocusesonthepublicsafety
agenciesamongotherissues.Cloistheheadofstrategiccommunications,andJillmanagesboardappointmentsamong
otherresponsibilities.
Illletthecommspeoplechimeinwithnextsteps.
Thanks,
Janey
From:
Sent:
To:
Cc:
Subject:
Langsdorf, Elizabeth
Wednesday, June 03, 2015 5:12 PM
Holden, John;Patton, Stephen;Darling, Leslie;Platt, Thomas;Franklin, Liza;Peters, Lynda
Breymaier, Shannon;Cooper, Tarrah
RE: FYI on MSNBC report last Thursday
WithTarrah
From: Holden, John

Sent: Wednesday, June 03, 2015 5:10 PM
To: Patton, Stephen; Darling, Leslie; Platt, Thomas; Franklin, Liza; Peters, Lynda
Cc: Breymaier, Shannon; Langsdorf, Elizabeth
Subject: FYI on MSNBC report last Thursday
FYIIjustfoundthatMSNBCdidastorylastThursdayfollowinguponChannel5sstoryearlierlastweekonalleged
eventsfollowingtheMcDonaldshooting
http://www.msnbc.com/allin/watch/missingvideointhelaquanmcdonaldcase453667395733
ItincludesextensiveinterviewcommentsfromMcDonaldattorneyMichaelRobbinswhocomesinataboutfouranda
halfminutesintothepieceandtalksatthemissingBurgerKingvideoandwhatsomewitnesseswereallegedlytoldby
investigators.
HostChrisHayes(whoisthesoninlawoftheBGAsAndyShaw)saidMSNBCwillcontinuetofollowthestory,andwill
appealarecentrejectionbyCPDofaFOIAtheyfiled.
John
From:
Sent:
To:
Cc:
Subject:
Holden, John
Thursday, June 04, 2015 3:41 PM
Breymaier, Shannon;Langsdorf, Elizabeth
Update on WSJ police settlement story
FYIJustaquickupdateonthelonggestatingstorybytheWallStreetJournalontrendsinvolvingsettlementpayments.
ReporterZushaElinsoninformedmetodaythatthestoryisstillintheworks,butitsscopehaschangedsincehewaslast
intouch.Insteadoflookingatthetop15lawenforcementagenciesinthenation,theyarenowjustlookingatthetop
10citiesafterdeterminingthataddinginsheriffsdepartmentscausedtoomanyapplesandorangesvariables.
Usingouronlinedata,theydeterminedChicagohaspaidout$279millionoverthepastfiveyearsinsettlementsand
judgmentsandthatofthatamount$249.7millionispolicerelated.WorkingwithJimDunn,weverifiedtheirnumbers
wereaccurate.Ialsonotedthatofthe$249.7millioninpolicecasespayments,about$201millionofthatwasforcases
filedpriortothecurrentadministration.Hewasveryappreciativeforgettingthatnumber.
Hesaidthestorywillincludeatablethatshowswhatthetenlargestcitiesarepayingoutintotalsettlementsand
judgmentsandthenhowmuchofthatistiedtopolicecases,butotherwisethestorywillnotspendalotoftime
comparingnumbersbetweencities.Ratheritwillfocusonthelargenumberofvariablesthatdrivesuchcostsaround
thecountryandthatevenjudgmentscomingoutoffederalcasesvarygreatlydependingonthejurisdiction.
Hesaidthatthestorywillnotethatthesecostsseemtoberisingalloverthecountry,eveninstatesthathavecaps
(includingMaryland)and/orverytoughenvironmentsforplaintiffslawyerstryingtowincivilrightscases,suchas
Texas.Theyspeculatethatthehighprofilepoliceshootingcasesofthepastyear,includingthatofLaQuanMcDonald,
arelikelytofurtherthistrend.
Thereisstillnocertaintywhenthestorywillrun,butthereporteraffirmedthathewouldgivemeadayortwoof
advancenoticebeforeitdoes.
Letmeknowifyouhaveanyquestions.
John
From:
Sent:
To:
Cc:
Subject:
Attachments:
Monday, June 08, 2015 11:57 AM

Platt, Thomas
Laquan McDonald v City of Chicago (Atty/Client Privileged)
Letter - Attorney Tom Platt - 08 June 15.docx
(Atty/Client Privileged)
Tom,
Good Day. Please see the attached re: Laquan McDonald v City of Chicago
Thank You,
Tony Wojcik
08June15
Tom,
Re:LaquanMcDonaldv.CityofChicago.
Thanksformeetingwithus.Inadditiontotheassistancewerequestedatthemeetingweaskthe
following:
Aswementionedduringourconversationwehaveconcernsaboutpotentialharmthatmayoccurasa
resultofourbeingindividuallynamedintheSettlementAgreementintheabovereferencedmatter.
Theseconcernsincludepossibledangertoourselves,ourfamiliesanddamagetoourproperty,among
others.
Sincewehavenotbeenformallynamed,accused,orallegedtohavecommittedanyinfractioninany
affidavit,courtfiling,orcomplaint,andbecauseournameswerespecifiedintheSettlement
Agreementwithoutourknowledge,consentand/orconsultmerelybecausethePlaintiffsAttorney
suggestedwewereprospectivedefendantsinalawsuitthatwasneverfiled,werequestyou
immediatelydemandthattheCityofChicagoredactournamesfromanyFreedomofInformation
requeststhataregrantedfromthisimmediatetimeforward.
WewouldalsolikeyoutoensurethatwebeformallynotifiedbytheCityofChicagoofanyandall
FreedomofInformationrequeststhathavetodate,andwillinthefuturebegrantedorrefused.
Ifyouneedanythingadditionalforthisrequestletmeknow.
ThankYou,
TonyWojcik
(312)6722179WorkCell
LtAnthonyWojcik#
SgtDanielGallagher#
DetDavidMarch#
DetRichardHagen#
From:
Sent:
To:
Subject:
Attachments:
Fischler, Matt
Tuesday, June 09, 2015 12:36 PM
Rountree, Janey;Hill, Kathleen;Iweagwu, Tony
Re: Public Safety To Do List_May 19.docx
Public Safety To Do List_May 20 notes.docx; Public Safety To Do List_May 19 MF KH
adds.docx
Bothversions,onewithkatie/mattadditionspremeetingandonewithnotespostmeeting
From:Rountree,Janey
Sent:Tuesday,June9,201512:33PM
To:Fischler,Matt;Hill,Kathleen;Iweagwu,Tony
Subject:PublicSafetyToDoList_May19.docx
Willyouguysupdatethisbeforeourmeetingthisafternoon?Notethatattachedwastheoriginalversionbeforeyou
guysredlineditinadvanceofourlastmeeting.Oneofyouprobablyhasthefinal,redlinedversionelectronically(Ionly
keptthepapercopy).thanks
Thisemail,andanyattachmentsthereto,isintendedonlyforusebytheaddressee(s)namedhereinandmay
containlegallyprivilegedand/orconfidentialinformation.Ifyouarenottheintendedrecipientofthisemail
(orthepersonresponsiblefordeliveringthisdocumenttotheintendedrecipient),youareherebynotified
thatanydissemination,distribution,printingorcopyingofthisemail,andanyattachmentthereto,isstrictly
prohibited.Ifyouhavereceivedthisemailinerror,pleaserespondtotheindividualsendingthemessage,and
permanentlydeletetheoriginalandanycopyofanyemailandprintoutthereof.
From:
Sent:
To:
Cc:
Subject:

Ewing, Clothilde;Rountree, Janey;Quinn, Kelley
Spielfogel, David
RE: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
He did not specifically ask about dates, but he did ask how the average resident would learn about this, etc.
These meetings are not 'advertised' to the public. Deputy Chief Washington will call different stakeholders in the
community and ask if they are interested in hosting a listening tour and leaves it up to them who they invite (20-25
people). The only direction he gives them is that this will be a discussion where members of the community can offer
ideas or solutions on enhancing on community and police relationships. So these are not publicly advertised, as it would
miss the point of the original premise of the listening tour.
From: Ewing, Clothilde [mailto:[email protected]]

To: Rottner, Jennifer E.; Rountree, Janey; Quinn, Kelley
Cc: Spielfogel, David
Subject: FW: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
Wereweaskedspecificallyaboutdates?
Howareweadvertisingthistothepublicorworkingwiththecommunities?Thiswillbechased.
From: NewsClips
Subject: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
CPD'listeningtour'fuzzyondetails
WBEZ//PatrickSmith//June10,2015
Citiesacrossthecountryhavebeenrippedapartbyviolentencountersbetweenpoliceandcitizens.
FergusonhadMichaelBrown,NewYorkhadEricGarner,BaltimorehadFreddieGrayandChicagohad17
yearoldLaquanMcDonald,whowasshot16timesbyaChicagocoplastOctober.TheresalsoChicagoPolice
CommanderGlennEvans,indictedforallegedlyramminghisgunintosomeonesmouth.AndDetectiveDante
Servin,acquittedofkilling22yearoldRekiaBoyd.
Thatspartofthereasonwhythecitystopcop,Supt.GarryMcCarthy,recentlyannouncedabig,citywide
listeningtour.Itsamajorinitiativeforthepolicedepartmenttocommunicatewiththepublic.
Theresabigantipolicesentimentbothlocallyandnationally.Andweredealingwithprotestsonadaily
basis,McCarthysaidintheSpring.
AfterDetectiveServinwasfoundnotguiltybyajudgeinApril,angerinChicagoreachedahighpoint.And
thatswhenMcCarthycameoutwithaplantorepairtherelationshipbetweencopsandresidents:Hecalledit
theCPDNeighborhoodOutreachTour.
Theideawasthedepartmentwouldopenupabigpublicdialogue.McCarthyandpolicecommanderswould
personallymeetwithpeopleandreallylisten.
MayorRahmEmanuelthrewhissupportbehindtheinitiative.
Thelisteningtour,notjustbySuperintendentMcCarthy,itsalsobyeachofthecommandersinthedistricts,
isallapartofeffortofbuildingtrustandrelationshipsthatareessentialpartofcommunitypolicing,Emanuel
said.
CHAIN CONTINUES AS
PREVIOUSLY PRODUCED
From:
Sent:
To:
Cc:
Subject:

Quinn, Kelley;Ewing, Clothilde;Rountree, Janey
Spielfogel, David
RE: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
Follow Up Flag:
Flag Status:
Follow up
Completed
No, when Patrick Smith reached out, he did not ask me about specific dates. He just asked to speak with the Supt about
the tour and also, how the public can go about finding out info about the meetings.
From: Quinn, Kelley [mailto:[email protected]]

To: Rottner, Jennifer E.; Ewing, Clothilde; Rountree, Janey
Subject: RE: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
Wewerentaskedaboutdates,right?
From: Rottner, Jennifer E. [mailto:[email protected]]

To: Ewing, Clothilde; Rountree, Janey; Quinn, Kelley
Subject: RE: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
Also-in response to Alderman's Sawyer's comment of the police wanting to 'handpick' who will be at these meetings,
Deputy Chief Washington told me they do not know who from the community will be at the meeting until they arrive. It is
completely up to the 'host' of the listening tour to invite people in their community and we never say yes/no one way or
another. So we do not cherry pick who will be in attendance.
From: Ewing, Clothilde [mailto:[email protected]]

To: Rottner, Jennifer E.; Rountree, Janey; Quinn, Kelley
Subject: FW: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
Wereweaskedspecificallyaboutdates?
Howareweadvertisingthistothepublicorworkingwiththecommunities?Thiswillbechased.
From: NewsClips
Subject: (NEWS) WBEZ: CPD 'listening tour' fuzzy on details
CPD'listeningtour'fuzzyondetails
WBEZ//PatrickSmith//June10,2015
Citiesacrossthecountryhavebeenrippedapartbyviolentencountersbetweenpoliceandcitizens.
1
FergusonhadMichaelBrown,NewYorkhadEricGarner,BaltimorehadFreddieGrayandChicagohad17
yearoldLaquanMcDonald,whowasshot16timesbyaChicagocoplastOctober.TheresalsoChicagoPolice
CommanderGlennEvans,indictedforallegedlyramminghisgunintosomeonesmouth.AndDetectiveDante
Servin,acquittedofkilling22yearoldRekiaBoyd.
Thatspartofthereasonwhythecitystopcop,Supt.GarryMcCarthy,recentlyannouncedabig,citywide
listeningtour.Itsamajorinitiativeforthepolicedepartmenttocommunicatewiththepublic.
Theresabigantipolicesentimentbothlocallyandnationally.Andweredealingwithprotestsonadaily
basis,McCarthysaidintheSpring.
AfterDetectiveServinwasfoundnotguiltybyajudgeinApril,angerinChicagoreachedahighpoint.And
thatswhenMcCarthycameoutwithaplantorepairtherelationshipbetweencopsandresidents:Hecalledit
theCPDNeighborhoodOutreachTour.
Theideawasthedepartmentwouldopenupabigpublicdialogue.McCarthyandpolicecommanderswould
personallymeetwithpeopleandreallylisten.
MayorRahmEmanuelthrewhissupportbehindtheinitiative.
Thelisteningtour,notjustbySuperintendentMcCarthy,itsalsobyeachofthecommandersinthedistricts,
isallapartofeffortofbuildingtrustandrelationshipsthatareessentialpartofcommunitypolicing,Emanuel
said.
Therewerenodetailsaboutwhenthetourwasstarting,nobigannouncementabouthowanybodyfromthe
neighborhoodscouldtakepart.Butthen,allofasuddenataChicagoCityClubeventinMay,McCarthysaid
thelisteningtourwasalreadyunderwayandthatitwasabighit.
Imgoingouteverysingledaytocommunitymeetings,sittingdownwithsmallgroupsofresidentswithout
thepress,andwehaveconversationsandwelistentopeople,McCarthytoldaroomfullofbusinessandcivic
leaders.
ButevenafterMcCarthygavehisspeechattheCityClub,therewasstillnowaytofindoutwhereandwhen
theeventsofthisbig,publiclisteningtourwerehappening.
WBEZhasbeentryingtofindoutmoreaboutthisoutreachtoureversinceitwasfirstannounced:Weve
called,weveemailedabouthalfadozentimesandweveaskedinperson.Themainquestioniswhereare
theseeventslistedforthepublic?
Thetourissupposedtobeachancetohearfromthepublictogetresidentfeedbackandtofoster
ongoingdialogue.Butifpeopledontknowaboutit,whydoit?
Residentsarenttheonlyonesstrugglingtogetthisinformation.Peopleyoudpresumewouldabsolutely
knowdonteither.
Seemslikeitssomekindofsecretmission,saidAld.PatDowell,whorepresentsthe3rdWardonChicagos
SouthSide.
Shesaidshewouldlovetoadvertisethelisteningtourtoherconstituents,butshesbeenkeptinthedark.
Idontknowanythingabouthowtheyreorganized,whatheistryingtoaccomplish,Ald.Dowelllamented.
Anofficerinchargeofcommunityrelationsforherdistrictsaidshedidntknowwhenthemeetingswere
happeninginherdistrict.Infact,shealreadymissedtheoneinherowndistrictsheonlyfoundoutaboutit
fromaresidentafterwards.
DowellsfellowSouthSidealderman,RoderickSawyer(6),saidhegotalistofthelisteningtourstopsafterhe
specificallyaskedthepolice.Buthesaidhedoesntthinkmostpeoplehaveanywayoffindingoutaboutthe
events.
Ald.Sawyersaidhesuspectsthepolicewanttohandpicktheiraudience,whichhesaiddefeatsthewhole
purpose.
RemainingDialogueTourEvents
District
Date
Time
Location
Contact
Garfield Hospital,
011
Thursday, June 11
5:30 p.m.
Chuck Levy
520 N. Ridgeway
2
002
Wednesday, June 17 5:30 p.m.
014
Wednesday, June 24 7:00 p.m.
011
Thursday, Jul 2
6:00 p.m.
010
Tuesday, July 7
7:00 p.m.
002
Thursday, July 9
6:00 p.m.
007
Monday, July 13
6:00 p.m.
015
Wednesday, July 15 6:00 p.m.
005
Monday, July 20
Chicago Urban
League, 4510 S.
Roderick Hawkins
Michigan
Bickerdike
Redevelopment
Danny Serrano
Corporation, 2550 W.
North
People's Church of
the Harvest, 3570 W. Pastor Eaddy
Fifth Avenue
Lawndale Christian
Development
Corporation,
2111 S. Hamlin Ave
Tracie Worthy
(Firehouse
Community Arts
Center) Ogden and
Hamlin
KLEO Community
Family Life Center, Torrey Barrett
119 E. Garfield Blvd.
Chicago Embassy
Church, 5848 S.
Bishop Peecher
Princeton
Mars Hill Baptist
Church, 5916 W.
Pastor Stowers
Lake St
Temple of Glory
Pastor Wilson
Church 311 E.
95th St.
6:30 p.m.
From:
Sent:
To:
Cc:
Subject:
Holden, John
Patton, Stephen
Darling, Leslie
FW: Dept of Law email search request
HiSteve
t.
John
From: FOIAeDiscovery
To: Holden, John
Subject: Re: Dept of Law email search request
HiJohn,
Thesesearcheshavebeenexecuted.Theresultsarebelow.YouwillreceiveanemailviaOneDrivesharingthe
pstfilesshortly.Thanks.
6.10.2015FOIA1066
StephenPattonJohnHolden128
YES19MB
Microsoft
6.10.2015FOIA1067
ThomasPlattJohnHolden
362YES
41MBMicrosoft
6.10.2015FOIA1068
LizaFranklinJohnHolden90
YES12MB
Microsoft
From:FOIAeDiscovery
Sent:Wednesday,June10,20153:53PM
1
To:Holden,John
Subject:Re:DeptofLawemailsearchrequest
Gotit.Willnotifyyouwhencomplete.
From:Holden,John
Sent:Tuesday,June9,20156:25PM
Subject:DeptofLawemailsearchrequest
Hello
I am requesting an email search for the accounts of Stephen Patton, Thomas Platt and Liza Franklin all with
the Corporation Counsels Office for the time period of Oct. 20, 2014 to April 20, 2015 using the search terms
Neslund, Michael Robbins, and LaQuan.
Please let me know if you have any questions on this matter.
JohnHolden
DirectorofPublicAffairs
ChicagoDepartmentofLaw
O:(312)7441575
C:
[email protected]
From:
Sent:
To:
Subject:
Attachments:
Holden, John
Darling, Leslie;Breymaier, Shannon;Rasmas, Chloe
Wade letter
Wade Response 061015.doc
AmberjustapprovedthisletterrequestingadditionalclarificationfromCarolMarinsintern.
JohnHolden
O:(312)7441575
C:(312)7184240
[email protected]
From:
Sent:
To:
Cc:
Subject:
Holden, John
LAWFOIA;Ritter, Amber
Peters, Lynda;Farmer, Toni;Darling, Leslie
FW: NBC5 FOIA
Ittookabitofteasingout,butwefinallyhaveasuccinctrequestfromMarinsteamontheirLaQuanMcDonaldemail
search.TonicanyousetupafolderforanewFOIA?
From: Don Moseley [mailto:[email protected]]

Sent: Thursday, June 11, 2015 3:06 PM
To: Holden, John
Subject: Re: NBC5 FOIA
Yes. Confirmed. Thanks again

Don Moseley
On Jun 11, 2015, at 2:51 PM, Holden, John <[email protected]> wrote:
ThanksDon.JustsothatwecanafullandexplicitlywordedFOIArequestonthisallinoneplace,can
youpleaseconfirmthatthatwouldbe:
We are requesting searches of the email accounts and/or letters or correspondence of Department of
Law employees Stephen Patton, Thomas Platt and Liza Franklin in which the name LaQuan (or Laquan)
McDonald is used for the time period of Oct. 20, 2014 to June 11, 2015.
John

To: Holden, John
Subject: NBC5 FOIA
John,
This is to clarify our most recent FOIA request. We are requesting searches of the email accounts and/or
letters or correspondence using the names of Department of Law employees in the FOIA letter we sent in
which the name LaQuan (or Laquan) McDonald is used.
Thanks for your attention,
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
1
From:
Sent:
To:
Cc:
Subject:
Holden, John
Rasmas, Chloe;Breymaier, Shannon
Darling, Leslie;Ritter, Amber
Carol Marin's third attempt at LaQuan McDonald email search
After a bit of back and forth with Carol Marins producer Don Moseley and student intern, we now have the
following language for their FOIA on the selected email searches involving the name LaQuan McDonald. We
will treat it as a new FOIA received today.
We are requesting searches of the email accounts and/or letters or correspondence of Department of Law employees
Stephen Patton, Thomas Platt and Liza Franklin in which the name LaQuan (or Laquan) McDonald is used for the time
period of Oct. 20, 2014 to June 11, 2015.
JohnHolden
O:(312)7441575
C:(312)7184240
[email protected]
From:
Sent:
To:
Subject:
Green, Melissa
Rountree, Janey;Rapelyea, Sean;Fischler, Matt;Hill, Kathleen;Koronides, Christine
RE: URGENT: CALL
Follow Up Flag:
Flag Status:
Follow up
Completed
Awesome.thanksfordoingthis.wldliketodomoreofthisgenerallyonmanysubjectsandsoIappreciatetheeffort
andwillingnesstobefirst!

To: Green, Melissa; Rapelyea, Sean; Fischler, Matt; Hill, Kathleen; Koronides, Christine
Subject: RE: URGENT: CALL
Seanshouldchimeintoo,butIthinkitwentverywell.TheyseemedmuchmoreengagedthantheirDCcounterparts
andmorefocusedonlocalissues(astobeexpected).Belowarethequestionstheyaskedandissuesdiscuss:
Questionstheyaskedandweanswered:
Gangviolence
Violenceagainsttransgenderedindividuals
violenceonthenorthsideinuptownandrogerspark
statusofbodyworncamerapilot
Reentryresources
istherearecentuptickinviolence?Ifso,whatscausingit?
Otherissueswediscussed:
CommissionforaSaferChicago
youthemployment
reentryresources
restorativejusticeinschools
alternativesforarrestedyouth
gangcallins
Federalgrantstosupportviolencereductionstrategy(PSN)andbodyworncamerapilot
trainingforofficers
responsetoLaquanMcDonaldshootingandstatusofinvestigation
newstreetdrugsandwhatsinthem
StaffforCongressmanDaviscomplimentedtheofficersinthe11thdistrictforproactivepolicing
From: Green, Melissa

To: Rountree, Janey; Rapelyea, Sean; Fischler, Matt; Hill, Kathleen; Koronides, Christine
Youwillbegreat,theywillbemonsters.Andifyourteamcantracktheirquestionswldbegreat!

Subject: Re: URGENT: CALL
Okwillletyouknowhowitgoes
From:Green,Melissa
Sent:Thursday,June11,20153:02:24PM
To:Rountree,Janey;Rapelyea,Sean;Fischler,Matt;Hill,Kathleen;Koronides,Christine
Subject:RE:URGENT:CALL
Dontusephone.Itchangesdynamic.Sorryforlastminuteaudible

Defertoseanaboutwhetheranyoftheotherattendeeshadplannedtocallin
From: Green, Melissa

To: Rapelyea, Sean; Rountree, Janey; Fischler, Matt; Hill, Kathleen; Koronides, Christine
Subject: URGENT: CALL
Guys,arewetheonlypeoplecallingin?ifso,wearegoingtonotcallin.thereissomethingabtitthatdoesntfeelright
andruinsrhythmofinperson.Katie/Mattcanyoutakereallygoodnotesonwhatdelegationfolksask?
MelissaGreen
Director,FederalAffairsOffice
OfficeofMayorRahmEmanuel
[email protected]
From:
Sent:
To:
Subject:
Attachments:
Maxson, Mark J. <[email protected]>

Rasmas, Chloe;Rottner, Jennifer E.;Rountree, Janey;Collins, Adam
RE: FOIA meeting this afternoon
Copy of June 23, 2015.xls
Follow Up Flag:
Flag Status:
Follow up
Completed
Hi Chloe,
I'm lucky to have 193MB of email storage. Most of the staff here have only 50MB.
There in no new agenda for CPD FOIA. We try our best to process them as best we can. I spoke to Bill B. and attached
an updated Media/PAC/Lawsuit list. I'll try to update it Wednesday but I think there is FOIA field trip to Homan Square to
look at records.
Mark
From: Rasmas, Chloe [mailto:[email protected]]

Sent: Tuesday, June 23, 2015 1:36 PM
To: Maxson, Mark J.; Rottner, Jennifer E.; Rountree, Janey; Collins, Adam
Subject: RE: FOIA meeting this afternoon
HiMarkmyemailyesterdaybouncedbackbecauseitsaidthereyourinboxwasfull.IsthereanewagendaforCPD
FOIAs?
From: Maxson, Mark J. [mailto:[email protected]]

Sent: Friday, June 19, 2015 5:01 PM
To: Rottner, Jennifer E.; Rountree, Janey; Rasmas, Chloe; Collins, Adam
Subject: RE: FOIA meeting this afternoon
There is at least one other lawsuit not on this list.

Mark
12 CH 29764 / JOHN LOMBARDI V. CITY
pro se
13 CH 02061 / KILROY WATKINS V. CPD
Margaret Lundahl
13 CH 03703 / VERNON TOLBERT V. CPD
pro se
13 CH 19726 / EDWARD MITCHELL V. CPD
pro se
13 CH 27271 / YOHN ZAPADA V. CPD
pro se
14 CH 09565 / FREDDY MARTINEZ V. CPD
Matt Topic
14 CH 15338 / FREDDY MARTINEZ V. CPD
Matt Topic
14 CH 16844 / BGA V. CPD
Matt Topic
14 CH 17675 / ELBERT L. CONWAY V. CITY
pro se
14 CH 17958 / LAMONT GRIFFIN V. CPD
pro se
1
14 CH 18779 / SARAH CUNNIF V. CITY
Shiller Preyer Law Office
14 CH 19067 / BRANDON SMITH V. CPD AND S&S
Matt Topic
14 CH 19165 / JENNIFER HELSBY V. CPD
Matt Topic
14 CH 20224 / JAMES MCROY V. CPD
pro se
14 MR 117 / VIRGIL ROBINSON V. CPD
pro se
15 CH 01308 / KILROY WATKINS V. CPD
Margaret Lundahl
15 CH 02324 / JAMES WALKER, JEFF BOYD V. CPD
Matt Topic
15 CH 03492 / JAMIE KALVEN V CPD
Matt Topic
15 CH 04183 / BGA V. CPD, DOL AND MO
Matt Topic
15 CH 04547 / TONY WILLIAMS V. CPD
pro se
15 CH 04993 / JARED KOSOGLAD V. CPD
Matt Topic
15 CH 05426 / DANIEL RODRIGUEZ V. CPD
pro se
15 CH 06157 / GUARDIAN NEWS & MEDIA LLC V. CPD

15 CH 06646 / BGA V. CPD
Brendan Healy, Mandell

Menkes
Matt Topic
15 CH 07941 / SEAN STARR V. CPD
Paul Geiger
15 CH 6646 / BGA v. CPD
Matt Topic
From: Rottner, Jennifer E.

To: '[email protected]'; '[email protected]'; '[email protected]'
Cc: Maxson, Mark J.
Subject: Re: FOIA meeting this afternoon
+MarkbutIthinkheistiedupwiththerally.IwillsendyouthelastoneIreceived
From: Rountree, Janey [mailto:[email protected]]
To: Rasmas, Chloe <[email protected]>; Collins, Adam <[email protected]>; Rottner,
Jennifer E.
Subject: FOIA meeting this afternoon
Hiall,
CanIgetanupdateonwherewearewithCPDFOIA?Jennisthereanupdatedspreadsheet?
Thanks
From:
Sent:
To:
Cc:
Subject:
Attachments:
Holden, John
Franklin, Liza;Platt, Thomas
Reader story on police involved shootings
Reader- IPRA recommends firing CPD officer 062915.docx
HILizaandTom
FYI,thisistheChicagoReaderstorythatpromptedtheTribunestoryontheIPRArecommendationaboutfiringOfficer
Perez.Forwhatitisworth,thesecondhalfofthestorytriestorecapthenumberofofficerscurrentlyondeskduty,
includingServin,VanDyke,etc.
John
From:
Sent:
To:
Cc:
Subject:
Peters, Lynda
Monday, July 06, 2015 11:01 AM
Breymaier, Shannon;Holden, John;Patton, Stephen;Darling, Leslie
Ritter, Amber
Re: Ch. 5 interview request
LyndaPeters
CityProsecutor
Sent:Monday,July6,201510:42:29AM
To:Holden,John;Patton,Stephen;Darling,Leslie
Cc:Peters,Lynda;Ritter,Amber
Subject:RE:Ch.5interviewrequest
.
If they want to get a general comment from the city in writing, we may consider that, depending on where they
but definitely not an interview.
Shannon Breymaier
O: 312-744-9045 C:
[email protected]
From: Holden, John
Sent: Monday, July 06, 2015 9:44 AM
To: Patton, Stephen; Darling, Leslie
Cc: Breymaier, Shannon; Peters, Lynda; Ritter, Amber
Subject: FW: Ch. 5 interview request
FYI.Pleaseletmeknowhowyouwouldlikemetorespond.BasedonpasthistorywithCarolMarin,theywouldlikely
balkinprovidingquestionsinadvance,butIwouldrecommendaskingforatleastagenerallineofquestionsbefore
evenconsideringit.

Sent: Monday, July 06, 2015 9:29 AM
To: Holden, John
Subject: Ch. 5 interview
John,
We will do a story this week or next (not sure yet) on the emails we received. To that point is it possible to do an interview
with Steve Patton? The story will be based on what is in the e-mails and so we are looking at the city's mindset in settling
the case. I don't believe at this writing there is anything controversial from the city's standpoint.
Thanks,
1
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
-----Original Message----From: Holden, John <[email protected]>
To: dmose92480 <[email protected]>
Sent: Mon, Jun 29, 2015 6:43 pm
HiDonIhadafamilyemergencycropupovertheweekendandhavebeenouttodayatahospital.Iwasunderthe
impressionacolleaguewouldrespondtoyoubutifyoudon'tgetittodaythentomorrowforsure.Sorryforthedelay.
John
From:[email protected]<[email protected]>
Sent:Monday,June29,20154:40:42PM
To:Holden,John
Subject:Re:NBC5FOIA
Hi John,
Checking on our promised FOIA.
Thanks,
Don
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
To: dmose92480 <[email protected]>
Sent: Wed, Jun 24, 2015 3:21 pm
Subject: RE: NBC5 FOIA
HiDonYes,youwillbegettingrecordsandwejustneedadditionalreviewingtimethataccommodatesvarious
schedules.Thanksforyourpatience.John

To: Holden, John
Of course...can you tell me why?

And I am assuming (I hope correctly) that the extension means there are documents forthcoming?
2
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
To: Don Moseley <[email protected]>
Sent: Wed, Jun 24, 2015 1:46 pm
Subject: RE: NBC5 FOIA
HiDon
IknowwehaveadeadlinetomorrowonyourFOIA,butwoulditbepossibletogetyourconsentforacoupleofextra
daysuntilMondayforourresponse?
Thankyou,
JohnHolden
From: Don Moseley [mailto:[email protected]]

To: Holden, John
Yes. Confirmed. Thanks again
Don Moseley
On Jun 11, 2015, at 2:51 PM, Holden, John <[email protected]> wrote:
ThanksDon.JustsothatwecanafullandexplicitlywordedFOIArequestonthisallinoneplace,can
youpleaseconfirmthatthatwouldbe:
We are requesting searches of the email accounts and/or letters or correspondence of Department of
Law employees Stephen Patton, Thomas Platt and Liza Franklin in which the name LaQuan (or Laquan)
McDonald is used for the time period of Oct. 20, 2014 to June 11, 2015.
John

To: Holden, John
Subject: NBC5 FOIA
John,
This is to clarify our most recent FOIA request. We are requesting searches of the email accounts and/or
letters or correspondence using the names of Department of Law employees in the FOIA letter we sent in
which the name LaQuan (or Laquan) McDonald is used.
3
Thanks for your attention,

Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and
may contain legally privileged and/or confidential information. If you are not the intended recipient of this
e-mail (or the person responsible for delivering this document to the intended recipient), you are hereby
notified that any dissemination, distribution, printing or copying of this e-mail, and any attachment thereto,
is strictly prohibited. If you have received this e-mail in error, please respond to the individual sending the
From:
Sent:
To:
Subject:
Attachments:
Fischler, Matt
Tuesday, July 07, 2015 11:10 AM
Rountree, Janey
project list
Public Safety To Do List_June 9 notes (1).docx; Public Safety Team Check - June 19.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
attachedmynotesfromourlastcheckinandthenthenotesfromjune9thathasthefulllist
From:
Sent:
To:
Subject:
Attachments:
Ritter, Amber
Tuesday, July 07, 2015 6:04 PM
Holden, John;Patton, Stephen;Darling, Leslie;Breymaier, Shannon;Platt, Thomas
RE: Channel 5 emails
Pages from 3.pdf
Iseethetopofthefirstemailwascutoff.Hereitisinitsentirety.
From: Holden, John

Sent: Tuesday, July 07, 2015 5:56 PM
To: Patton, Stephen; Darling, Leslie; Breymaier, Shannon; Platt, Thomas
Cc: Ritter, Amber
Subject: Channel 5 emails
AttachedaretheemailsandattachmentsthatDonMoseleysaidwouldbereferencedinChannel5sstoryonthe
McDonaldsettlement,whichhesaidisslatedtoairThursdayinthe10p.m.newscast.Hesaidthestoryisgoingtolook
athowthesettlementdecisionwasmade.ItoldDonwewouldnotbeavailableforaninterviewbutsaidifhehadany
specificquestionsheneededaddressed,heshouldsendthemtome.Hesaidhethoughttheywereo.k.,butnotedhe
wasstilltryingtotrackdownvideoortranscriptsoftheFinanceCommitteehearingforStevescomments.
JohnHolden
O:(312)7441575
C:(312)
[email protected]
From:
Sent:
To:
Subject:
Breymaier, Shannon
Thursday, July 09, 2015 9:10 PM
Breymaier, Shannon
Tomorrow's News
Follow Up Flag:
Flag Status:
Follow up
Completed
FRIDAY
AMTV:MREtoannouncethatFreshMovesMobileMarketswillprovideaffordablefreshfruitsandvegetablesinfood
desertcommunitiesonthecityssouthandwestsides.
ABC7,NBC5,CBS2,WGN9,ST:MREandCTAannounceda$30MPurpleLineExpressImprovementProject,whichwill
improveservicereliabilitythroughtrackmodernizationwork.
CT/Hal,Reuters/Pierog,WBEZ/Arnold,WTTWChicagoTonight/Friedman,ABC7,AP:Coverageoftoday'spension
hearing.DOLprovidedastatementconsistentwithpreviouspensionmessaging.ThejudgeisscheduledtoruleonJuly
24.
CBS2,ABC7,Crains/Gallun&Ori,WTTWChicagoTonight/Klauss,CT/Blair:StoriesonMarinaCityreceivingapreliminary
recommendationasaLandmarkDistrict.Itsthefirststepinamonthslongprocessthatcouldleadtoafinal
recommendationbytheCommissionsometimenextyear.Thatfinalrecommendation,ifapproved,wouldbeforwarded
toCityCouncil.
AP,WindyCityTimes,WGN9:Dr.Moritadidtargetedinterviewsonthecontinuingmeningitisoutbreakfollowingan
aldermanicbriefingonwhatCDPHisdoingtoprovidevaccinationstothosemostvulnerable.
ST/Fitz,CT/Juan,WBEZ/Vevea:CoverageoftheUSDOEannouncementofagreementwithCPStoensurethatdistrictis
compliantwithTitleIX.CPSprovidedastatementdemonstratingtheworkbeingdonetocomeintocompliance.
CT/Byrne,BGA/Karp,WBEZ/Vevea:CoverageofCCCtrusteemeetinginwhichthetuitionincreaseresolutionpassed.
CCCpushedbackhardonthemtoreflecttheaccuratecomparisonofoldtuitionstructurev.newone;evenw/
increases,CCCremainsthecheapestcommunitycollegealternativeforChicagoans.
CT/Kass:ColumnonimmigrationandvotingsparkedbyTrump'srecentcomments;willnotethatpeopledonothaveto
becitizenstovoteinLSCelections.
CBS2,FOX32,NBC5:StoriesfollowinguponstatementsmadebyAntonioBrown'sattorney;CPDconfirmedthathemet
withpolicebutdidnotcommentonwhatwasdiscussed.
CBS2,ABC7,NBC5:StoryonauseofforceincidentfromJunethatwascapturedonvideo.IPRAisinvestigatingandCPD
releasedastatementinresponse.OfficerremainsonfulldutybcIPRAhasnotrecommendedstrippinghimasofyet.
NBC5/Marin:AnotherstoryabouttheLaquanMcDonaldpoliceinvolvedshootingfocusingonemailsobtainedthrougha
FOIArequest.SomeoftheemailscontainconversationbetweenDOLandMcDonaldsattorneysaboutsettlement
negotiations,andMarinmayfocusonanemailoutliningsomeoftheplaintiffsinitialdemands.Marinalsoexpressed
1
interestinemailsinwhichstaffersofMPO,DOLandCPDforwardedanarticletoeachotherabouttheshootingthatwas
publishedinSlate.
CBS2/Zekman:FollowuptoherstoryonfoodinspectionsattheTasteofChicago.Shevisitedthreevendorsandclaimed,
followingherowntemperatureinspection,thatthreeofthesevenproductssheboughthadtemperatureviolations.
CDPHprovidedastatementabouttheproperproceduresfortemperatureinspections,thattheyaredoneinthekitchen
andnotafterfoodiswalkedawayfromthevendor,todispelherclaims.
NBC5:StoryaboutavideofeaturinganofficerbeingverballyabusiveduringanarrestinJune.IPRAandIADarejointly
investigating.
ABC7:CoverageofvisitbyAuburnUniversityofficialstoSchmidElementaryaftersecondgraderscreatedacollegeday
videothatwentviral.AthleticDirectorJayJacobsandAubie,theschoolmascot,surprisedthestudentswithatripto
AuburninSeptember.RetiredathleteandalumnusBoJackson,alsosurprisedstudentswithanupcomingtriptoaWhite
Soxgame.
PBSNewsHour:Nationalstoryongunviolence,willincludeaninterviewwiththePendletons.SuptMcCarthywillalso
discusschallengesfacingCPDintermsofaccountabilityforgunoffenders.
AP:StoryongunviolenceandchallengesfacingtheCPDintermsofaccountabilityforgunoffenders.Willinclude
interviewwithSuptMcCarthy.
CT/Gillers:Frontpagestoryonthebondissue,thefactthatweareissuingtaxablebondsandwhythepaymentshave
increasedforthisissue.Wesaidweexpecttheretobecontinuedinterestamonginvestorsandcontinued
acknowledgmentoftheMREsfinancialreforms.Shewilllikelysaythatwearestillscoopingandtossing,butframingin
otherways.WillincludecommentaryfromMattFabianonhowwewentaboutstructuringthedeal.Weexpectthatshe
willhitusoncontinuedborrowing.
ST/Schlickerman(possible):Storyaboutcityoverpaymentstosomefirefighter/EMTs;themoneyisnowbeingrecouped
fromemployeepaychecksoverthenextthreepayperiods.OBMoutlinedtheerror,explainingthattheoverpayments
weremadetothosethatwerenotyeteligibleforincentivepaybecausetheyhadnotservedintheirpositionsforlong
enough.WealsoexplainedthestepsCFD,DHRandOBMwilltaketopreventthisfromhappeningagain.
ST/Fitz:Storyinspiredbylastweek'sCBSpieceabouthowMovingEverest,acharteroperator,employedgiveawaysand
rafflestoattractfamiliestoenroll.CPSsaidthatwestronglydiscouragethesetactics,andencourageparentstoselect
schoolsbasedonacademicofferings.
STWire/Rezin:CoverageofalawsuitfiledbyastudentatPhillipsAcademy,whoclaimshewasassaultedbyaCPS
securityguard.CPSdeclinedtocommentonpendinglitigation.
Crain's:CoverageofLandmarkCommissionapprovalofroofdeckforGrouponheadquartersat600W.Chicago.
Crains/Ori:ItemaboutLandmarks'PermitReviewCommitteeapprovingarooftopdeckontheformerMontgomery
Wardcomplex.Passedwithoutcontroversy.
DNAinfo/Ludwig:StoryaboutParkDistrictBoardapprovingacontracttohaveSMGmanagetheupcomingMorganPark
SportsCenter.WillquoteSMGrepswhospokeatthemeetingabouthowthisfacilityisamuchneededamenityinthe
southsidethatwillalsogeneratemoneyfortheparkdistrict.
DNAinfo/Watson:Storyaboutatreeinthe15thwardthatfellonMondayanddamagedacar.DSSprovideddataonthe
significantamountofforestryworkperformedinthe15thward,pushingbackagainstcommentsfromsomeresidents
whoclaimnoforestryworkisdoneintheward.DSSalsosaidweprioritizetreeremovals/trimsandthatMREincreased
2
fundingtoenableadditionalweekendforestryworkthisyear.Despitethefactspresentedtoher,thereporterwilllikely
onlywriteabouttheonefelledtreeandnotmentionthedepartment'sotherworkintheward.
________________________________
From:
Sent:
To:
Subject:
Attachments:
Ritter, Amber
Friday, July 10, 2015 10:14 AM
Darling, Leslie
FW: Channel 5 emails
Pages from 3.pdf
From: Ritter, Amber

Cc: Darling, Leslie
Subject: RE: Channel 5 emails
PRIVILEGEDANDCONFIDENTIAL
Theresnocommentary,though.FWIW,JohntoldmethatMarinsproducerreferredtoanemailbetweenSteveand
RalphPrice,forwardingaKalvenarticle,inwhichtherewascommentaryaboutrecenteventscomplicatingthingsfor
CPD.However,asyoucansee(attached),thephrasearecentlyobtainedreportonthedeadteencomplicatesthe
ChicagoPoliceDepartmentsstory,whichappearsinthesubjectlineoftheemail,isactuallythetitleofthearticleand
iscertainlynotCitycommentary.
ImnotsureifJohnmisunderstoodMarinsproducerorifMarinsproducermisunderstoodtheemail.IadvisedJohnto
makesureitwasclear.

To: Ritter, Amber; Holden, John; Patton, Stephen; Darling, Leslie; Platt, Thomas
Ah, that would explain the discrepancy. Thanks, Amber.

Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Ritter, Amber
To: Breymaier, Shannon; Holden, John; Patton, Stephen; Darling, Leslie; Platt, Thomas
FYI,ShannonlaterforwardedthischaintoLeslie,reflectedintheattachment.
From: Ritter, Amber

To: Breymaier, Shannon; Holden, John; Patton, Stephen; Darling, Leslie; Platt, Thomas
Actually,itlookslikeJohnscopycutoffthetopofseveralpages.Theemailthatappearsonpg.3ofthePDFJohnsent,
forwardingtheKalvenarticletotheteam,isfromAdam.Iamattachingabettercopyofithere.
TherestofthecopiesinhisPDFlookfine.

To: Holden, John; Patton, Stephen; Darling, Leslie; Platt, Thomas
Cc: Ritter, Amber
John, you told me over the phone that they were focusing on commentary attached to the emails concerning
the slate article and that Adam Collins was circulating the clip. The attachments you sent include neither
commentary or Adams email address. Can you please clarify what Don is focusing on, since these emails dont
match the description you provided to me by phone?
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Holden, John
To: Patton, Stephen; Darling, Leslie; Breymaier, Shannon; Platt, Thomas
Cc: Ritter, Amber
Subject: Channel 5 emails
AttachedaretheemailsandattachmentsthatDonMoseleysaidwouldbereferencedinChannel5sstoryonthe
McDonaldsettlement,whichhesaidisslatedtoairThursdayinthe10p.m.newscast.Hesaidthestoryisgoingtolook
athowthesettlementdecisionwasmade.ItoldDonwewouldnotbeavailableforaninterviewbutsaidifhehadany
specificquestionsheneededaddressed,heshouldsendthemtome.Hesaidhethoughttheywereo.k.,butnotedhe
wasstilltryingtotrackdownvideoortranscriptsoftheFinanceCommitteehearingforStevescomments.
JohnHolden
O:(312)7441575
C:(312)7184240
[email protected]
From: Patton, Stephen [[email protected]]

Sent: Wednesday, February 11, 2015 6:46 AM
To: Ralph Price
Subject: Re: Laquan McDonald shooting: A recently obtained autopsy report on the dead teen
complicates the Chicago Police Departments story.
Thanks.
________________________________________
From: Price, Ralph M. <[email protected]>
Sent: Wednesday, February 11, 2015 4:27:53 AM
To: Patton, Stephen
Subject: Laquan McDonald shooting: A recently obtained autopsy report on the dead teen
complicates the Chicago Police Departments story.
http://www.slate.com/articles/news_and_politics/politics/2015/02/laquan_mcdonald_shooting_a_recently_obtained_autopsy_report_on_the_dead.html
From:
Sent:
To:
Subject:
Breymaier, Shannon
Friday, July 10, 2015 5:22 PM
Holden, John;Patton, Stephen;Darling, Leslie
RE: Corrected online version
I dont think this update helps us much at all. It also still contains previous language (twice) highlighted in
yellow below.
This mistake is the crux of their entire story if you had a conversation with NBC to clarify before the story
ran, they wouldnt have had a story at all and we wouldnt be in this position. This is a completely unnecessary
self-inflicted wound that should and could have been easily avoided.
Shannon Breymaier
O: 312-744-9045 C:
[email protected]
From: Holden, John
Sent: Friday, July 10, 2015 5:08 PM
To: Patton, Stephen; Darling, Leslie; Breymaier, Shannon
Subject: Corrected online version
Theyamendedtheonlinestorywhichclarifiesthesubjectlineissue,butleavesinthereferencetotheChicagoPolice
Departmentsstory.IhavetoldDontwicethatitwasnottheChicagoPoliceDepartmentsstorybutrathertheFOPs.I
willcontinuetomonitor.
City Emails Refer to Complications In Police

Version of How Teen Was Shot
An autopsy report on the slain teen complicates the Chicago Police Departments story
By Carol Marin and Don Moseley
Emails released by the city's Law Department, following a Freedom of Information Act request, refer to complications in the Chicago Police
Departments story of how 17-year-old LaQuan McDonald was shot and killed. NBC Chicago's Carol Marin reports. (Published Thursday, Jul 9,
2015)
Updated 25 minutes ago
Emails released by the city's Law Department, following a Freedom of Information Act request, refer to complications in the Chicago Police
Departments story of how 17-year-old LaQuan McDonald was shot and killed.
At 4:27 on the morning of Feb. 11 and again at 5:28 a.m., Ralph Price, an attorney for the Chicago Police Department, e-mailed Corporation Counsel
Stephen Patton using the description in the link about the McDonald shooting posted on the website Slate: A recently obtained autopsy report on the
dead teen complicates the Chicago Police Departments story.
McDonald was shot 16 times on the night of October 20, 2014 after being stopped by Chicago police who responded to a call of a man with a knife.
According to attorneys for the estate of McDonald, a single officer fired the 16 shots, nine of which struck him in the back.
1
The attorneys say an unreleased video from a camera in a police vehicle show McDonald was on the ground and in a fetal position when some of the
shots were fired.
On the scene the night of the shooting a spokesman for the Fraternal Order of Police said McDonald lunged at officers and the shots were fired in
self-defense.
On Feb. 10, at 8:07 p.m. the website Slate posted a story titled Sixteen Shots by independent journalist Jamie Kalven. The story detailed how a
witness said McDonald was moving away from police, not lunging at them as the FOP spokesman originally said.
Kalven also first outlined details from the Medical Examiners autopsy, writing: The autopsy raises questions not only about how [McDonald] died,
but about how the Chicago Police Department has handled the case since.
Minutes later at 8:23 p.m., Adam Collins, a Deputy Press Secretary in the mayors office, according to emails provided by the city, sent a link of the
article to the Mayor Rahm Emanuels Chief of Staff and two mayoral assistants, as well as to Steve Patton, the city's Corporation Counsel.
Early on the next morning, Feb. 11, Price, an attorney for the Chicago police department, sent his e-mail to the citys top lawyer with the subject line:
A recently obtained autopsy report on the dead teen complicates the Chicago Police Departments story.
Price included a link to Kalvens story.
Patton replied in a return e-mail at 6:46 a.m.: Thanks.
A city Law Department spokesman said the Price e-mail did not reflect the citys viewpoint.
The e-mails suggest, however, that officials in both the Corporation Counsels office and the mayors office were closely monitoring what was being
reported with Chicagos mayoral election, at the time, less than two weeks away.
Early on the next morning on Feb. 11, Ralph Price, an attorney for the Chicago police department, wrote in an email to the citys top lawyer: A
recently obtained autopsy report on the dead teen complicates the Chicago Police Departments story.
Price included a link to Kalvens story. Patton replied in a return email at 6:46 a.m.: "Thanks.
The emails suggest officials in both the Corporation Counsels office and the mayors office were closely monitoring what was being reported with
Chicagos mayoral election, at the time, less than two weeks away.
LaQuan McDonald was shot less than three months after Michael Brown was shot and killed by an officer in Ferguson, Missouri, prompting national
attention on the police department in the St. Louis, Missouri suburbs.
On March 6 attorney Jeff Neslund, who along with Michael Robbins represents the McDonald family, wrote to the Corporation Counsels office.
The letter was released as part of the FOIA request and included the following: This case will undoubtedly bring a microscope of national attention
to the shooting itself as well as the citys pattern, practice and procedures in rubber- stamping fatal police shootings of African Americans as
'justified' . I submit this particular shooting can be fairly characterized as a gratuitous execution and as well as a hate crime."
The following month, the city announced it was offering a $5 million settlement in the case, although no lawsuit had been filed.
On April 9 Collins, in an email sent to Patton, as well as one of his top assistants and an assistant to the mayor, wrote in the subject line: Possible
inquires: CPD/McDonald shooting and noted the following Monday, April 13 the City Council Finance Committee would hear of the proposed
settlement agreement.
Two days later without debate the full city council approved the McDonald settlement.
The FBI and the U.S. Attorneys office, as well as the Cook County States Attorneys office have said they are investigating the McDonald
shooting.
From:
Sent:
To:
Subject:
Ewing, Clothilde
Collins, Adam
Fw: (NEWS) NBC5 News at 10PM: NBC5 investigates Laquan McDonald shooting
Follow Up Flag:
Flag Status:
Follow up
Flagged
From:NewsClips
Sent:Friday,July10,20154:12:08AM
Subject:(NEWS)NBC5Newsat10PM:NBC5investigatesLaquanMcDonaldshooting
NBC5Newsat10PM:NBC5investigatesLaquanMcDonaldshooting
ANCHOR:Nbc5investigateshowcityofficialscametobelievetherewereproblemswiththefatalshootingof
LaquanMcDonald.He'stheteenagershot16timesbyaChicagocop.Thedetailscomeinemailsreleasedin
Nbc5investigatesunderFreedomofInformationAct.HeresCarolMarin.
MARIN:OnFebruary11thofthisyearanattorneyfortheChicagopolicedepartmenttoldthecity'stoplawyer
quotetherewerecomplicationsinthepolicedepartment'saccountjustifyingtheshootingofLaquan
McDonald.17yearoldLaquanMcDonaldwassurroundedbytenChicagopoliceofficersonthenightof
October20th,2014accordingtoattorneysfortheMcDonaldfamily.Officersrespondedtocallofmanwitha
knife.Thefirstofficersonthescenerequestedataser.AswehavereportedattorneysforMcDonaldsfamily
sayoneofthelaterarrivingofficersfired16timeswithhisservicerevolver,eachshotstrikinghim.In
December2014,freelancereporterJamieKalvenwasthefirsttoreportonwhathappenedthatnightat41st
andPulaski.
KALVEN:Thestorytoldatthesitebythespokesmanforthefraternalorderofpoliceisboylungesatpolice
withtheknife.We'retolditsselfdefense,justifiedshooting.
MARIN:OnFebruary10that8:07Kalvenreportedhislateststoryonthewebsiteslatedetailingin16shotshow
awitnesssaidMcDonaldwasmovingawayfrompolice,notlungingatthemandKalvenalsooutlinedforthe
firsttimedetailsfromtheautopsy.QuotetheautopsyraisesquestionsnotonlyabouthowheMcDonalddied
butabouthowtheChicagopolicedepartmenthashandledthecasesince.At8:23p.m.,AdamCollins,the
deputypresssecretaryinthemayor'sofficeaccordingtoemailsprovidedbythecity,sentalinkofthearticle
tothemayor'schiefofstaffandtwomayoralassistantsaswellastoStephenPattoncitycorporationcouncil.
Theemailsuggestboththemayor'sofficeandthecorporatecouncilwerecloselymonitoringmediareportsof
thiscase.AtthetimeitwastwoweeksbeforetheFebruarymayoralelection.Themorningafterstory
appearedat4:27a.m.andagainat5:28a.m.,RalphPrice,anattorneyfortheChicagopolicedepartmente
mailedPattonthesubjectlinereadingarecentlyobtainedautopsyreportonthedeadteencomplicatesthe
Chicagospolicedepartmentsstory.Pattonrepliedinareturnemailat6:46amthanks.LaquanMcDonaldwas
shotlessthanthreemonthsafterMichaelBrownwaskilledbyanofficerinFerguson,Missouriprompting
nationaloutrage.TheMcDonaldshootingwascapturedonapolicedashcamerabuthasnotmadepublic.On
March6th,theattorneyJeffNeslundwrotetothecorporationcouncil'sofficethisquotethiscasewill
undoubtedlybringamicroscopeofnationalattention.Isubmitthisparticularshootingcanbefairly
characterizedasangratuitousexecutionandaswellasahatecrime.Withinamonth,thecasewasallbut
1
settled.TheFBI,theU.S.Attorney'soffice,thecookcountystateattorney'sofficeandafederalgrandjuryare
allcurrentlyprobingtheshootingofLaquanMcDonald.
ANCHOR:Thanks.
From:
Sent:
To:
Subject:
Darling, Leslie
Ritter, Amber
Re: revised article
Gotit.Thanks.
>OnJul13,2015,at10:50AM,Ritter,Amber<[email protected]>wrote:
>
>Oddly,itwontletmeclipthelinktosend.IfoundtherevisedarticlebygooglingMarinlaquancomplicatesits
thefirsthit.
>
>
>Thisemail,andanyattachmentsthereto,isintendedonlyforusebytheaddressee(s)namedhereinandmaycontain
From:
Sent:
To:
Cc:
Subject:
Breymaier, Shannon
Rottner, Jennifer E.;Guglielmi, Anthony
Rountree, Janey;Ritter, Amber
RE: NBC story
Good morning! Any chance I can get an update on this before 10:30 am?
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
Sent: Monday, July 13, 2015 4:52 PM
To: Breymaier, Shannon; Guglielmi, Anthony
Cc: Rountree, Janey; Ritter, Amber
Subject: RE: NBC story
Waiting to find out.

From: Breymaier, Shannon [mailto:[email protected]]
To: Rottner, Jennifer E.; Guglielmi, Anthony
OK, thanks do you know if they actually sent responsive documents or if they just sent a denial? If not, well
just wait to see what the response says when you receive it.
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
So FOIA just told me they sent it out to him last week. I only have a copy of the original request, not the response. Just
asked them to send it over to me.
Thanks so much, Jenn.

Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
Will reach out to FOIA now and see what they can tell me.
OK, this may be a problem, unless the FOIA officers reached out to Don on day five and day 10 of his request
to ask for more time to respond (and they would have needed to agree to any extension beyond 10 days). Has
there been any correspondence sent to Don in regard to this FOIA?
Also, Jenn, you said that CPD was likely going to claim the request was burdensome, but if the burdensome
request wasnt made within 10 days of the request, youve blown the burdensome argument and will have to
produce all of the records.
Can you please find out ASAP as to what has been communicated to Don/NBC on this request so we can figure
out how best to proceed?
Thanks so much!
Shannon
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
Just sent you his email. Looks like they submitted something May 27th and it was in regards to performance review of
cameras.
Subject: Re: NBC story
Also,whendidtheysubmittheirFOIAtoCPD(andwhatwastheFOIAfor?)
2
From:Rottner,JenniferE.<[email protected]>
Sent:Monday,July13,20154:04:31PM
To:Guglielmi,Anthony;Breymaier,Shannon
Subject:RE:NBCstory
Thanks Shannon!
I spoke with Deputy Chief Lewin and the information Don FOIAd has not yet been released to him (and will likely be
denied for several reasons-burdensome, etc).
Going to connect again with Jonathan tomorrow about how/if we want to respond about his questions regarding
video/audio in marked cars, but we may just give him some general language, as we know where he is likely going with
this.
Thanks!
From: Guglielmi, Anthony

Cc: Rottner, Jennifer E.
ThanksShannon!.JennRottneronmyteamisworkingonthisonewithourITfolks.
__
Anthony Guglielmi
Director, Communications & News Affairs
Office of the Police Superintendent
Phone: 312-745-6110
Cell: 312-545-3251
@AJGuglielmi | @Chicago_Police
www.chicagopolice.org

To: Guglielmi, Anthony
Subject: NBC story
Anthony
Don Mosely at NBC tells law that they are running another Laquan McDonald story on Wednesday or Thursday
night. They said they are working with CPD and that the angle is about audio on police dash cam.
Just wanted to make sure this is on your radar please let me know if you have any questions.
Thanks!
Shannon
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
3
From:
Sent:
To:
Subject:
Attachments:
Platt, Thomas
Dunn, James
settlement
Paul Wolf.pdf
HereistheletterfromPaulWolfrereturnoftheproceeds
ThomasJ.Platt
3127444833
LAW OFFICES OF
MITCHELL, HOFFMAN &WOLF,L.L.C.

221 North LaSalle Street, Suite 11.48
PAUL P. WOLF
J. WESLEY MITCHELL
KENNETH A. HOFFMAN
GABRIEL A. ZUNINO
TELEPHONE(312) 726.6722
FACSIMILE(312) 7263220
TOLL FREE(888)719.6160
TONYA GONZALEZ o PARALEGAL
www.mitchellhoffmanwolf.com
July 14,2015
VIA HAND DELIVERY

Thomas Platt
30 N. LaSalle
Room 900
Chicago,IL 60602
Re:
Estate of Laquan McDonald

No.: 14 P 7092
Mr. Platt:
As requested, I am providing an explanation in writing regarding the necessity of the
Defendant, City of Chicago,(or its liability insurer) to directly fund the structured annuity with
. After the initial
the settlement money that is apportioned to the DCFS minor,
funding of the structured settlement, the City of Chicago (or its liability insurer) can assign its
obligation to a substituted obligor, who thereafter remains liable on the payment obligations.
This is done pursuant to a qualified assignment.
Ifthe above procedure is not followed, the tax benefits to the minor are lost. Specifically,
the minor will lose the tax benefits associated with a qualified structure, in that all amounts
received would no longer be free from federal income tax. The only way to assure that the
income interest generated from the long term structured payments is not taxable is by the
Defendant,(or its liability insurer) to directly purchase and fund the structure.
As you are aware the above procedure was not followed in this case. Rather, all the
settlement money was paid to the Plaintiffs' attorneys and deposited into their client trust
account. Accordingly, it would be the Plaintiffs' attorneys who would be funding any structured
settlement from their trust account resulting in anon-qualified structure, all to the detriment of
the minor.
Page 2
Addtionally, the City of Chicago made the settlement payment to the Plaintiffs' attorneys
prior to any Probate Court approval ofthe settlement. Without prior approval, the Defendant had
no authority to pay any settlement amount and the Plaintiffs' Administrator had no authority to
sign a release. If the parties had followed the Probate Court rules, the settlement amount would
never have been paid out until a qualified structure had been approved for the benefit of the
DCFS, minor.
As the Court's appointed Guardian Ad Litem, I must inform the Court of the parties'
representatives' failure to follow the Probate rules and procedures. Of course this can all be
avoided by the parties having the money being returned to the City since there was no authority
to distribute it in the first place and wait for proper Probate Court approval of the settlement,
distribution, and structure. At that time, the Administrator can legally sign the release and the
City can directly fund the structure with the portion of money that the Court approves should be
distributed to the minor.
Lastly, I have retained Don Engels of Galaher Settlements to provide us with a structured
annuity proposal for approval by the Probate Court. Should you need any additional
information, please do not hesitate to contact me.
Very truly yours,
Paul Wolf
cc:
Michael D. Robbins
Jeffrey J. Neslund
Donald Engels
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Spielfogel, David;Ewing, Clothilde
FW: July and August strategies.doc
July and August strategies.doc
Follow Up Flag:
Flag Status:
Follow up
Completed
Hithereattachedaremyfirstthoughtsonacommsplanforlatesummer.IonlysentittoAnthonyat3:45andhe
hasnthadachancetoaddintherestoftheCPDstuff.Iexpecttogetitfromhimlatertonightortomorrowmorning.
Justwantedtoletyouknowitsinprogress.

To: Guglielmi, Anthony ([email protected])
Subject: July and August strategies.doc
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Wednesday, July 15, 2015 8:20 AM
Rountree, Janey
Fwd: July and August strategies.doc
July and August strategies.doc
What's the status of this and the david Kennedy event in our office? Who has seen?
-------- Original message -------From: "Guglielmi, Anthony" <[email protected]>
Date: 07/15/2015 7:09 AM (GMT-05:00)
To: "Rountree, Janey" <[email protected]>
Cc: "Collins, Adam" <[email protected]>
Subject: RE: July and August strategies.doc
Resendingwithattachment
From:
Sent:
To:
Cc:
Subject:
Breymaier, Shannon
Jennifer E. Rottner;Anthony Guglielmi
Rountree, Janey;Collins, Adam
Re: NBC story
Follow Up Flag:
Flag Status:
Follow up
Completed
Thanksfortheupdate!
From:Rottner,JenniferE.<[email protected]>
Sent:Thursday,July16,201512:07:45PM
To:Breymaier,Shannon;Guglielmi,Anthony
Cc:Rountree,Janey;Collins,Adam
Subject:RE:NBCstory
We sent over this statement:
The Department remains committed to technological investments that improve officer and public safety, promote
transparency and strengthen accountability. In-car cameras are vital in our efforts to gather relevant evidence and assist
in the investigation and resolution of officer-involved incidents. Today, almost eight hundred vehicles are equipped with incar camera systems. Chicago has one of the largest such deployments in the United States. The Department will continue
to evaluate new technology and national best practices as it determines the possible expansion of camera systems.

Sent: Thursday, July 16, 2015 12:00 PM
Cc: Rountree, Janey; Collins, Adam
Per DOL, this NBC story is running tonight. Did you all ever send them a response as to their questions about
police dash cams/audio on the cams?
Thanks!
Shannon Breymaier
O: 312-744-9045 C:
[email protected]

Waiting to find out.

CHAIN CONTINUES AS
PREVIOUSLY PRODUCED
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Hill, Kathleen;Iweagwu, Tony;Fischler, Matt
Public Safety To Do List_June 9 notes (1).docx
Public Safety To Do List_June 9 notes (1).docx
Follow Up Flag:
Flag Status:
Follow up
Completed
Higuys,
Forourlongoverduecheckintomorrow,willyouupdatetheattacheddocumentandalsosendmeseparatelyaquick
descriptionofhowyourespendingyourtimethesedays,iewhichprojects?TomorrowIwilltrytoprioritizethework
thatweredoingoverthenextfewmonthsandmakesuretheworkisdistributedevenlyacrossthegroupandby
interestifpossible.Isetitupfor90minutessowecanalsofinishthediscussionofnewideastowardtheend.
Seeyoutomorrow!
From:
Sent:
To:
Cc:
Subject:
Breymaier, Shannon
Breymaier, Shannon
Akinlemibola, Grace;Anthony Guglielmi;Chavez, Claudia;Claypool, Forrest;Deal,
Joe;Diette, Clay;Escareno, Rosa;Ewing, Clothilde;Faulman, Mike;Hall, Abby;Harte,
Meghan;Koch, Steven;Laws, Lisa;Mondry, Lauren;Negron, Michael;Nelson, Ashli;Payne,
Mark;PRESS_LIST;Rapelyea, Sean;Rendina, Michael;Rivera, Arnaldo;Rountree,
Janey;Spielfogel, David;Urbina-McCarthy, Mary;Yager, Katherine
Tomorrow's News
Follow Up Flag:
Flag Status:
Follow up
Completed
FRIDAY
AMTV:MREtocelebratewithsomeofthe200,000Chicagoworkerswhoreceivedaraisethismonthduetothe
minimumwageincrease.
AMTV:MREreleasesconceptualrenderingsofGatelyParktrack&field,whichwillbethefirstpublicindoortrack&field
inthecity.
Everyone:MREnamesnewleadershipteamatCPS.
ABC5/Hope,NBC7/CharlieW,Crain's/Pletz,CT/Jessica,possiblyothers:CoverageofKraftHeinzHQannouncement.MRE
didinterviewsontopicwithABCandNBCfocusingonthereasonswhytheywouldlocateinChicagoandthevalueofthe
move.
NBC5/Marin:AnotherstoryabouttheLaquanMcDonaldshooting,thisonefocusingontheprevalenceofCPDdash
cameras.CPDexplainedthatincarcamerasarevitalinoureffortstogatherrelevantevidence,andthedepartmentis
committedtotechnologicalimprovementsthatpromotepublicandofficersafety,improvetransparencyandstrengthen
accountability.Storyshouldalsoincludearetractionfromarelatedstorylastweekthatmischaracterizedanemail
communicationbetweenCPDandDOL.
Univision:CoverageofColumbianartistatDowntownSoundtonight.
Univision/Avila:Storyaboutastudent
whoranawayfromtheRayGrahamTrainingCenter.Theschoolimmediatelyreportedtheincidenttothepolice,and
thestudentwassafelyreturnedhomelaterintheday.
CT/HeatherandHal,BondBuyer/Yvette,Bloomberg/Elizabeth,Reuters/Karen:StoriesontheCity'sbondissue.Will
includestatementnotinginvestorsbeingbullishonChicagoandthattheywereoversubscribed.CTwilllikelyfocuson
theinterestpaymentsthatwillbedueover30yearsandthecosttothecityofdoingtaxablebonds.
WSJ:Nationalstoryaboutthehighandincreasingcostoflegalsettlementsresultingfrompoliceshootingsinthewake
ofMondaysNY$5.9MsettlementforthedeathofEricGarner.Chicagoismentionedasoneofthecitieswiththe
highestpolicesettlementcosts,andtheMcDonaldshootingandBurgehistoryarebothmentioned,thoughChicagoisby
nomeansthefocusofthestory.
CT/Hilk:StoryonthepriceincreaseforDivvydailypassesstartingJuly22.Cmsr.Scheinfeldsaidthiswillprimarilyimpact
outoftownDivvyusers,as~2/3ofdailyusersarevisitors.CDOTstressedthatevenwiththepricechange,Divvyisa
greatdealandaverycompetitivepricefor24hoursofaccessthatallowsuserstoexploreChicagoandallitsparks,
neighborhoodsandrecreationalamenitiesinafunandactiveway.
CT/Perez:ProfilepieceonDr.JaniceJackson,thecitysnewchiefedofficerandhervisionforleadingschools.
CT/Long:Storyabout$35MinstatefundsdesignatedforvariousconstructionprojectsatCPS.Likelytobecriticalof
stateprocedures.
STWire/Owen:StoryoncustomersapprehendingasuspectwhohadassaultedawomanontheRedLinenearBelmont.
ACTAworkerwasreportedlyonsceneandnotassistingintheencounter.Atthispoint,theCTAoperatorhadalready
notifiedCPD.CPDapprehendedthesuspect.
DNAInfo/Lulay:StoryaboutthelaunchofthePilsenFarmersMarket.DCASEsaidthatthelaunchhasbeendelayedin
ordertomeetcommunityexpectations.DCASEisworkingwithAldermanSolisofficetolaunchthemarketonJuly22
withaspecialperformancebyElasticArts.
DNAInfo/Lulay:StoryaboutimplicationsonschoolstarttimeshiftsaspartofCPS'costsavings.Storywillquestionthe
impactstoeducationbymovingbelltimes,assomestudiesshowthathighschoolstudentperformbetterwhenthey
startlater.
DNAInfo/Bloom:StoryonantiharassmentadvocatespeakingatCTAboardmeetingaboutincidentsofsexual
harassmentandaskingthatCTAincreaseawarenessthroughacampaignorothermeans.CTAsaidwedidacampaigna
fewyearsagothatestablishedguidelinesforreportingandrespondingtoreportsofincidents.CTAisalreadylookingat
waystoimprovecommunicationsandawarenessofthisissuethroughitsregular,ongoingpubliceducationand
campaignefforts.
________________________________
From:
Sent:
To:
Subject:
Holden, John
Breymaier, Shannon;Higgins, Jessica
RE: BGA Response
Itsmellslikeafishingexpeditiontome.Ithinkoverallheisjusttryingtoadvanceanissuethathasbeengetting
attentionfromothermembersofthemedia.
IamnotsureifhewillbebeenawareofthestoryinyesterdaysWallStreetJournal,butthewholepayoutonpolice
casesissueisonethatalotofreportershavebeenchippingawayat.
http://www.wsj.com/articles/costofpolicemisconductcasessoarsinbiguscities1437013834
John

To: Higgins, Jessica; Holden, John
Subject: Re: BGA Response
HeusuallyfollowsupwithQs.Hedoesalotoffishingexpeditionsonpolicesettlements.
From:Higgins,Jessica
Sent:Friday,July17,201512:30:15PM
To:Holden,John
Cc:Breymaier,Shannon
Subject:Re:BGAResponse
OkSorryagainforthedelay.IfSteveandShannonareok,I'mok.
Doweknowwhat/whenhe'sdoingwithit?
OnJul17,2015,at1:03PM,Holden,John<[email protected]>wrote:
No,stillwaitingforthefinalapproval.

Sent: Friday, July 17, 2015 11:59 AM
To: Higgins, Jessica
Cc: Holden, John; Darling, Leslie
Subject: RE: BGA Response
John?
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
1

From: Higgins, Jessica
SorryI'vebeenintheair.Hasthisgoneout?
OnJul17,2015,at10:38AM,Breymaier,Shannon<[email protected]>wrote:
Otherwise, Im fine with this going out today
+Jess for awareness. Can you hold off on sending until about 11 to give Jess time
to take a peek in case she has any questions? Thanks.
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Holden, John

Cc: Darling, Leslie
Subject: BGA Response
HiShannon
AttachedaretwoversionsofthepossibleresponsetoAndrewsrequest.Thefirstisthe
completelistofalltheresolvedfatalshootingcasesinvolvingpayments(totalingabout
$42million)andthesecondisthewrongfuldeath(e.g.statebutnotfederal)cases
thatheactuallyaskedforinhisrequest.
IjustreviewedbothwithSteveandhewassomewhatagnostic,butwascomfortable
goingwiththenarrowedlist.
Iamabletodiscussinthemorning.IthinkwewillhaveaprettyhotAndrewifwedont
getbacktohimtomorrowwiththeresponse.
John
This e-mail, and any attachments thereto, is intended only for use by the
addressee(s) named herein and may contain legally privileged and/or confidential
information. If you are not the intended recipient of this e-mail (or the person
responsible for delivering this document to the intended recipient), you are hereby
notified that any dissemination, distribution, printing or copying of this e-mail,
and any attachment thereto, is strictly prohibited. If you have received this e-mail
in error, please respond to the individual sending the message, and permanently
<Schroedter Shooting Case Report 071315.doc>
<Fatal Shootings Cases with Payments, 1-1-10 to 7-15-15.xlsx>
<Wrongful Death Cases with Payments, 1-1-10 to 7-15-15.xlsx>
From:
Sent:
To:
Cc:
Subject:
Breymaier, Shannon
Holden, John;Higgins, Jessica
Darling, Leslie
RE: BGA Response
You can go ahead and send now since Jess and I are OK.
Shannon Breymaier
O: 312-744-9045 C: 312-859-2719
[email protected]
From: Holden, John
To: Breymaier, Shannon; Higgins, Jessica
Cc: Darling, Leslie
Myplanwastopullthetriggeronthisaround3p.m.Letmeknowifyouhaveanylastthoughtsbeforehand.

To: Higgins, Jessica; Holden, John
HeusuallyfollowsupwithQs.Hedoesalotoffishingexpeditionsonpolicesettlements.
From:Higgins,Jessica
To:Holden,John
Cc:Breymaier,Shannon
Subject:Re:BGAResponse
OkSorryagainforthedelay.IfSteveandShannonareok,I'mok.
Doweknowwhat/whenhe'sdoingwithit?
OnJul17,2015,at1:03PM,Holden,John<[email protected]>wrote:
No,stillwaitingforthefinalapproval.

To: Higgins, Jessica
John?
CHAIN CONTINUES AS
PREVIOUSLY PRODUCED
From:
Sent:
To:
Subject:
Goodmann, Daniel <[email protected]>

Platt, Thomas
Re: Hunter (EO LaQuan McDonald) - No. 14 P 7092
ThanksTom.Enjoytheweekendandmybesttoyourlovelybride.
DanielJGoodmann
ManagingDirector
(312)5957055Office
(312)5431834Cell
SentfrommyiPhone
OnJul17,2015,at5:46PM,Platt,Thomas<[email protected]>wrote:
HaveleftfordaybutwillreviewMonday.
From:Goodmann,Daniel<[email protected]>
To:Platt,Thomas;McGregor,Lorraine;Dunn,James
Cc:Real,Elizabeth
Subject:FW:Hunter(EOLaQuanMcDonald)No.14P7092
DearTom:
AttachedarethefollowingdocumentspertainingtothestructuredsettlementfortheEstateofLaQuan
McDonald.
Premium Check(s) Request: Please note, the premium check is due in our office by July 30,
2015inordertomaintainthecurrentcostandbenefits.
Qualified Assignment, Release and Pledge Agreement (Pacific): Please have this signed on
page 4 and initialed on page 5 on behalf of the City of Chicago, as Assignor. We will send a
separatecopyoftheagreementtotheplaintiffsstructuredsettlementrepresentativeforthem
toobtaintheplaintiffssignaturesandinitials.
QualifiedAssignment,ReleaseandPledgeAgreement(Berkshire):Pleasehavethissignedon
page 5 and initialed on page 6 on behalf of the City of Chicago, as Assignor. We will send a
separatecopyoftheagreementtotheplaintiffsstructuredsettlementrepresentativeforthem
toobtaintheplaintiffssignaturesandinitials.
Draft of the Release and Settlement Agreement: Feel free to make any changes and/or
additionstothelanguagethatarenecessaryforthiscase,exceptforSections6(ii)through11.0,
whicharerequiredbythelifeinsurancecompaniesinordertocomplywithIRCguidelines.Once
a final draft of the agreement has been prepared, we would appreciate the opportunity to
reviewitpriortoexecutionbytheparties.Afterithasbeensignedbyallparties,pleasereturn
ittoourofficebyemail.Thelanguageisbasedonthesettlementagreementyouhadsentto
meonApril1,2015.Ifthereareanyissues,pleaseadvise.
1

Ifyouhaveanyquestions,pleasedonothesitatetocontactme.
Thankyou.
Dan
Daniel J. Goodmann, CSSC

Managing Director - Structured Settlements
Mesirow Financial
353 North Clark Street
Chicago, IL 60654
(312) 595-7055 Direct Line
(877) 772-4436 Toll Free
(312) 595-6736 Desktop Fax
(312) 595-4440 Office Fax
(312) 543-1834 - iPhone
[email protected]
This communication may contain privileged and/or confidential information. It is intended solely for the use of the
addressee. If you are not the intended recipient, you are strictly prohibited from disclosing, copying, distributing or
using any of this information. If you received this communication in error, please contact the sender immediately and
destroy the material in its entirety, whether electronic or hard copy. Confidential, proprietary or time-sensitive
communications should not be transmitted via the Internet, as there can be no assurance of actual or timely delivery,
receipt and/or confidentiality. This is not an offer, or solicitation of any offer to buy or sell any security, investment or
other product.
Visit us on the Web at mesirowfinancial.com

This communication may contain privileged and/or confidential information. It is intended solely
for the use of the addressee. If you are not the intended recipient, you are strictly prohibited from
disclosing, copying, distributing or using any of this information. If you received this
communication in error, please contact the sender immediately and destroy the material in its
entirety, whether electronic or hard copy. Confidential, proprietary or time-sensitive
communications should not be transmitted via the Internet, as there can be no assurance of
actual or timely delivery, receipt and/or confidentiality. This is not an offer, or solicitation of any
offer to buy or sell any security, investment or other product.
This communication may contain privileged and/or confidential information. It is intended solely for the use of
the addressee. If you are not the intended recipient, you are strictly prohibited from disclosing, copying,
distributing or using any of this information. If you received this communication in error, please contact the
sender immediately and destroy the material in its entirety, whether electronic or hard copy. Confidential,
proprietary or time-sensitive communications should not be transmitted via the Internet, as there can be no
2
assurance of actual or timely delivery, receipt and/or confidentiality. This is not an offer, or solicitation of any
From:
Sent:
To:
Subject:
Attachments:
Platt, Thomas
[email protected]
Mesirow docs Hunter
Goodman cover email July 17.docx; Hunter - FCRLD COMPTROLLER CHECKLIST
(Berkshire).pdf; Hunter - FCRLD COMPTROLLER CHECKLIST (Pacific Life).pdf; Hunter Premium Check(s) Request.pdf; Hunter - Qualified Assignment Release & Pledge
(Berkshire).pdf; Hunter - Qualified Assignment Release & Pledge (Pacific).pdf; Hunter Release & Settlement Agreement 071715.docx
MaterialsfromDanGoodman
ThomasJ.Platt
3127444833
From:
Sent:
To:
Cc:
Subject:
Attachments:
Goodmann, Daniel <[email protected]>

Monday, July 20, 2015 12:49 PM
Platt, Thomas
Dunn, James;Real, Elizabeth
RE: Hunter revised release
Goodmann revised 07-20-2015 Hunter - Release Settlement Agreement.docx
Attachedistherevisedreleaseandagreement.Werevisedparagraph7takingoutdf.
Onceweknowtheturnaroundtimeonthechecks,letmeknow.Ifwehavetopushfunding,itwillaffectthebenefits.
Thankyouagainforalltheaccommodationsyouhavemadeinthismatterandyourpatience.

Mesirow Financial
Chicago, IL 60654
(312) 595-7055 Direct Line
(877) 772-4436 Toll Free
(312) 595-6736 Desktop Fax
(312) 595-4440 Office Fax
(312) 543-1834 - iPhone
[email protected]
From: Platt, Thomas [mailto:[email protected]]

To: Goodmann, Daniel
Cc: Dunn, James
Subject: Hunter revised release
Dan
Irevisedcertainpartsofthereleaseandsettlement.Par.5iscompletelyredone.Thereareadditionstopar.4andpar.
12.Allamendmentswereunderlinedandboldedforyourconvenience
ThomasJ.Platt
3127444833
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - PROBATE DIVISION
TINA HUNTER, as Independent Administrator
of the Estate of LaQUAN McDONALD, Deceased
)
Claim
ant,
vs.
)
CITY OF CHICAGO, a municipal corporation
)
Defendant.
)
)
)
)
No.
14 P 7092
)
)
RELEASE AND SETTLEMENT AGREEMENT

Tina Hunter, mother of decedent LaQuan McDonald (also known as LeQuan McDonald)
and as Independent Adm inistrator of the Estate of LaQuan McDonald, (hereinafter, the Estate
of LaQuan McDonald), by her attorneys, Jeffrey
J. Neslund Law Offices and Law Office of
Michael D. Robbins & Associates, and Defendant, City of Chicago, by its attorney, Stephen R.
Patton, Corporation Counsel of the City of Chi
cago, by one of his attorneys, Thom
as Platt,
Deputy Corporation Counsel, herein stipulate and agree to the following:

1.
The Estate of LaQuan McDonald 14 P 7092, Circuit Court of Cook County, has
brought a claim against City of Chicago and its employees, Chicago Police Officer Jason Van
Dyke, Star 9465, Officer Joseph Walsh, Star
12865, Detective David March, Star 20563,
Sergeant Daniel Gallagher, Star 1303, Lieutena nt Anthony Wojcik, Star 481, Detective Richard
Hagen, Star 20606 and other Chicago Police officer
s and e mployees of the City of Chicago
arising out of the fatal shooting of LaQuan McDonald on October 20, 2014 for which the Estate
of LaQuan McDonald claims damages.
2.
City of Chicago denies Estate of LaQuan McDonalds allegations of wrongdoing

3.
The parties and their respective attorn eys ack nowledge that settlem ent of this
claim is not an admission of liability, or of unconstitutional or illegal conduct by or on the part of

the City of Chicago of its future, cu rrent or former officers, agents and employees, and shall no t
1
serve as evidence of any wrongdoing
by or on the part of
the City of Chicago or its future,
current or form er officers, agen ts and em ployees. The p arties and their respective atto rneys
further a cknowledge tha t se ttlement is m ade to avoid the uncertainty of the outcom e of any
litigation an d the expen se in tim e and m oney of litiga tion and f or the purpose of judicia l
economy.
4.
In consideration of the hereinafter indi cated settlem ent ente red pursuan t to this
Release and Settlement Agreement, and upon advice of counsel, the Estate of LaQuan McDonald
agrees not to file any lawsuit, claim or cause of action of any kind at any time in any jurisdiction,
including but not lim ited to, any claim s under the Illinois W rongful Death Act, the Illinois
Survival Act and claim s under 42 U.S.C 1983 ag ainst C ity of Chicago, Officer Jason Van
Hagen, Star 20606 or any of its cu rrent, future or form er officers, agents and em ployees with
respect to the inciden t set f orth in paragraph one of this Release and Settlem ent Agreem ent
except solely in the ev
ent that the Chicago C
ity Council rejects the hereinafter indicated
settlement, with each p arty bearing its own costs and attorneys fees.
The Estate of LaQuan
McDonald agrees it will be r equired to ex ecute the Release and Settlem ent Agreement prior to
the Citys presentation of the
settlement agreem ent to the Ch icago City Council and that the
Estate of LaQuan McDonald offers to settle
on these term s shall not be revoked or otherwise
repudiated unless the Chicago City Council rejects the se ttlement agreement. The City Council
approved the amount of the settlement on April 15, 2015.
5.
The City of Chicago and Estate of LaQuanMcDonald agree that the fact or existence
and terms of this settlement agreement, including but not limited to this Release and Settlement
Agreement, shall remain confidential until the Chicago City Council approves an ordinance
authorizing this agreement. The City of Chicago and Estate of LaQuan McDonald and its attorneys
further acknowledge and agree that there is an ongoing criminal investigation by the federal and
state authorities of the incident which is the subject of this release and settlement agreement
(incident), and that potential evidence and materials (materials) relating to this investigation
2
and potential criminal charges, were obtained by the Estate of LaQuan McDonald in response to
subpoenas issued in the matter of Estate of LaQuan McDonald, 14 P 7092, Circuit Court of Cook
County. The City of Chicago submits that release or dissemination of these materials could
interfere with and have an adverse impact on the ongoing criminal investigation and potential
charges brought with respect to this incident. Estate of LaQuan McDonald and its attorneys
therefore agree not to publicly release, disclose or disseminate the materials obtained through
subpoenas issued in 14 P 7092 (materials), until the completion of the pending criminal
investigations and, if criminal charges are brought, the conclusion of such criminal charges by way
of plea agreement, trial or dismissal, unless these materials are otherwise publicly disclosed or
disclosed as required by law or court order. Estate of LaQuan McDonald and its attorneys agree
that they will not make any copies or distribute these materials to any other persons or entities and
will provide seven days written notice to the City of Chicago, its attorneys or successors prior to
any publication, dissemination of release of the above mentioned materials.
6.
Estate of LaQuan McDonald accepts
Chicago, in the total am
a settlem ent from Defendant, City of
ount of FIVE MILLION DOLLA
RS AND NO/100 DOLLARS
($5,000,000.00), inclusive of all costs and attorneys fees, payable as follows:

(i)
Cash Payment at Settlem ent:
Three Million One Hundred Seventy Six
Thousand Six Hundred Sixty Seven and 00/ 100 Dollars ($3,176,667.00) payable to Tina
Hunter, as Independent Adm inistrator of th e Estate of LaQuan McDonald, and their
attorneys, the Law Office of Je ffrey J. Neslund, to be disbursed as directed by the Circuit
Court of Cook County, Illinois, Probate Division, Case No. 14 P 7092.
(ii) Structured
Settlement/Annuity Funding: Nine Hundred Twenty Six
Thousand, Ninety and no/100 Dollars ($926,090.00) payable to Pacific Life &Annuity
Services, Inc. in order to fund the future pe
riodic paym ents set forth below in Section
6.2(a).
(iii) Structured
Settlement/Annuity Funding: Eight Hundred Ninety Seven

3
Thousand, Two Hundred Forty Three and no/100 Dollars ($897,243.00) payable to BHG
Structured Settlements, Inc. in order to fund the future peri odic payments set forth below
in Section 6.2(b).
6.2
Future periodic paym ents (th e P eriodic Pay ments) m ade accord ing to the
schedule(s) as set forth below:

(a)
Payee:
$500.00 per month, guaranteed 5 years, beginning on July 1, 2018.
The final guaranteed payment will be due on June 1, 2023.
$17,500.00 payable semi-annually, guaranteed 5 years, beginning on
July 1, 2018 (10 paym ents total). The final gu aranteed payment will be
due on January 1, 2023.
$1,708.65 per m onth for the lifetime of
guaranteed 37
years, beginning on July 1, 2023, with the last guaranteed paym ent on
June 1, 2060. The A nnuity Paym ent Am ount m ay be subject to an
annual increase every July 1 st beginning one (1) year after the first
payment and will be ba sed on the lesser of the Index Retu rn during th e
applicable Index Term (first I ndex Term May 15, 2023 through May 15,
2024) and the cap of 5%. If the Index Return during the applicable Index
Term is negative, there will be no increase in the annuity payment amount.
(b)
Payee:
guaranteed 37
years, beginning on July 1, 2023, incr easing at 3% com pounded annually.
$30,000.00 guaranteed lump sum, payable on March 28, 2023.
No part of t he cost of the Period ic Payments may be paid directly to the Claimant or any Payee ,
inasmuch as the parties negotiated for a struct
ured settlement and the P eriodic P ayments. All
sums set for th herein c onstitute da mages on acc ount of personal physica l injuries or sickness,
within the meaning of Section 104(a)(2) of the Internal Revenue Code of 1986, as amended.
7.
Claimant acknowledges that the P
eriodic Paym ents described in Section 6.2
cannot be accelerated, deferred, in creased or d ecreased by the Clai mant or any Pay ee; nor shall
4
the Claimant or any Payee have the power to sell, mortgage, encumber, or anticipate the Periodic
Payments, or any part thereof, by assignment or otherwise.
The Claimant acknowledges and ag rees that neither the peri odic payments nor any rights
thereto or interest therein (collectively, Payment Rights) can be:
(a)
accelerated, deferred, increased or decreased by the Claimant and/or Payees;
(b)
sold, m ortgaged, assigned, pledged, hypot hecated or otherwise transferred or
encumbered, either directly or indirectly, by
the Claimant and Payees unless such sale,
assignment, pledge, hypothecation or other transfer or encu mbrance (any such trans action being
hereinafter referred to as a Transfe r) has been approved in advance in a qualified order a s
outlined in Section 589 1(b)(2) of th e Internal Revenue Code of 1986, as am ended (a Qualified
Order), and approved by the
Circuit Court, County of Cook , State of Illinois, Probate
Division, and otherwise complies with applicable state law, including without limitation any and
all applicable state structured settlem ent protection statues. Any such qualified order m ust be
sought in th e original jurisdiction of the settleme nt and m eet all the standards of necessity and
approved by the court in said jurisdiction.
(c)
Claimant and Payees shall not have th e power to affect a Transfer of Paym ent
Rights except as provided in subparagraph (b
) above, and any other purported Transfer of
Payment Rights shall be wholly void.

8.1
Any remaining guaranteed periodic payments to be made pursuant to the terms of
this Release and Settlement Agreement after the death of

the estate of
shall be made payable to
Once reaching t he age of major ity, any payments to b e m ade
pursuant to the terms of this Re lease and Settlement Agreement af ter the death of Payee
shall be made to such person or entity as designated in wr iting by Payee
to
the City o f Chicagos Assignee. If no person or entity is so de signated by Payee

once reaching age of majority, or if the person designated is not liv ing at the time of the Payee' s
death, such payments shall be made to the estate of the Payee.
8.2
No such designation, nor any revocation ther eof, shall be effective unless it is in
writing and delive red to the City

designation must be in a form
of Chicago or the C ity of Chic agos Assig nee. The
acceptable to th e City of Chicago o r the City of Chicagos
Assignee before such paym ents are m ade, but in no even t shall the reque st of the Payee be
5
unreasonably withheld or denied.

9.1
Claimant acknowledges and agrees that
the City of Chicago shall m
ake a
qualified assignment, within th e meaning of Section 130 (c) of the Internal Revenue Code of
1986, as amended, of the City of Chicagos liability to make the Periodic Payments set forth in:
Section 6.2(a) to Pacific Life & Annuity Services, Inc.;
Section 6.2(b) to BHG Structured Settlements, Inc.;
The Assignees obligation for pa yment of the Periodic Paym ents shall be no greater than
that of the City of Chicago (wheth
er by judg ment or agreem ent) imm ediately preced ing the
assignment of the Period Payments obligation.

9.2
Any such assignment, if made, shall be accepted by the Claimant without right of
rejection an d shall complete ly re lease and dis charge the City of Chi cago from t he Periodic
Payments obligation assigned to the Assignees.
The Claimant recognizes that, in the event of
such an assignment, the Assignees shall be the sole obligor with respect to the Periodic Payments
obligation, and that all other releases with re
pertain to the liability of the
spect to the Periodic Paym ents obligation that
City of Chicago shall thereupon
become final, irrevocable and
absolute.
10.
The City of Chicago, itself or through its Assignees, reserves the right to fund the
liability to make the Periodic Payments outlined in:

Section 6.2(a) from Pacific Life Insurance Company;
Section 6.2(b) from Berkshire Hathaway Life Insurance Company of Nebraska;
(collectively the Annuity Issuers).
The City of Chicago or the Assignees shall be the sole owne r of the ann uity policy and
shall have all rights of ownership.
The City of Chicago, or the Assignees, m
Annuity Issuers m ail paym ents directly to the
ay have the
Payee. The Payee shall be responsible for
maintaining a current mailing address for the Payee with the Annuity Issuers.
11.
The obligation of the City of Chicago a nd/or the Assignees to make each Periodic
Payment sh all b e dis charged upon the m ailing of a valid check or electron ic funds tran sfer
(EFT) in the am ount of such paym ent to the de signated address of the Payee nam ed in Section
6
6.2 of this Release and Settlement Agreement.

12.
The Citys obligation purs uant to this Release and Settlem
conditioned upon approval of the Release and
ent Agreem ent are
Settlement Agreem ent by the C hicago City
Council. The City will not be obligated to perfor m its obligations pursuant to this Release and
settlement Agreem ent until the following even ts o ccur: (1) the City receives a copy of this
Release and Settlement agreement executed by the Estate of LaQuan McDonald and its attorney;
(2) the Chicago City Council enact s an ordinance authorizing se ttlement and paym ent of the
funds agreed upon in this Release and Settlem ent Agreement. The Chicago City Council enacted
an ordinance on April 15, 2015 approving the total amount of the settlement.
13.
The City agrees to pay Claim
ant the total settlem ent amount as specified in
paragraph 6 herein with in thirty (30 ) days of receipt by th e Corporation Counsels Office of a
fully executed settlement agreement, an ordinance of the City Council aut horizing the settlement
as described in p aragraph 6, and any necessary court-entered order in the Circuit Court of Cook
County for the disposition of funds, whichever is
received latest.
The sum s shall be payable
solely by the City of Chicago, and Estate of LaQu an McDonald and its atto rneys agree that they
will not seek paym ent from any source other th an the City of Chicago.
The settlement checks
will be m ake payable as se t f orth in pa ragraph 6. Eac h party her eto sha ll be ar its own
attorneys fees and costs in connection with this Release and Settlement Agreement, the matters
and documents referred to herein, and all related matters.
14.
Agreement, and upon advice of counsel, Estate of LaQuan McDonald agrees to indem nify and
hold harm less the City of Chicago, and its futu
re, current, or former
officers, agents and
employees including, but not lim ited to, Officer Jason Van Dyke, Sta r 9465, Offi cer Joseph
Walsh, Star 12865, Detective David March, S tar 20563, Sergeant Daniel Gallagher, Star 1303,
Lieutenant Anthony Wojcik, Star 481, Detective Richard Hagen, Star 20606 from any claim s,
losses, damages or expenses, including attorney s fees and costs, incurred, or w
incurred, by reason of any lien or any other clai
m or interest held by
hich m ay be
any person, entity o r
corporation against any moneys received or to be received by Estate of LaQuan McDonald under
this settlement entered pursuant to this Release and Settlement Agreement.
7
15.
Estate of LaQuan, upon advice of couns
el, understands and agrees that in
consideration of the se ttlement entered pu rsuant to this R elease and Settlem ent Agreem ent,
Estate of LaQuan McDonald does hereby release and forever discha rge on behalf of him self and
his heirs, ex ecutors, ad ministrators and assigns, all claim s he ha d or ha s a gainst Officer Jason
Van Dyke, Star 9465, Officer Joseph W alsh, Star 12865, Detect ive D avid March, Star 20563,
Hagen, Star 20606 and the City of Chicago, and its fu ture, current or former officers, and agents
and em ployees, including but not lim ited to all cl aims he had, has, or m ay have in the future,
under local, state or federal law, arising either directly or indirectly out of the incident which was
the basis of this claim and any potential litig ation, and that such release and discharge also is
applicable to any and all unnamed agents, employees, officers or persons affiliated with the City
of Chicago.
16.
under paragraph 19 herein contain the entire agreem ent between the parties with regard to the
settlement of this claim, and shall be binding upon and inure to th e benefit of the parties hereto,
jointly and severally, and the heirs, executo
rs, adm inistrators, personal representatives,

17.
shall be construed and interpreted in accordance with its laws.
Terms contained herein shall not
be construed against a party merely because that party is or was the principal drafter.
18.
In entering into this Release an
d Settlement Agreem ent, Estate of LaQuan
McDonald represents that it has relied upon the advice of its attorneys, who is the attorney if its
choice, and that the term s of this Release an d Settlem ent Agreem ent have been inte rpreted,
completely read and explained to the Independent Administrator by its a ttorney, and that those
terms are fully understood and voluntarily accepted by the Estate of LaQuan McDonald.
Estate
of LaQuan McDonald a lso represents and warrants that no o ther person or en tity has or h as had
any in terest in the cla ims or caus es of ac tion referred to herein, an d that the independent
administrator and its attorneys have the sole right and exclusive authority to execute this Release
8
and Settlem ent Agreement and rec eive the su ms specif ic herein, and that they ha ve not sold,
assigned, transferred, conveyed, or otherwise disposed of any of the claims or causes of actio n
referred to herein.
19.
The parties hereto agree to cooperate fu lly and execute any and all supplem entary
documents and to take all addi
tional actions which are consis tent with and which m ay be
necessary or appropriate to give full f orce and effect to the basic terms and intent of this Release
and Settlement Agreement.
City of Chicago
Stephen R. Patton
__________________________________ Corporation
Counsel
Tina Hunter, as Independent Administrator
Attorney for the City of Chicago
of the Estate of LaQuan McDonald, deceased,
Claimant
BY:________________________________
Thomas J. Platt
30 North LaSalle Street Suite 900
(312) 744-4833
Attorney No. _________
Address: ____________________________
____________________________________
Date of birth: _________________________
*SSN: _______________________________
DATE: ______________________________
_____________________________________
Jeffrey J. Neslund
Attorney for Claimant
Jeffrey J. Neslund Law Offices
150 N. Upper Wacker Drive - Suite 2460
(312) 223-1100
Attorney No. ____________
FEIN: ___________
____________________________________
Michael Robbins
Law Office of Michael D. Robbins & Assoc.
20 North Wacker Drive Suite 3710
(312) 899-8000
Attorney No. ______________
FEIN: ___________________
DATE: ______________________________
DATE:______________________________
* Social Security Number is voluntary
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Monday, July 20, 2015 1:11 PM
Guglielmi, Anthony;Rountree, Janey
RE: July and August strategies.doc
July and August strategies v2.doc
TalkedtoAnthony.Thisisreallysolid.Ishiftedafewthingsaroundthatweknowtimingonnow,andIaddedacolumn
toclarifywhoseventitwouldbe.
Fornextsteps,Idreallyliketoslotinacoupleoftheseannouncements(highlightedinyellow).Canwegetoneteedup
fornextweekandonefortheweekafter?
WealsotalkedthismorningaboutaplacedstorywithFrankMainaboutthegangcallins,nowthattheresnewDOJ
pressstaff.Thatcouldbeagreatstory
From: Guglielmi, Anthony [mailto:[email protected]]

Sent: Wednesday, July 15, 2015 6:09 AM
To: Rountree, Janey
Cc: Collins, Adam
Subject: RE: July and August strategies.doc
Resendingwithattachment
From:
Sent:
To:
Subject:
Attachments:
Platt, Thomas
Goodmann, Daniel
RE: Goodmann revised 07-20-2015 Hunter - Release Settlement Agreement (with
Guardian).docx
Goodmann revised 07-21-2015 Hunter - Release Settlement Agreement (with
Guardian).docx
Additionalrevisionsweremadeasattached.
OriginalMessage
From:Goodmann,Daniel[mailto:[email protected]]
Sent:Tuesday,July21,20159:36AM
To:Platt,Thomas
Subject:RE:Goodmannrevised07202015HunterReleaseSettlementAgreement(withGuardian).docx
Ok,thanksfortheheadsup.
DanielJ.Goodmann,CSSC
ManagingDirectorStructuredSettlementsMesirowFinancial
353NorthClarkStreet
Chicago,IL60654
(312)5957055DirectLine
(877)7724436TollFree
(312)5956736DesktopFax
(312)5954440OfficeFax
(312)5431834iPhone
[email protected]
OriginalMessage
From:Platt,Thomas[mailto:[email protected]]
Sent:Tuesday,July21,20159:34AM
To:Goodmann,Daniel
Subject:RE:Goodmannrevised07202015HunterReleaseSettlementAgreement(withGuardian).docx
Iwillbemakingafewmorechanges
OriginalMessage
From:Goodmann,Daniel[mailto:[email protected]]
Sent:Monday,July20,20155:08PM
To:Platt,Thomas;Dunn,James
Cc:Real,Elizabeth
Subject:Goodmannrevised07202015HunterReleaseSettlementAgreement(withGuardian).docx
Hereisthefinalrevisedrelease.Callwithanyquestionsorrevision.Thanksagain!
VisitusontheWebatmesirowfinancial.com
Thiscommunicationmaycontainprivilegedand/orconfidentialinformation.Itisintendedsolelyfortheuseofthe
addressee.Ifyouarenottheintendedrecipient,youarestrictlyprohibitedfromdisclosing,copying,distributingorusing
anyofthisinformation.Ifyoureceivedthiscommunicationinerror,pleasecontactthesenderimmediatelyanddestroy
thematerialinitsentirety,whetherelectronicorhardcopy.Confidential,proprietaryortimesensitivecommunications
shouldnotbetransmittedviatheInternet,astherecanbenoassuranceofactualortimelydelivery,receiptand/or
confidentiality.Thisisnotanoffer,orsolicitationofanyoffertobuyorsellanysecurity,investmentorotherproduct.
________________________________
VisitusontheWebatmesirowfinancial.com
Thiscommunicationmaycontainprivilegedand/orconfidentialinformation.Itisintendedsolelyfortheuseofthe
addressee.Ifyouarenottheintendedrecipient,youarestrictlyprohibitedfromdisclosing,copying,distributingorusing
anyofthisinformation.Ifyoureceivedthiscommunicationinerror,pleasecontactthesenderimmediatelyanddestroy
thematerialinitsentirety,whetherelectronicorhardcopy.Confidential,proprietaryortimesensitivecommunications
shouldnotbetransmittedviatheInternet,astherecanbenoassuranceofactualortimelydelivery,receiptand/or
confidentiality.Thisisnotanoffer,orsolicitationofanyoffertobuyorsellanysecurity,investmentorotherproduct.
IN THE MATTER OF THE ESTATE OF

LaQUAN McDONALD also known as
LeQUAN McDONALD, deceased, by its
)
)
)
)
)
)
)
No . 14 P 7092

Tina Hunter, Independent Administrator of the Estate of LaQuan McDonald, (hereinafter,
the Estate of LaQuan McDonald), and m other of decedent LaQuan McDonald (also known as
LeQuan McDonald) by her attorneys, Jeffrey J. Neslund Law Offices and Law Office of Michael
D. Robbins & Associates, the estate of
a m inor benefici ary of the Estate of
LaQuan McDonald by her court ap pointed guardian, (also d esignated herein as a P ayee) and
City of Chicago, by its attorney, Stephen R. Patt on, Corporation Counsel of the City of Chicago,
by one of his attorneys, Thomas Platt, Deputy Corporation Counsel, herein stipulate and agree to
the following:
1.
The Estate of LaQuan McDonald 14 P 7092, Circuit Court of Cook County, (also
designated herein as Claimant) has brought a claim against City of Chicago and its employees,
Chicago Police Officer Jason Van Dyke, Star 9465, Officer Joseph Walsh, Star 12865, Detective
David March, Star 20563, Sergeant Daniel Galla gher, Star 1303, Lieutenant Anthony W ojcik,
Star 481, Detective Richard Hagen, Star 20606 and other Chicago Police officers and employees
of the City of Chicago arisi ng out of the fatal shooting of
LaQuan McDonald on October 20,
2014 for which the Estate of LaQuan McDonald claims damages.

2.

3.

1
economy.
4.
5.
2
6.

(i)
(ii) Structured
6.2(a).
(iii) Structured
in Section 6.2(b).
6.2

(a)
Payee:
guaranteed 37
3
(b)
Payee:
guaranteed 37
7.
(a)
(b)
4

(c)

8.1

the estate of
Once reaching t he age of major ity, a ny pa yments to be m ade
to

8.2

9.1
ake a
that of the City of Chicago (whether by judgm ent or agreem ent) imm ediately preced ing the
9.2
absolute.
5
10.

ay have the
11.
12.
ent Agreem ent are
13.
received latest.
14.

6
hich m ay be
15.
in cons ideration of th e settlem ent e ntered pursu ant to th is Release and Settlem ent Agreem ent,
of Chicago.
16.

17.
18.
d Se ttlement Agreem ent, Estate of LaQuan
7
Estate
referred to herein.
19.
City of Chicago
Stephen R. Patton
BY:_________________________________ Corporation
Counsel
Claimant
BY:________________________________
Address: _____________________________
Thomas J. Platt
_________________________________
Date of birth: __________________________
(312) 744-4833
DATE: ______________________________
BY:__________________________________
Jeffrey J. Neslund
20 N. Wacker Drive - Suite 3710
(312) 223-1100
FEIN: ___________
DATE: ______________________________
BY:_________________________________
Michael Robbins
(312) 899-8000
Attorney No. ______________
FEIN: ___________________
DATE:______________________________
BY:_____________________________________
Court appointed Guardian of the Estate of
,
a Minor beneficiary of the Estate of LaQuan McDonald
Address: _________________________________
_________________________________________
DATE: __________________________________

)
)
)
)
)
)
)
No . 14 P 7092

Bornstein, a beneficiary of th
a minor by her guardian ad litem, Bruce
e E state of Laquan McDonald,
(also designated herein as a
Payee) an d City of Chicago, by its attorn ey, Stephen R. Patton, Corporation Counsel of th e
City of Chicago, by one of his attorneys, Thom
as Platt, Deputy Corporation Counsel, herein
stipulate and agree to the following:

1.

2.

3.

current or form er officers, agen ts and em ployees. The p arties and their respec tive atto rneys
1
economy.
4.
5.
2
6.

(i)
(ii) Structured
6.2(a).
(iii) Structured
in Section 6.2(b).
6.2

(a)
Payee:
guaranteed 37
3
(b)
Payee:
guaranteed 37
7.
(a)
(b)
4

(c)

8.1

the estate of
to

8.2

9.1
ake a
that of the City of Chicago (whether by judgm ent or agreem ent) imm ediately preced ing the
9.2
absolute.
5
10.

ay have the
11.
12.
ent Agreem ent are
13.
received latest.
14.

6
hich m ay be
15.
of Chicago.
16.

17.
18.
7
Estate
referred to herein.
19.
City of Chicago
Stephen R. Patton
BY:_________________________________ Corporation
Counsel
Claimant
BY:________________________________
Thomas J. Platt
(312) 744-4833
DATE: ______________________________
Address: _____________________________
_____________________________________
Date of birth: __________________________
BY:__________________________________
Jeffrey J. Neslund
150 N. Upper Wacker Drive - Suite 2460
(312) 223-1100
FEIN: ___________
DATE: ______________________________
BY:_________________________________
Michael Robbins
(312) 899-8000
Attorney No. ______________
FEIN: ___________________
DATE:______________________________
BY:_____________________________________
Bruce Bornstein, Guardian of the Estate of
Address: _________________________________
_________________________________________
DATE: __________________________________
A Minor
From:
Sent:
To:
Subject:
Attachments:
Platt, Thomas
Goodmann, Daniel;[email protected]
updated release
Guardian).docx
Foryourreview
ThomasJ.Platt
3127444833
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Rountree, Janey
RE: Comms doc
Follow Up Flag:
Flag Status:
Follow up
Completed

To: Collins, Adam
Subject: Comms doc
Dontforgettosendthattomewheneveryouhaveasec
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Adam Collins ([email protected])
Follow Up Flag:
Flag Status:
Follow up
Completed
IaddedNationalNightOut/FaithinActioninAugust,whichisnotonGFMscalendarbutshouldbesomethingthe
Mayordoes.Weareintheearlystagesofaguntiplineandtraffickingconferencebutneitherarecookedenoughto
includehere.
From:
Sent:
To:
Cc:
Subject:
Attachments:
Laura Coronado <[email protected]>

Platt, Thomas;[email protected];Paul Wolf;Ed
Lau;[email protected]
Michael Robbins;neslundlaw
Mcdonald - Release
Hunter - Release Settlement Agreement (with Guardian) revised 7-21-2015.docx
AttachedpleasefindtheReleasewiththechangesthatMr.PlattandMr.Robbinsdiscussedyesterday,removingMr.
BornsteinsnamefromthefirstparagraphandsignaturelineaswellascorrectingMr.Neslundsaddress.
Thankyou,
LauraCoronado
AssistanttoMichaelD.Robbins
MichaelD.Robbins&Associates
20NorthWackerDrive,Suite3710
Chicago,IL60606
(312)8998000
Fax:(312)7819123
[email protected]
www.lawmdr.com
Thisemailmaycontainprivilegedand/orconfidentialinformation.Ifyouarenottheintendedrecipient,pleasedonot
read,distributeorreproducethisemail.Ifyoubelievethatyouhavereceivedthisemailinerror,immediatelynotify
MichaelD.Robbins&Associatesatthephonenumberprovidedaboveanddeletethisemailfromyoursystem.

)
)
)
)
)
)
)
No. 14 P 7092

, a m inor by her guardian ad litem , a
beneficiary of the Estate of Laquan McDonald, (also designated herein as a Payee) and City o f
Chicago, by its attorney, Stephen R. Patton, Corp oration Counsel of the City of Chicago, by one
of his attorneys, Thom as Platt, Deputy Corpor ation Counsel, herein sti pulate and agree to the
following:
1.

2.

3.

1
economy.
4.
5.
2
6.

(i)
(ii) Structured
6.2(a).
(iii) Structured
in Section 6.2(b).
6.2

(a)
Payee:
ter, guaranteed 37
3
(b)
Payee:
guaranteed 37
7.
(a)
(b)
4

(c)

8.1

the estate of
to

8.2

9.1
ake a
that of the City of Chicago (wheth
er by judg ment or agreem ent) imm ediately preced ing the

9.2
absolute.
5
10.

ay have the
11.
12.
ent Agreem ent are
13.
received latest.
14.

6
hich m ay be
15.
of Chicago.
16.

17.
18.
7
Estate
referred to herein.
19.
City of Chicago
Stephen R. Patton
BY:_________________________________ Corporation
Counsel
Claimant
BY:________________________________
Thomas J. Platt
(312) 744-4833
DATE: ______________________________
Address: _____________________________
_____________________________________
Date of birth: __________________________
BY:__________________________________
Jeffrey J. Neslund
(312) 223-1100
FEIN: ___________
DATE: ______________________________
BY:_________________________________
Michael Robbins
(312) 899-8000
Attorney No. ______________
FEIN: ___________________
DATE:______________________________
BY:_____________________________________
Guardian of the Estate of
A Minor
Address: _________________________________
_________________________________________
DATE: __________________________________
From:
Sent:
To:
Subject:
Rountree, Janey
Thursday, July 23, 2015 11:49 AM
Collins, Adam;Ando, Scott
RE: Updated Davis statement
Follow Up Flag:
Flag Status:
Follow up
Completed
Ithesentenceaboutsustainrate,thereisamissingwordorsomething.Imightalsoreplaceironicallywithin
addition.OtherwiseIamfinewiththis.
From: Collins, Adam

Sent: Thursday, July 23, 2015 11:43 AM
To: Ando, Scott; Rountree, Janey
Subject: Updated Davis statement
Here'sanupdatedversion.Letmeknowyourthoughts.
OVERALL
Chicagoisfairlyuniqueamongmajorcitiesinthatthereisanindependentcivilianinvestigativeagency,separatefrom
thepolicedepartment,whichindependentlyinvestigatesseriousallegationsofpolicemisconductaswellasofficer
involvedshootings,andwetakeourimportantroleextremelyseriously.
IPRAiscommittedtoconductingfair,unbiased,objective,thoroughandtimelyinvestigationsofallegationsofpolice
misconductandofficerinvolvedshootings.Weobjectivelyinvestigateacomplaint,determinethefacts,reachafinding
andmakearecommendationfordisciplinewhenacomplaintissustained.IPRAtakesnosidesnotwiththe
complainantorthedepartmentmemberandwewillnottoleratebiasinanyform.
Asyouwouldexpect,anyfindingmustbebasedonallavailableevidence.Anythinglessdoesadisservicetoour
community,ourresidentsandthoseweinvestigate.
OFFICERINVOLVEDSHOOTINGSANDMISCONDUCTFINDINGS
WhiletherehasbeendiscussionofthenumberofshootingsIPRAhasfoundtobewithinCPDpolicyandstatelaw,each
oftheseincidentshasalsobeenreviewedbyprosecutorsforpossiblecriminalcharges.Suchareviewisastandardpart
ofeveryIPRAinvestigationsoeachincidentisreviewedbytwoindependentinvestigativeagencies.
Thisprocess,whichisinitiatedbyIPRA,hasledtoprosecutorialactionagainstseveralofficersinrecentyearsincluding
DanteServinandGlennEvans.ThepoliceshootingdeathofLaquanMcDonaldiscurrentlyunderfederalinvestigationas
aresultofIPRAspartnershipwithprosecutors.
Moreover,IPRAcurrentlyhasthehighestsustainedrateagainstisitshistoryjustunder13.5%in2014andover20%in
2015thusfar.
DAVISALLEGATIONS
AllIPRAofficerinvolvedshootinginvestigations,andinvestigationsofmisconductforwhichasustainedfindingis
pervisingInvestigator,aDeputyChiefandthe1stDeputyChiefbeforethereport
containingtherecommendationsisgiventotheChiefAdministrator,who,pursuanttotheIPRAordinance,makesa
disciplinaryrecommendationstothePoliceSuperintendent.Thereviewprocessincludesinternaldiscussionsatalllevels
1
ofreviewtoensurethefindingsreachedareaccurateandmeettheburdenofproof,whichisapreponderanceofthe
evidence.
NooneatIPRAhaseverbeenaskedtochangetheirfindings.However,inaverysmallnumberofcases,whenduringthe
courseofasupervisoryreviewitisfoundthatevidencehasbeenexcludedforasummaryfindingoranalysisasupervisor
willrequestthataninvestigatorreviewandincludeallavailableevidenceintheirfindings.
SuchwasthecasewithMr.Davis.Afewcasesheworkedonwerefoundtobeincompletebyallthreelevelsof
managementabovehim,allwithequalorgreaterexperience,becausetheydidnotincludeallavailableevidenceandin
somecaseswerebuiltonassumptions.Ironically, in some cases Mr. Davis rejected the recommendations of his
subordinates and told them to change their recommendations.
OFFTHERECORD:ItshouldbenotedthatlastyearnotasingleinvestigatorotherthanDaviswerefoundtohave
findingsthatdidnotincludeallavailableevidenceinanyofficerinvolvedshootingorexcessiveforce
investigationregardlessofthefindingsinthosecases.
OFFTHERECORD:itsnotaccuratetosaythattheChiefAdministratoroverridesDavis.Itsuggeststhatthe
decisionwasunilateralwheninfact,basedonallavailableevidence,noneofDavissupervisorsagreedwiththe
conclusionshereached.
From:
Sent:
To:
Attachments:
Collins, Adam
Ando, Scott
OVERALL.docx
Follow Up Flag:
Flag Status:
Follow up
Flagged
From:
Sent:
To:
Cc:
Subject:
Holden, John
Breymaier, Shannon
Darling, Leslie
RE: DoL FOIA Response
Thx.

To: Holden, John
Cc: Darling, Leslie
Subject: Re: DoL FOIA Response
I'mfinewithyousendingaslongasLeslieisOK.
From:Holden,John
Sent:Thursday,July23,20151:16PM
Cc:Darling,Leslie
Subject:FW:DoLFOIAResponse
WegotafollowupinquiryfromAndrew(seebelow).Forapproval:hereistheproposedresponsetoAndrewthatSteve
suggested:
Theinformationyourequested,andweprovided,wasforanyandallpaymentsthecitymadetosettleorsatisfya
judgmentinawrongfuldeathlawsuitthatwastheresultofafatalpoliceinvolvedshooting,fromJan.1,2010to
present.YouarecorrectthatthepaymentstheCitymadeinconnectionwiththosecasestotal$21.7million.
YouarealsocorrectthatiftheLaQuanMcDonaldcasehadnotbeensettledbeforeitwasfiled,itlikelywouldhave
claimedwrongfuldeathandthattheamountofthatsettlementwas$5million.
From: Andrew Schroedter [mailto:[email protected]]

To: Holden, John
Subject: Re: DoL FOIA Response
I'm finishing up my story and wanted to confirm:

The records you sent show that since 2010 the city has paid $21.7 million to families or estates of victims
who were shot and killed by police. If you include the $5 million the city recently paid to the family
of Laquan McDonald you have a total of $26.7 million.
Is that correct?
1
On Fri, Jul 17, 2015 at 3:06 PM, Holden, John <[email protected]> wrote:
Dear Mr. Schroedter:
Please find attached to this email a response to your recent Freedom of Information Act request. Thank you for
your patience in this matter.
John Holden
--------------------Senior Investigator
Better Government Association
223 W. Jackson Blvd; #900
Chicago, IL 60606
(p) 312-821-9035
[email protected]
www.bettergov.org
From:
Sent:
To:
Cc:
Subject:
Attachments:

Collins, Adam
Rountree, Janey
Draft
Statement Ando IPRA 07_23_15 (2).doc
Follow Up Flag:
Flag Status:
Follow up
Completed
Look at this. I used track changes

Scott M. Ando
Chief Administrator
Independent Police Review Authority
1615 W. Chicago Ave., 4th Floor
Chicago, IL 60622
Tel. (Direct): 312-746-3551
Cell: 312-545-4379
e-mail: [email protected]
This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged
and/or confidential information. If you are not the intended recipient of this e-mail (or the person responsible for delivering this
document to the intended recipient), you are hereby notified that any dissemination, distribution, printing or copying of this e-mail,
and any attachment thereto, is strictly prohibited. If you have received this e-mail in error, please respond to the individual sending the
From:
Sent:
To:
Cc:
Subject:
Attachments:

Collins, Adam
Rountree, Janey
Emailing: Statement Ando IPRA 07_23_15
Statement Ando IPRA 07_23_15.doc
Follow Up Flag:
Flag Status:
Follow up
Completed
Hereitiswithjustthelineremoved.I'llsendittoLarrytogivetoMSNBC.
Themessageisreadytobesentwiththefollowingfileorlinkattachments:
StatementAndoIPRA07_23_15
Note:Toprotectagainstcomputerviruses,emailprogramsmaypreventsendingorreceivingcertaintypesoffile
attachments.Checkyouremailsecuritysettingstodeterminehowattachmentsarehandled.
From:
Sent:
To:
Cc:
Subject:
Attachments:

Merritt, Larry
Collins, Adam
Emailing: Statement Ando IPRA 07_23_15 (3)
Statement Ando IPRA 07_23_15 (3).doc
Follow Up Flag:
Flag Status:
Follow up
Flagged
ForMSNBC.ReferenceFinnell,byhisownadmissiononhisWBEZinterview,hewasneveraskedto"change"afinding.
Themessageisreadytobesentwiththefollowingfileorlinkattachments:
StatementAndoIPRA07_23_15(3)
Note:Toprotectagainstcomputerviruses,emailprogramsmaypreventsendingorreceivingcertaintypesoffile
attachments.Checkyouremailsecuritysettingstodeterminehowattachmentsarehandled.
From:
Sent:
To:
Cc:
Subject:
Attachments:
Soni, Reshma
Dunn, James
McNally, Meghan;Fuentes, Angelina;Harrison, Gwendolyn;Platt, Thomas;Hernandez,
Fidel;Rakestraw, Karen;GenActg_Journals
RE: DOL refund - McDonald
McDonald refund - 07222015.pdf
ThankyouJim.
Karen/Jerome,sorryfortherushrequestbutwewouldneedtodoaJVtodebittherevenuethatisin
andcredit
for$5,000,000.Thisisfortherefund
receivedfortheMcDonaldcase,Docketnumber14P7092.Canthisbedonetomorrow?Sorryfortherush.wejust
needtomakeapaymentassoonasthecreditisgivenintheexpenseaccount.
Fidel,IwouldassumethatwewouldseethisreceiptintheC2reporteithertomorroworMonday,isthatcorrect?Can
weconfirmoncewereceiveit?Thanks!
Thankyouall!
Reshma
From: Dunn, James

To: Soni, Reshma
Cc: McNally, Meghan; Fuentes, Angelina; Harrison, Gwendolyn; Platt, Thomas
Subject: FW:
Reshma,
AttachedisthedepositreceiptfortheMcDonaldrefund.Thedocketnumberis14P7092.
Theaccountthattheoriginalpaymentwasmadefromis
Letmeknowifyouneedanythingelse.
Jim
JamesL.Dunn
AdministrativeDeputy
DepartmentofLaw
121N.LaSalle600
Chicago,IL60602
[email protected]
3127441558
From: E-Copy_System, Canon

To: Dunn, James
Subject:
T--:- -.~.. _r --,~.._
,v. ~ - ;....,
~~;-,
CODE
,~::,
~`~:,
~;~,
~~;
DEPOSIT SLIP/RECEIPT
CITY OF CHICAGO
Department of Finance
City Hali, Room 107
FUND
~~ \
DEPT.
ORGN.
~~
ACCT.
DOLLARS
~
Receipt No.
Dater
Dept:
CENTS
Iol~
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Maker's Name: ~~
i heck over
Contact Person C~l.~~ c~
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(Print)
Chicago Department of Finance
1Z1 N. LaSalle Street

Room 107
Chica o IL 60602
(312 X47-4747
(312) 744-2975 (TTY)
www,cityofchicago.org/finance
DR - MISC Special Collections
tic 5,000,000.00
5,000,000.00
Caps Code; aa61
Comment: current expense reimJf laquan
mcdoriald
State. IL
Su Total:
To al:
5,000,000.00
5,000,000.00
None Scanned
Checks
5,000,000.00
DR00347
7/22/2015 10;59
#10245627/2299/752
*~~*~~**~~~~ Dl1PLICATE #001 ~~~~~~~~~~~~
7/22/2015
11:01
DR00347
Pay parking tickets, water bills and

other City fees on-line at
www.cityofchicagn.arg.
Please take a few moments to tell us

about your visit today by using the
online Customer Survey at
u~~~~~ ,c i tyofch i cago ,o rgi revenue.
Thank you.
heck No:
Phone No
From:
Sent:
To:
Cc:
Subject:
Quinn, Kelley
Collins, Adam
Rendina, Michael;Ewing, Clothilde;Update_List;Rountree, Janey
Re: Press inquiry: IPRA HR issue
Follow Up Flag:
Flag Status:
Follow up
Completed
Let's get it out.

On Jul 23, 2015, at 6:43 PM, Collins, Adam <[email protected]> wrote:
Are we good with the statement I'd like to movw? We need to get that out thus evening to wbez
-------- Original message -------From: "Collins, Adam" <[email protected]>
Date: 07/23/2015 6:19 PM (GMT-06:00)
To: "Rendina, Michael" <[email protected]>, "Ewing, Clothilde"
<[email protected]>, Update_List <[email protected]>
Cc: "Rountree, Janey" <[email protected]>
Subject: RE: Press inquiry: IPRA HR issue
Here's Raoul. Danny is the fired investigators cousin
State Senator Kwame Raoul, chairman of the Senate Judiciary Committee, said he was deeply
disturbed by the circumstances surrounding the firing of a top employee at the Independent
Police Review Authority. IPRA fired former Chicago Police Commander Lorenzo Davis earlier
this month. The 65-year old Davis said he had found evidence that a half-dozen shootings by
Chicago police officers were NOT justified. He said his bosses at IPRA pressured him and his
colleagues to change those findings, and exonerate the CPD officers involved.
Sen Raoul told FOX 32 News, I think the major problem is that they are asking an experienced
law enforcement officer to change his conclusion. Even if they disagree with him, it is
problematic that they fire him for not changing his conclusion.
Sen. Raoul said hed like to see IPRA investigated by the Illinois State Police, the Illinois
Attorney General or the U.S. Department of Justice.
-------- Original message -------From: "Rendina, Michael" <[email protected]>

Date: 07/23/2015 6:08 PM (GMT-06:00)
<[email protected]>, Update_List <[email protected]>
1

Subject: Re: Press inquiry: IPRA HR issue
Canusendwhatwassaidbyelecteds?
SentfrommyBlackBerry10smartphoneontheVerizonWireless4GLTEnetwork.
From: Collins, Adam
To: Ewing, Clothilde; Update_List
Cc: Rountree, Janey
Yes, and the longer ipra statement too.

The goal here is to address it from our office today so wbez doesn't feel compelled to ask mre
about it in the future
-------- Original message -------From: "Ewing, Clothilde" <[email protected]>
Date: 07/23/2015 5:50 PM (GMT-06:00)
To: "Collins, Adam" <[email protected]>, Update_List
<[email protected]>
DoeshealreadyhavetheofftherecordstuffyouprovidedtoCharles?
From: Collins, Adam
To: Update_List
Cc: Rountree, Janey
ChipMitchellatWBEZcontinuestoaskourofficecommentontheIPRAstoryandcallsfromsomein
recentdays(Sawyer,DannyDavid,KwameRaoul)foraninvestigationintoIPRA.Ithinkweshould
addressitnowwhenhescoveringthestoryanywaysandtrytoavoiddraggingthestoryoutanyfurther.
HereswhatIdliketotellhim,fromme:
ThisisaninternalIPRAmatterthattheyhaveaddressed.IPRAischargedwiththemissionofmaintaining
thehighestlevelofintegritywhileconductingobjective,thoroughinvestigations,andthecitydoesnot
toleratebiasedinvestigationsinanycapacity.Thegoalofeveryinvestigationmustbetofindthetruth
andstriveforjustice.WehaveconfidenceinIPRAandtheimportantroletheyplayasanindependent,
civilianledreviewagency.
From: Collins, Adam

Sent: Thursday, July 23, 2015 11:54 AM
To: Update_List
Cc: Rountree, Janey
Therewas/isaprotestatIPRArightnowonthisfiringandanumberofotherissues.Charles
Thomasisamongthosecoveringanddemandingmoreinfoonthematter.
belowiswhatI'dliketohavethemgivetoinquiringpress.
Weneedtomovethisprettyquickly.Pleaseletmeknowifyouhaveanyissues.
OVERALL
Chicagoisfairlyuniqueamongmajorcitiesinthatthereisanindependentcivilianinvestigativeagency,
separatefromthepolicedepartment,whichindependentlyinvestigatesseriousallegationsofpolice
misconductaswellasofficerinvolvedshootings,andwetakeourimportantroleextremelyseriously.
IPRAiscommittedtoconductingfair,unbiased,objective,thoroughandtimelyinvestigationsof
allegationsofpolicemisconductandofficerinvolvedshootings.Weobjectivelyinvestigateacomplaint,
determinethefacts,reachafindingandmakearecommendationfordisciplinewhenacomplaintis
sustained.IPRAtakesnosidesnotwiththecomplainantorthedepartmentmemberandwewillnot
toleratebiasinanyform.
Asyouwouldexpect,anyfindingmustbebasedonallavailableevidence.Anythinglessdoesa
disservicetoourcommunity,ourresidentsandthoseweinvestigate.
OFFICERINVOLVEDSHOOTINGSANDMISCONDUCTFINDINGS
WhiletherehasbeendiscussionofthenumberofshootingsIPRAhasfoundtobewithinCPDpolicyand
statelaw,eachoftheseincidentshasalsobeenreviewedbyprosecutorsforpossiblecriminalcharges.
SuchareviewisastandardpartofeveryIPRAinvestigationsoeachincidentisreviewedbytwo
independentinvestigativeagencies.
Thisprocess,whichisinitiatedbyIPRA,hasledtoprosecutorialactionagainstseveralofficersinrecent
yearsincludingDanteServinandGlennEvans.ThepoliceshootingdeathofLaquanMcDonaldis
currentlyunderfederalinvestigationasaresultofIPRAspartnershipwithprosecutors.
Moreover,IPRAcurrentlyhasthehighestsustainedrateinitshistoryjustunder13.5%in2014and
over20%in2015thusfar.
DAVISALLEGATIONS
AllIPRAofficerinvolvedshootinginvestigations,andinvestigationsofmisconductforwhichasustained
findingisrecommended,arereviewedbyaSupervisingInvestigator,aDeputyChiefandthe1stDeputy
ChiefbeforethereportcontainingtherecommendationsisgiventotheChiefAdministrator,who,
pursuanttotheIPRAordinance,makesadisciplinaryrecommendationstothePoliceSuperintendent.
Thereviewprocessincludesinternaldiscussionsatalllevelsofreviewtoensurethefindingsreachedare
accurateandmeettheburdenofproof,whichisapreponderanceoftheevidence.
3

NooneatIPRAhaseverbeenaskedtochangetheirfindings.However,inaverysmallnumberofcases,
whenduringthecourseofasupervisoryreviewitisfoundthatevidencehasbeenexcludedfora
summaryfindingoranalysisasupervisorwillrequestthataninvestigatorreviewandincludeall
availableevidenceintheirfindings.
SuchwasthecasewithMr.Davis.Afewcasesheworkedonwerefoundtobeincompletebyallthree
levelsofmanagementabovehim,allwithequalorgreaterexperience,becausetheydidnotincludeall
availableevidenceandinsomecaseswerebuiltonassumptions.In addition, in some cases Mr. Davis
rejected the recommendations of his subordinates and told them to change their
recommendations.
OFFTHERECORD:ItshouldbenotedthatlastyearnotasingleinvestigatorotherthanDavis
werefoundtohavefindingsthatdidnotincludeallavailableevidenceinanyofficerinvolved
shootingorexcessiveforceinvestigationregardlessofthefindingsinthosecases.
OFFTHERECORD:itsnotaccuratetosaythattheChiefAdministratoroverridesDavis.It
suggeststhatthedecisionwasunilateralwheninfact,basedonallavailableevidence,noneof
Davissupervisorsagreedwiththeconclusionshereached.
From:Collins,Adam
Sent:Monday,July20,20153:40PM
To:Update_List
Cc:Rountree,Janey
Subject:RE:Pressinquiry:IPRAHRissue
Wehave3TVschasingthisstorytoday,basedontheslantedversionthatWBEZaired.ABC7/Charles,
CBS2/Tucker,Fox32/Wall.
HereswhatIPRAissaying
Thisisapersonnelmatter,anditwouldbeinappropriatetoaddressitthroughthemedia.IPRAis
committedtoconductingfair,unbiased,objective,thoroughandtimelyinvestigationsofallegationsof
policemisconductandofficerinvolvedshootings.
Chicagoisfairlyuniqueamongmajorcitiesinthatthereisanindependentcivilianinvestigativeagency,
separatefromthepolicedepartment,whichindependentlyinvestigatesseriousallegationsofpolice
misconductaswellasofficerinvolvedshootings,andwetakeourimportantroleextremelyseriously.
IPRAobjectivelyinvestigatesacomplaint,determinesthefacts,reachesafindingandmakesa
recommendationfordisciplinewhenacomplaintissustained.
AllIPRAofficerinvolvedshootinginvestigations,andinvestigationsofmisconductforwhichana
sustainedfindingisrecommended,arereviewedbyaSupervisingInvestigator,aDeputyChiefandthe
1stDeputyChiefbeforethereportcontainingtherecommendationsisgiventotheChiefAdministrator,
who,pursuanttotheIPRAordinance,makesadisciplinaryrecommendationstothePolice
Superintendent.Thereviewprocessincludesinternaldiscussionsatalllevelsofreviewtoensurethe
findingsreachedareaccurateandmeettheburdenofproof,whichisapreponderanceoftheevidence.
OFFTHERECORD
4
IPRAisnotclosewiththeChicagoPoliceDepartment;IPRAisatotallyindependentinvestigativeagency,
althoughwedohaveanecessaryproductiveworkingrelationshipwiththem,whichisabsolutely
necessaryforthedisciplinaryprocesstowork.IPRAtakesnosidesnotwiththecomplainantorthe
departmentmember.
InaverysmallnumberofIPRAscases,findingsmaybechangedwhentheinvestigatorhasreachedan
appropriateconclusionnotsupportedbytheevidence.InthecaseofMr.Davis,hisfindingswerefound
tobeinaccuratebythreelevelsofmanagementabovehim,allwithequalorgreaterexperience.
From: Collins, Adam

To: Update_List
Cc: Rountree, Janey
Subject: Press inquiry: IPRA HR issue
ChipMitchellatWBEZisdoingastoryaboutanIPRAinvestigatorwhowasterminated.Theformer
employeeandafewothersaresayinghegotintroubleforopposingIPRAdecisionstochangeordiscard
sustainedfindingsbyhisinvestigativeteaminseveralcasesofallegedexcessiveforce,including
officerinvolvedshootings.HealsoclaimsthatthelackofanIPRAsustainedfindingagainstanyofficer
inthehundredsofondutypoliceinvolvedshootingsovertheyearshaserodedpublicconfidenceinthe
policedepartment.
Heslookingforaresponse.
HereswhatIPRAwouldliketosay.UnlessthereareissuesIllhavethemmovethisat3pm.
Thisisapersonnelmatter,anditwouldbeinappropriatetoaddressitthroughthemedia.IPRAis
committedtoconductingfair,unbiased,objective,thoroughandtimelyinvestigationsofallegationsof
policemisconductandofficerinvolvedshootings.
From:
Sent:
To:
Subject:
Collins, Adam
Guglielmi, Anthony;Rountree, Janey
Fw: (NEWS) BGA: Chicago tops in fatal police shootings among big U.S. cities
Follow Up Flag:
Flag Status:
Follow up
Completed
HeyAnthony
Canyoupleaseletmeknowifyougetanyfollowupsonthis?It'sridiculousthatBGAwouldn'tbotherto
mentionthatChicagoisincrediblytransparentonthisissue,andthereasontheywereabletogetitallforthis
citywasthatit'sonlinebrokendownbygenderandrace.You'dthinktheBGAwouldcareaboutthatfact...
Also,wouldhavebeenamuchsmarteranswerforIPRAthatwhattheysaid.That'swhathappenswhenthey
don'tgiveusaheadsupthough.
From:NewsClips
Sent:Monday,July27,20155:14AM
Subject:(NEWS)BGA:ChicagotopsinfatalpoliceshootingsamongbigU.S.cities
ChicagotopsinfatalpoliceshootingsamongbigU.S.cities
BGA//AndrewSchroedter//July26,2015
Chicagopolicehavefatallyshot70peopleoverafiveyearspan,topsamongdepartmentsinthelargestU.S.
cities.
TheChicagovictimswerenearlyallmale.Mostwereblack.Morethanhalfofthekillingshappenedinsix
SouthSidepolicedistricts.
Nootherpolicedepartmentinanyofthe10mostpopulouscitieskilledmorepeoplefrom2010through2014,
butChicagoranksfourthbehindPhoenix,PhiladelphiaandDallaswhenthenumbersareadjustedfor
population,accordingtoaBetterGovernmentAssociationanalysisofdataobtainedthroughinterviewsand
openrecordsrequests.
Thefindingscomeaslawenforcementsuseofdeadlyforcecomesunderintensescrutinyamidhighly
publicizedkillingsinCleveland;Ferguson,Missouri;NewYork,andelsewherethathavetriggeredanational
conversationaboutpolicing.
InChicago,anofficerwasrecentlyacquittedofkillinganunarmedwoman,thefirsttimeacophasstoodtrial
forafatalshootinginmorethanadecade,andtheFBIisinvestigatinglastyearsdeathofateenshot16times
byChicagopolice.
Cityofficialsarequicktopointout,however,thatpoliceshootingsaretrendinglowerthisyearofficershad
fatallyshotthreepeoplein2015asofFriday,puttingthedepartmentonpacetorecordthefewestkillings
since2012,whentherewereatotalofeight.
Therealquestionis,aretheshootingsappropriate?saysformerLosAngelespoliceofficerDavidKlinger,a
professorofcriminologyandcriminaljusticeattheUniversityofMissouriSt.Louis.Ifnot,thatswhereIget
concerned.
1
Buthowthatdeterminationismadecanbecontroversial.
ChicagosIndependentPoliceReviewAuthority,orIPRA,hasinvestigatednearly400policeshootingsfatal
andnonfatalsince2007andfoundonlyonetobeunjustified,thoughScottAndo,IPRAschief
administrator,saidtherearependinginvestigationsthatonewouldbelievewillbeunjustified.Hedeclined
tobemorespecific.
Justbecauseitwasjustifieddoesntmeanitwasnecessary,saysPeterMoskos,aformerBaltimorepolice
officerwhoisanassistantprofessorattheJohnJayCollegeofCriminalJusticeatCityUniversityofNewYork.
Perhaps,itcouldhavebeenpreventedbybettertrainingordifferenttactics.
ChicagoPoliceSupt.GarryMcCarthyhaspubliclycreditedmoretrainingandoversight,aswellasofficer
restraint,forreducingthenumberofpoliceshootingsthisyear.Hisnewsaffairsofficedidntrespondtoa
requestbytheBGAtospeakwithMcCarthy.
Butinastatement,thedepartmentsaid,Since2011,underSupt.McCarthy,theChicagoPoliceDepartment
hasinvestedinspecializedinstruction...[that]reinforcespoliceofficersskillsetsoncommunitybuilding,
problemsolvinganddeescalatingtenseconfrontations.Policeinvolvedshootingsaredownbydoubledigit
percentagesfollowingtheimplementationofthisuniquetraining.
TheFraternalOrderofPolice,whichrepresentsrankandfileChicagocops,didntrespondtointerview
requests.
TheBGAobtaineddataonfatalshootingsfromdepartmentsinthe10largestU.S.citiesbypopulation,
throughinterviewsandopenrecordsrequests.Thedataincludesshootingsbyonandoffdutyofficers.
Afederaldatabasethattrackspoliceshootingsinatimelyandcomprehensivemannerdoesntexist,sotheres
nosimplewaytocomparethenumberofpoliceshootingsacrossdifferentcities.
Chicagopolicereportedkilling70peoplefrom2010through2014,themostofanydepartmenttheBGA
lookedat,followedbyPhoenix(57);Philadelphia(54);Houston(49);andLosAngeles(47),recordsshow.
Whenadjustedforpopulation,Phoenixwastopswitharateof3.77per100,000residents,followedby
Philadelphia(3.48);Dallas(2.7);Chicago(2.57);andHouston(2.23).NewYorkrankedatthebottom,though
thatdepartmentprovidedtheBGAwithdataforonlyfourofthefiveyearsrequested.Apolicespokesman
said2014figureswerentavailable,thoughtheNewYorkDailyNewsreportedlastDecemberthatNewYork
policehadkilled13peoplelastyear.ANewYorkpolicespokesmancouldnotconfirmthatfigure.
Othernotablefindings:
Chicagopoliceshot240peoplefrom2010through2014,oranaverageaboutoneperweek,accordingto
interviewsandrecords.ThatwasmorethanotherdepartmentsexaminedbytheBGA,thoughLosAngeles,
NewYorkandPhoenixprovidedincompletedataonoverallpoliceshootings,ordataonfatalshootingsonly.
Since2010,thecityofChicagohaspaid$26.7milliontofamiliesofvictimswhowereshotandkilledbypolice,
accordingtointerviewsandrecords.Thatincludesa$5millionpaymenttothefamilyofLaquanMcDonald,
theteenwhowasfatallyshot16timesbypolicelastOctober.AnFBIspokeswomansaysacriminal
investigationofthatshootingisongoing.
BlacksareaboutathirdofChicagospopulationbutaccountedforatleasttwothirds,or46,ofthe70people
killedbypolicefrom2010to2014,IPRArecordsshow.
Fortyone,or59percent,ofChicagos70fatalshootings,happenedintheCalumet,Deering,Englewood,
GrandCrossing,GreshamandMorganParkpolicedistricts.
ToldoftheBGAsfindings,ArthurLurigio,aprofessorofpsychologyandcriminaljusticeatLoyolaUniversity
Chicago,saidhewasntsurprisedtheshootingswereconcentratedinspecificpocketsofthecity.
Thedistrictswherepoliceshootingsarethehighestareprobablythedistrictswhereviolentandgangcrimes
arethehighest,hesays.Inthoseneighborhoods,policeareonhigheralert.Theyremorelikelytofeel
threatened,andtheresagreaterlikelihoodtheyllreactmoreaggressively.
Lastyear,theBGAreportedthat,overadecade,thecityspentmorethan$500milliononpolicemisconduct
relatedlegalclaims,includingthoseinvolvingpoliceshootings.
From:
Sent:
To:
Subject:
Rountree, Janey
Guglielmi, Anthony;Collins, Adam
RE: Heads up from ME
Follow Up Flag:
Flag Status:
Follow up
Completed
Onthesecondone,shouldtheUSAttorneysofficebetheonetopushbackand/orcalltheME?

To: Collins, Adam; Rountree, Janey
Subject: Heads up from ME
JustafriendlyFYI,FrankfromME'sofficecalledtoadvisethattheywillbereleasingsomeinfotodayinrefto2cases:
1. AutopsyresultsofLatoyaJackson(womanfoundburnedinherhomew/bodiesofherchildren).CODwas
strangulation.
2. CasereportandCrimescenelogandprocessingsheetsforLaquanMcDonaldcasewearegoingtofightthisbc
ofanongoinginvestigation.
From:
Sent:
To:
Subject:
Attachments:
Fischler, Matt
Rountree, Janey
last notes from team check-in
Public Safety To Do List_July 17 notes (1) (2).docx
Follow Up Flag:
Flag Status:
Follow up
Completed
From:
Sent:
To:
Subject:
Stivers, Samantha
Rountree, Janey;Henry, Vance;Bennett, Kenneth
RE: Follow up requests from the from Police Accountability Coalition
Follow Up Flag:
Flag Status:
Follow up
Completed
PushedbacktoTuesdayat1pm.

To: Stivers, Samantha; Henry, Vance; Bennett, Kenneth
Subject: RE: Follow up requests from the from Police Accountability Coalition
Imactuallynotfreeat11today.Ihaveanurgentcallthatisntonmycalendar.Canwefindanothertime?
From: Stivers, Samantha

To: Henry, Vance; Rountree, Janey; Bennett, Kenneth
Sentsomethingoutfortodayat11am
From: Henry, Vance

To: Rountree, Janey; Bennett, Kenneth; Stivers, Samantha
Subject: Re: Follow up requests from the from Police Accountability Coalition
GoodMorningJaney,surething,let'stalkasap.
I'vehadsomeofflinetalksw/leadersandhavesomeinsights,weshoulddiscuss.
I'vegottenanearfullfollowingMonday'sfrontpagearticleintheSunTimesaboutthe#70fatalshootingbyCPD,inthe
last5yrs.
Additionally,therecontinuestobetalkaboutthetapeinvolvingtheshootingofLaquanMcDonald,andpublicsentiment
aboutacoverup.
Asyoumightimagine,thetiminganddetailsdiscussedintheSunTimesarticleandgrowinginterestintheMcDonald
incidenthasnotworkedinourfavor,andishelpingto"stirthepot".
********
Sam,
PlsscheduleKen,Janeyandmyselfforaconferencecall,preferablyFridayinam.
ThanksMa'am.
1
From:Rountree,Janey
Sent:Thursday,July30,20154:46:09PM
To:Bennett,Kenneth;Henry,Vance
Subject:FW:FollowuprequestsfromthefromPoliceAccountabilityCoalition
Canwediscuss?
From: Alex Wiesendanger [mailto:[email protected]]

To: Henry, Vance; Bennett, Kenneth; Rountree, Janey
Cc: Rev. Curtiss Paul DeYoung, Ed.D.; Ciera Walker; Ryan Wallace; Lori Clark; Nora Gaines ([email protected])
DearKen,Janey,andVance,
Asithasbeenoveraweeksincewesentthisletterandwehavenotheardfromyou,ourleadershipismovingforward
undertheassumptionthatthemayorisnotwillingtomeetagaininthenextmonthandthatyouwillnotbesendingus
theinformationwehadaskedforinourfollowupcommunication(whichIhavereattachedagainforyourreference).If
thisisnottrue,pleaseletusknowwhenwecanmeetagainandwhenwewillreceivetheinformationyoureferenced.
Thankyouandhaveablessedday
AlexWiesendanger
DirectorofOrganizing
CommunityRenewalSociety
(312)6733840
[email protected]
Neverdoubtthatasmallgroupofthoughtful,committedcitizenscanchangetheworld.Infact,itstheonlythingthat
everhas.
From:AlexWiesendanger
Sent:Tuesday,July21,20153:22PM
To:Henry,Vance([email protected])<[email protected]>;Bennett,Kenneth
([email protected])<[email protected]>;'[email protected]'
<[email protected]>
Cc:Rev.CurtissPaulDeYoung,Ed.D.<[email protected]>;CieraWalker
<[email protected]>;RyanWallace<[email protected]>;LoriClark
<[email protected]>;NoraGaines([email protected])<[email protected]>
Subject:FollowuprequestsfromthefromPoliceAccountabilityCoalition
DearKen,Janey,andVance,
Pleasefindattachedafollowupletterfromourcoalitionwithrequestsforadditionalinformationandafollowup
meetingwithmayor.
Welookforwardtohearingfromyou.
Peacewithjustice
alex
From:
Sent:
To:
Subject:
Attachments:
Maxson, Mark J. <[email protected]>

Tuesday, August 04, 2015 11:57 AM
Rasmas, Chloe;Rottner, Jennifer E.;Rountree, Janey;Collins, Adam
RE: Unprotected copy
Copy of August 04, 2015.xls
From: Rasmas, Chloe [mailto:[email protected]]

Sent: Tuesday, August 04, 2015 9:50 AM
To: Maxson, Mark J.; Rottner, Jennifer E.; Rountree, Janey; Collins, Adam
Subject: RE: Unprotected copy
Hiisthereanewagenda?
Thanks!
From: Maxson, Mark J. [mailto:[email protected]]

Sent: Wednesday, July 29, 2015 4:56 PM
To: Rasmas, Chloe; Rottner, Jennifer E.; Rountree, Janey; Collins, Adam
Subject: Unprotected copy
From:
Sent:
To:
Subject:
Stivers, Samantha
Tuesday, August 04, 2015 1:05 PM
Rountree, Janey;Henry, Vance;Bennett, Kenneth
RE: Conf. Call - RE: Follow up requests from the from Police Accountability Coalition
Follow Up Flag:
Flag Status:
Follow up
Completed
Itypedinthewrongaccesscode.Sorry!
Try
Also,Vanceifyouareable,Janey&KenareinKensOffice.
_____________________________________________
Sent: Tuesday, August 04, 2015 1:01 PM
To: Stivers, Samantha; Henry, Vance; Bennett, Kenneth
Subject: RE: Conf. Call - RE: Follow up requests from the from Police Accountability Coalition
Thisaccesscodeisnotworkingforme
-----Original Appointment----From: Stivers, Samantha

To: Stivers, Samantha; Henry, Vance; Rountree, Janey; Bennett, Kenneth
Subject: Conf. Call - RE: Follow up requests from the from Police Accountability Coalition
When: Tuesday, August 04, 2015 1:00 PM-1:30 PM (UTC-06:00) Central Time (US & Canada).
Where: Please call 888/ Access Code:
Callinnumber:888
AccessCode:
HostPasscode:
From: Henry, Vance

To: Rountree, Janey; Bennett, Kenneth; Stivers, Samantha
Subject: Re: Follow up requests from the from Police Accountability Coalition
GoodMorningJaney,surething,let'stalkasap.
I'vehadsomeofflinetalksw/leadersandhavesomeinsights,weshoulddiscuss.
I'vegottenanearfullfollowingMonday'sfrontpagearticleintheSunTimesaboutthe#70fatalshootingbyCPD,inthe
last5yrs.
CHAIN CONTINUES AS
PREVIOUSLY PRODUCED

)
)
)
)
)
)
)
No. 14 P 7092

the Estate of LaQuan McDonald), (also designated herein as a Payee), and mother of
decedent LaQuan McDonald (also known as LeQuan McDonald) by her attorneys, Law Offices
of Jeffrey J. Neslund and Law Office of Michael D. Robbins & Associates, the estate of
a minor by her guardian ad litem, a beneficiary of the Estate of Laquan McDonald, (also
designated herein as a Payee) and City of Chicago, by its attorney, Stephen R. Patton,
Corporation Counsel of the City of Chicago, by one of his attorneys, Thomas Platt, Deputy
Corporation Counsel, herein stipulate and agree to the following:
1.
David March, Star 20563, Sergeant Daniel Gallagher, Star 1303, Lieutenant Anthony Wojcik,
of the City of Chicago arising out of the fatal shooting of LaQuan McDonald on October 20,
2.

3.

serve as evidence of any wrongdoing by or on the part of the City of Chicago or its future,
current or former officers, agents and employees.
The parties and their respective attorneys
further acknowledge that settlement is made to avoid the uncertainty of the outcome of any
litigation and the expense in time and money of litigation and for the purpose of judicial
economy.
4.
In consideration of the hereinafter indicated settlement entered pursuant to this
including but not limited to, any claims under the Illinois Wrongful Death Act, the Illinois
Survival Act and claims under 42 U.S.C 1983 against City of Chicago, Officer Jason Van
Dyke, Star 9465, Officer Joseph Walsh, Star 12865, Detective David March, Star 20563,
Hagen, Star 20606 or any of its current, future or former officers, agents and employees with
respect to the incident set forth in paragraph one of this Release and Settlement Agreement
except solely in the event that the Chicago City Council rejects the hereinafter indicated
settlement, with each party bearing its own costs and attorneys fees. The Estate of LaQuan
McDonald agrees it will be required to execute the Release and Settlement Agreement prior to
the Citys presentation of the settlement agreement to the Chicago City Council and that the
Estate of LaQuan McDonald offers to settle on these terms shall not be revoked or otherwise
repudiated unless the Chicago City Council rejects the settlement agreement. The City Council
5.
ordinance authorizing this agreement. The City of Chicago and Estate of LaQuan McDonald and
its attorneys further acknowledge and agree that there is an ongoing criminal investigation by the
federal and state authorities of the incident which is the subject of this release and settlement
agreement (incident), and that potential evidence and materials (materials) relating to this
investigation and potential criminal charges, were obtained by the Estate of LaQuan McDonald in
response to subpoenas issued in the matter of Estate of LaQuan McDonald, 14 P 7092, Circuit
Court of Cook County. The City of Chicago submits that release or dissemination of these
through subpoenas issued in 14 P 7092 (materials), until the completion of the pending criminal
2
Formatted: Justified
6.
Estate of LaQuan McDonald accepts a settlement from Defendant, City of
Chicago, in the total amount of FIVE MILLION DOLLARS AND NO/100 DOLLARS
(i)
Cash Payment at Settlement: Three Two Million One Three Hundred
Eighty Seventy Six Thousand Six Hundred Sixty Seven and 00/100 Dollars
($2,386,667.003,176,667.00) payable to Tina Hunter, as Independent Administrator of
the Estate of LaQuan McDonald, and their attorneys, the Law Office of Jeffrey J.
Neslund and Michael D. Robbins & Associates, to be disbursed as directed by the Circuit
(ii)
Structured Settlement/Annuity Funding:
Nine Hundred Twenty
SixSixteen Thousand, Ninety and no/100 Dollars ($916,090.00926,090.00) payable to

Pacific Life &Annuity Services, Inc. in order to fund the future periodic payments set
forth below in Section 6.2(a).
(iii)
Eight Hundred Ninety Seven
Structured Settlements, Inc. in order to fund the future periodic payments set forth below
in Section 6.2(b).
(iv)
Structured Settlement/Annuity Funding: Eight Hundred Thousand and
no/100 Dollars ($800,000.00) payable to BHG Structured Settlements, Inc. in order to

fund the future periodic payments set forth below in Section 6.2(c).
6.2
Future periodic payments (the Periodic Payments) made according to the

(a)
Payee:
July 1, 2018 (10 payments total). The final guaranteed payment will be
3

$1,678.751,708.65 per month for the lifetime of
guaranteed 37 years, beginning on July 1, 2023, with the last guaranteed
payment on June 1, 2060. The Annuity Payment Amount may be subject
to an annual increase every July 1st beginning one (1) year after the first
payment and will be based on the lesser of the Index Return during the
applicable Index Term (first Index Term May 15, 2023 through May 15,
(b)
Payee:
$1,850.00 per month for the lifetime of
guaranteed 37
years, beginning on July 1, 2023, increasing at 3% compounded annually.
(c)
Payee: Tina Hunter

$2,821.00 per month for the lifetime of Tina Hunter, guaranteed 20 years,
beginning on October 25, 2015, The final guaranteed payment will be
due on September 25, 2035.
$30,000.00 guaranteed lump sum, payable on June 24, 2032.
No part of the cost of the Periodic Payments may be paid directly to the Claimant or any Payee,
inasmuch as the parties negotiated for a structured settlement and the Periodic Payments. All
sums set forth herein constitute damages on account of personal physical injuries or sickness,
7.
Claimant acknowledges that the Periodic Payments described in Section 6.2
cannot be accelerated, deferred, increased or decreased by the Claimant or any Payee; nor shall
The Claimant acknowledges and agrees that neither the periodic payments nor any rights
(a)
(b)
sold, mortgaged, assigned, pledged, hypothecated or otherwise transferred or
encumbered, either directly or indirectly, by the Claimant and Payees unless such sale,
assignment, pledge, hypothecation or other transfer or encumbrance (any such transaction being
hereinafter referred to as a Transfer) has been approved in advance in a qualified order as
outlined in Section 5891(b)(2) of the Internal Revenue Code of 1986, as amended (a Qualified
Order), and approved by the Circuit Court, County of Cook, State of Illinois, Probate
all applicable state structured settlement protection statues. Any such qualified order must be
sought in the original jurisdiction of the settlement and meet all the standards of necessity and
(c)
Claimant and Payees shall not have the power to affect a Transfer of Payment
Rights except as provided in subparagraph (b) above, and any other purported Transfer of
8.1
Any remaining guaranteed periodic payments to be made after the death of any
Payee pursuant to the terms of this Release and Settlement Agreement shall be made to such
person or entity as shall be designated in writing by any Payee (once reaching the age of majority),
to the City of Chicago or the City of Chicagos Assignee. If no person or entity is so designated
by any Payee, or if the person designated is not living at the time of the Payees' death, such
payments shall be made to the estate of the Payee(s).
8.2
No such designation, nor any revocation thereof, shall be effective unless it is in
writing and delivered to the City of Chicago or the City of Chicagos Assignee.
The
designation must be in a form acceptable to the City of Chicago or the City of Chicagos
Assignee before such payments are made, but in no event shall the request of the any Payee be
9.1
Claimant acknowledges and agrees that the City of Chicago shall make a
qualified assignment, within the meaning of Section 130 (c) of the Internal Revenue Code of
Section 6.2(c) to BHG Structured Settlements, Inc.;
The Assignees obligation for payment of the Periodic Payments shall be no greater than
that of the City of Chicago (whether by judgment or agreement) immediately preceding the
5

9.2
rejection and shall completely release and discharge the City of Chicago from the Periodic
Payments obligation assigned to the Assignees. The Claimant recognizes that, in the event of
obligation, and that all other releases with respect to the Periodic Payments obligation that
pertain to the liability of the City of Chicago shall thereupon become final, irrevocable and
absolute.
10.

Section 6.2(c) from Berkshire Hathaway Life Insurance Company of Nebraksa;
The City of Chicago or the Assignees shall be the sole owner of the annuity policy and
The City of Chicago, or the Assignees, may have the
Annuity Issuers mail payments directly to the Payees. The Payees shall be responsible for
maintaining a current mailing address for the Payees with the Annuity Issuers.
11.
The obligation of the City of Chicago and/or the Assignees to make each Periodic
Payment shall be discharged upon the mailing of a valid check or electronic funds transfer
(EFT) in the amount of such payment to the designated address of the Payee named in Section
12.
The Citys obligation pursuant to this Release and Settlement Agreement are
conditioned upon approval of the Release and Settlement Agreement by the Chicago City
Council. The City will not be obligated to perform its obligations pursuant to this Release and
settlement Agreement until the following events occur:
(1) the City receives a copy of this
(2) the Chicago City Council enacts an ordinance authorizing settlement and payment of the
funds agreed upon in this Release and Settlement Agreement. The Chicago City Council enacted
13.
The City agrees to pay Claimant the total settlement amount as specified in
paragraph 6 herein within thirty (30) days of receipt by the Corporation Counsels Office of a
6
fully executed settlement agreement, an ordinance of the City Council authorizing the settlement
as described in paragraph 6, and any necessary court-entered order in the Circuit Court of Cook
County for the disposition of funds, whichever is received latest.
The sums shall be payable
solely by the City of Chicago, and Estate of LaQuan McDonald and its attorneys agree that they
will not seek payment from any source other than the City of Chicago.
will be make payable as set forth in paragraph 6.
Each party hereto shall bear its own
14.
Agreement, and upon advice of counsel, Estate of LaQuan McDonald agrees to indemnify and
hold harmless the City of Chicago, and its future, current, or former officers, agents and
employees including, but not limited to, Officer Jason Van Dyke, Star 9465, Officer Joseph
Walsh, Star 12865, Detective David March, Star 20563, Sergeant Daniel Gallagher, Star 1303,
Lieutenant Anthony Wojcik, Star 481, Detective Richard Hagen, Star 20606 from any claims,
losses, damages or expenses, including attorneys fees and costs, incurred, or which may be
incurred, by reason of any lien or any other claim or interest held by any person, entity or
15.
Hagen, Star 20606 and the City of Chicago, and its future, current or former officers, and agents
and employees, including but not limited to all claims he had, has, or may have in the future,
the basis of this claim and any potential litigation, and that such release and discharge also is
of Chicago.
16.
under paragraph 19 herein contain the entire agreement between the parties with regard to the
7
settlement of this claim, and shall be binding upon and inure to the benefit of the parties hereto,
17.
18.
choice, and that the terms of this Release and Settlement Agreement have been interpreted,
completely read and explained to the Independent Administrator by its attorney, and that those
terms are fully understood and voluntarily accepted by the Estate of LaQuan McDonald. Estate
of LaQuan McDonald also represents and warrants that no other person or entity has or has had
any interest in the claims or causes of action referred to herein, and that the independent
and Settlement Agreement and receive the sums specific herein, and that they have not sold,
assigned, transferred, conveyed, or otherwise disposed of any of the claims or causes of action
referred to herein.
19.
The parties hereto agree to cooperate fully and execute any and all supplementary
necessary or appropriate to give full force and effect to the basic terms and intent of this Release
City of Chicago
Stephen R. Patton
Corporation Counsel
BY:_________________________________
Claimant
BY:________________________________
Thomas J. Platt
(312) 744-4833
DATE: ______________________________
Address: _____________________________
_____________________________________
Date of birth: __________________________
BY:__________________________________
Jeffrey J. Neslund
(312) 223-1100
FEIN: ___________
DATE: ______________________________
BY:_________________________________
Michael Robbins
(312) 899-8000
Attorney No. ______________
FEIN: ___________________
DATE:______________________________
BY:_____________________________________
A Minor
Address: _________________________________
_________________________________________
DATE: __________________________________
From:
Sent:
To:
Subject:
McGregor, Lorraine
Monday, August 10, 2015 12:22 PM
Goodmann, Daniel;Platt, Thomas
RE: Hunter (EO LaQuan McDonald) - No. 14 P 7092
Yes.
Pacific$916,090.00
BHG$1,697,243.00
From: Goodmann, Daniel [mailto:[email protected]]

Sent: Monday, August 10, 2015 12:19 PM
To: McGregor, Lorraine; Platt, Thomas
Subject: RE: Hunter (EO LaQuan McDonald) - No. 14 P 7092
Thetwoarefrommyoffice?(BerkshireHathawayandPacificLife?)

Mesirow Financial
Chicago, IL 60654
(312) 595-7055 Direct Line
(877) 772-4436 Toll Free
(312) 595-6736 Desktop Fax
(312) 595-4440 Office Fax
(312) 543-1834 - iPhone
[email protected]
From: McGregor, Lorraine [mailto:[email protected]]

To: Platt, Thomas
Cc: Goodmann, Daniel
Subject: RE: Hunter (EO LaQuan McDonald) - No. 14 P 7092
Jimcalledtoo.However,Ionlyhavetwocomptrollerchecklistsinsteadoftheamountstocover$5MunlessI
overlookedone.
From: Platt, Thomas

To: McGregor, Lorraine
Subject: FW: Hunter (EO LaQuan McDonald) - No. 14 P 7092
Thepaymentisbeingdoneover.Theoriginalcheckwasreturned.Iwillwalkyouthroughit.
From: Goodmann, Daniel [mailto:[email protected]]

Sent: Monday, August 10, 2015 9:40 AM
Cc: Platt, Thomas; Dunn, James
Subject: Re: Hunter (EO LaQuan McDonald) - No. 14 P 7092
IwillcallyouwhenIgetin.Originalfundingwasreturned.Complicatedtosaytheleast.
DanielJGoodmann
ManagingDirector
(312)5957055Office
(312)5431834Cell
SentfrommyiPhone
OnAug10,2015,at9:22AM,McGregor,Lorraine<[email protected]>wrote:
Hello,
Seetheattached.PaymentwasdueinMay?Isthisanotherpayment?
4/22/2015 14 P 7092
In the Matter of the Estate of LaQuan McDonald also known as

LeQuan McDonald, deceased, by its Independent
Administrator, Tina Hunter
5/14/2015
From: Real, Elizabeth [mailto:[email protected]]

Sent: Friday, August 07, 2015 5:37 PM
To: Platt, Thomas; McGregor, Lorraine; Dunn, James
Subject: FW: Hunter (EO LaQuan McDonald) - No. 14 P 7092
GoodafternoonTom:
Theplaintiffshadtotakeanextra$10,000incashandTinaisstructuringnowaswell,sothedocuments
had to be revised. The following attached documents pertain to the structured settlement for the
EstateofLaQuanMcDonald.
Premium Check(s) Request 080715: Please note, the premium check is due in our office by
September11,2015inordertomaintainthecurrentcostandbenefits.
FCRLDCOMPTROLLERCHECKLIST(BERKSHIRE)080715
FCRLDCOMPTROLLERCHECKLIST(PACIFIC)080715
QualifiedAssignment,ReleaseandPledgeAgreement(Pacific)080715:Pleasehavethissigned
onpage4andinitialedonpage5onbehalfoftheCityofChicago,asAssignor.Wewillsenda
separatecopyoftheagreementtotheplaintiffsattorneytoobtaintheplaintiffssignaturesand
initials.
Qualified Assignment, Release and Pledge Agreement (Berkshire) 080715: Please have this
signedonpage5andinitialedonpage6onbehalfoftheCityofChicago,asAssignor.Wewill
send a separate copy of the agreement to the plaintiffs attorney to obtain the plaintiffs
signaturesandinitials.
QualifiedAssignmentandReleaseTina(Berkshire)080715:Pleasehavethissignedonpage5
andinitialedonpage6onbehalfoftheCityofChicago,asAssignor.Wewillsendaseparate
copyoftheagreementtotheplaintiffsattorneytoobtaintheplaintiffssignaturesandinitials.
2
$5
Release Settlement Agreement (with Guardian) revised 080715: We tracked the changes for
easeofreferencestartingwiththedocumentlabeledHunterReleaseSettlementAgreement
(withGuardian)revised7212015(final72215).ThiscopyhasbeensenttoMichaelRobbins
forhisreviewaswell.
Ifyouhaveanyquestions,pleasedonothesitatetocontactus.
Thankyou.
Liz
Elizabeth Real, CSSC
Account Manager Structured Settlements
Mesirow Financial
t 312.595.7058
t 877.772.4436
f 312.595.4440
e [email protected]
www.mesirowfinancial.com
This communication may contain privileged and/or confidential information. It is intended solely for the use of the
addressee. If you are not the intended recipient, you are strictly prohibited from disclosing, copying, distributing or
using any of this information. If you received this communication in error, please contact the sender immediately and
destroy the material in its entirety, whether electronic or hard copy. Confidential, proprietary or time-sensitive
communications should not be transmitted via the Internet, as there can be no assurance of actual or timely delivery,
receipt and/or confidentiality. This is not an offer, or solicitation

This communication may contain privileged and/or confidential information. It is intended solely
for the use of the addressee. If you are not the intended recipient, you are strictly prohibited from
disclosing, copying, distributing or using any of this information. If you received this
communication in error, please contact the sender immediately and destroy the material in its
entirety, whether electronic or hard copy. Confidential, proprietary or time-sensitive
communications should not be transmitted via the Internet, as there can be no assurance of
actual or timely delivery, receipt and/or confidentiality. This is not an offer, or solicitation of any
<mcdonald-04222015.pdf>
3
COMPTROLLER (PAYMENT) CHECKLIST
Case Name & Number:
Estate of LaQuan McDonald No. 14 P 7092____
Date of Incident: 10/20/2014 Description/Primary Cause: _Wrongful Death _____

Payment Type: ____ Pro Se ____Verdict ____Judgment (includes sanctions, etc.)
__X_Settlement
(Please check all applicable)
Judge
__ Liens ____ Yes ____ No (If so, provide below)
Amount: $1,697,243.00
Plaintiff(s)
______________________________
A Minor,
_______________________________
Structured Settlement Firm Name: _Mesirow Financial Structured Settlements

Consultants Name: _Daniel J. Goodmann / Elizabeth Real__
Address:
__353 N. Clark Street_________________

__Chicago, IL 60654 _________________
Phone Number:
(_312_) __595__ - _7055______
BHG Structured Settlements, Inc., (Tax ID No.:
*Plaintiff Pro se Social Security Number: _____ - ____ - _____

Required Attachments:
For Settlements
Verdicts/Judgments
__X_ Signed/dated settlement documents
___ Court-entered judgments/verdicts
____ Court-entered Agreed Order of Dismissal
______Interest added (effective date

of interest _____________________)
____ Court-entered Stipulation to Dismiss

______ Copies of all depositions
Please indicate any special instructions below:
Please make check payable to:
BHG Structured Settlements, Inc., (Tax ID No.:
)
3024 Harney Street
Omaha, NE 68131 (Call Mesirow when check is ready for pick-up)
* Required for 1099 Reporting
Case Name & Number:
Estate of LaQuan McDonald No. 14 P 7092____
Date of Incident: 10/20/2014 Description/Primary Cause: _Wrongful Death _____

__X_Settlement
Judge
__ Liens ____ Yes ____ No (If so, provide below)
Amount: $916,090.00
Plaintiff(s) _
______________________________
A Minor,
_______________________________
Structured Settlement Firm Name: _Mesirow Financial Structured Settlements

Consultants Name: _Daniel J. Goodmann / Elizabeth Real__
Address:
__353 N. Clark Street_________________

__Chicago, IL 60654 _________________
Phone Number:
(_312_) __595__ - _7055______
Pacific Life & Annuity Services, Inc., (Tax ID No.:
*Plaintiff Pro se Social Security Number: _____ - ____ - _____

For Settlements
Verdicts/Judgments
__X_ Signed/dated settlement documents
___ Court-entered judgments/verdicts
____ Court-entered Agreed Order of Dismissal
______Interest added (effective date

of interest _____________________)

______ Copies of all depositions
Please indicate any special instructions below:
Please make check payable to:
Pacific Life & Annuity Services, Inc., (Tax ID No.:
)
700 Newport Center Drive
Newport Beach, CA 92660 (Call Mesirow when check is ready for pick-up)
* Required for 1099 Reporting
353 North Clark Street, Chicago Illinois 60654

312.595.7020 mesirowfinancial.com
August 7, 2015
Thomas Platt
Attorney for City of Chicago
[email protected]
RE: Claimant:
No.
Estate of LaQuan McDonald

14 P 7092
Dear Tom:
Thank you for allowing us the opportunity to provide settlement services for the above-referenced claim. To fund the
periodic payments, please issue the premium checks as follows:
Premiums Due by:
September 11, 2015
Send to:
c/o Elizabeth Real

Mesirow Financial Structured Settlements
Chicago, IL 60654
Premium amount:
$1,697,243.00
Payee:
BHG Structured Settlements, Inc., (Tax ID No.: 47-0793577)

3024 Harney Street
Omaha, NE 68131
(Do not send check to this address; it is for informational purposes only)
Premium amount:
$916,090.00
Payee:
Pacific Life & Annuity Services, Inc., (Tax ID No.: 91-2025652)

700 Newport Center Drive
Newport Beach, CA 92660
(Do not send check to this address; it is for informational purposes only)
If you have any questions, please do not hesitate to contact me.

Sincerely,
MESIROW FINANCIAL STRUCTURED SETTLEMENTS
Elizabeth Real
Account Manager
cc:
Lorraine McGregor / City of Chicago / [email protected]

James Dunn / City of Chicago / [email protected]
Mesirow Advanced Strategies, Inc. Mesirow Financial Alternative Investments, LLC Mesirow Financial Commodities Management, LLC Mesirow Financial Consulting, LLC
Mesirow Financial Interim Management, LLC Mesirow Financial Investment Management, Inc. Mesirow Financial Private Equity Advisors, Inc. Mesirow Financial Real Estate Brokerage, Inc.
Mesirow Financial Real Estate Consulting, LLC Mesirow Financial Structured Settlements, LLC Mesirow Insurance Services, Inc. Mesirow Realty Sale-Leaseback, Inc.
Securities offered through Mesirow Financial, Inc. Member NYSE, SIPC
In the event of any conflict between this Agreement and the Settlement Agreement with respect to
the Periodic Payments or the assignment made herein, the terms and conditions of this
Agreement shall prevail.
This Qualified Assignment and Release Agreement may be signed in one or more counterparts.

Assignor: _________________________________
By:
Title:
Assignee:
BHG Structured Settlements, Inc.
By:
Authorized Representative
Title:
Claimant(s) or Payee(s):
By:
-
-
By:
SS-1000 (12/2013) [S]
Page
of
Addendum No. 1
Description of Periodic Payments
-

-
INITIALS
Assignor:
________
Assignee:
________
Claimant or Payee:
________
Attorney for Claimant:
________
SS-1000 (12/2013) [S]
Page
of
Qualified Assignment, Release and Pledge Agreement

In Accordance With
Internal Revenue Code Section 130
Claimant-Secured Party(ies):
Assignor:
City of Chicago
Settlement Agreement:
Governing Law:

[Exact title of Settlement Agreement or Order]
[E
Illinois
Assignee-Debtor:
BHG STRUCTURED SETTLEMENTS, INC.
Annuity Issuer: BERKSHIRE HATHAWAY LIFE INSURANCE COMPANY OF NEBRASKA

Effective Date:
Payee(s): As shown in Addendum No. 1, Description of Periodic Payments
Annuity Contract No.:
This Qualified Assignment, Release and

Pledge Agreement (Agreement) is made and
entered into as of the Effective Date by and
among the undersigned parties with reference to
the following facts:
A. Claimant-Secured Party(ies) and Assignor
are parties to or are otherwise subject to the
above-referenced Settlement Agreement
under which Assignor has liability to make
certain periodic payments to the designated
Payee(s) as specified in Addendum No. 1 of
this Agreement (the Periodic Payments).
Where no Payee(s) other than ClaimantSecured Party(ies) are shown in Ad
Addendum
No. 1, it is understood that any references
herein to Payee(s) shall apply to ClaimantSecured Party(ies).
SS-2
SS
-2000 (12/2013) [S]
B. Assignor and Assignee-Debtor wish to effect

a qualified assignment within the meaning
and subject to the conditions of Section
130(c) of the Internal Revenue Code of
1986, as amended (the Code).
C. Assignee-Debtor desires to grant to
Claimant-Secured Party(ies) a secured
interest to secure the liability being assumed
by Assignee-Debtor to make the Periodic
Payments.
D. This Agreement will be effective contingent
upon Assignee-Debtors receipt of the full
premium to fund the Periodic Payments
contained herein.
Page 1 of 6
Now, therefore, in consideration of the

foregoing and for other good and valuable
consideration, the parties agree as follows:
be used by Assignee-Debtor to fund the

Periodic Payments and shall at all times be
designated by Assignee-Debtor on its
records as being taken into account, under
Section 130 of the Code, with respect to this
Agreement. Notwithstanding anything to the
contrary contained in this Agreement,
neither any Claimant-Secured Party, any
Payee, nor any Successor Payee (as
defined in paragraph 8 of this Agreement)
shall have any rights with respect to the
Annuity or the payments thereunder that
would cause any amount attributable to the
Annuity to be currently includable in the
recipients income or would otherwise affect
the determination of when any recipient is
treated as having received any payment for
income tax purposes, or would otherwise
prevent this Agreement from satisfying all of
the conditions for a qualified assignment
within the meaning of Section 130(c) of the
Code.
1. Assignment and Assumption; Release of

Assignor. Assignor hereby assigns to
Assignee-Debtor, and Assignee-Debtor
hereby accepts and assumes, all of
Assignors liability to make the Periodic
Payments. Each Claimant-Secured Party
hereby accepts and consents to such
assignment by Assignor and assumption by
Assignee-Debtor. Effective on the Effective
Date, each Claimant-Secured Party hereby
releases and discharges Assignor from all
liability to make the Periodic Payments,
including the failure of Assignee-Debtor to
make any of the Periodic Payments and/or
Annuity Issuer to fund any of the Periodic
Payments for any reason whatsoever.
2. Nature of Periodic Payments. The Periodic
Payments constitute:
i.
damages (other than punitive damages),

whether by suit or agreement, or
ii.
compensation
under
compensation act,
workers
on account of personal injury or sickness in

a case involving physical injury or physical
sickness, within the meaning of Sections
130(c) and 104(a) of the Code.
3. Extent of Assignee-Debtors Liability.
Assignee-Debtors liability to make the
Periodic Payments shall be no greater than
the liability of Assignor as of the Effective
Date. Assignee-Debtor assumes no liability
other than the liability to make the Periodic
Payments. Assignee-De
Debtors liability to
make the Periodic Payments shall be
unaffected by any bankruptcy, insolvency,
liquidation or rehabilitation of Assignor.
4. Qualified Funding Asset. Assignee-Debtor
will fund the Periodic Payments by
purchasing from Annuity Issuer a qualified
funding asset, as defined in Section 130(d)
of the Code, in the form of an annuity
contract (the Annuity) issued by Annuity
Issuer and providing for payments
corresponding to the Periodic Payments.
Assignee-Debtor shall be designated as the
owner of the Annuity. All rights of legal
ownership and control of the Annuity shall
(subject to paragraph 9 of this Agreement)
be and remain vested exclusively in
Assignee-Debtor, including the right to
receive and retain all benefits under the
Annuity which are not inconsistent with the
security interest granted under paragraph
11; provided, however, that the Annuity shall
SS-2
SS
-2000 (12/2013) [S]
5. Delivery of Payments. Assignee-Debtor

may instruct Annuity Issuer to send
payments directly to Payee or Successor
Payee, or to deliver payments by electronic
funds transfer (EFT) to an FDIC-insured
depository institution in the United States for
credit (directly or indirectly) to an insured
account in the name of such Payee or
Successor Payee. Such direction of
payments under the Annuity shall not be
deemed to afford Claimant-Secured Party,
Payee or any Successor Payee any rights of
ownership or control of the Annuity.
Each Claimant-Secured Party, Payee and
any Successor Payee shall at all times keep
Annuity Issuer apprised of such ClaimantSecured Partys
s, Payees or Successor
Payees current mailing address and
telephone number and, if Payee or
Successor Payee receives payments by
EFT, the name, address, ABA routing
number and telephone number of the
applicable U.S. financial institution and the
account name and account number to which
the payments are to be credited.
Such
notices shall be in a form provided by
Annuity Issuer and must be received at least
thirty (30) days prior to the date payment is
due.
6. Discharge of Liability. Assignee-Debtors
liability to make each Periodic Payment to
any Payee or Successor Payee designated
to receive such payment shall be fully
discharged upon:
Page 2 of 6
i.
the mailing of a valid check on or before

the due date for such payment to the
address of record specified by Payee or

Successor Payee; or
ii.
the initiation of an EFT payment on or

before the due date for such payment to
the United Sates financial institution
account designated by Payee or
Successor Payee
If Payee or Successor Payee does not

receive a scheduled payment by check,
Payee or Successor Payee shall notify
Assignee-Debtor. Upon receipt of such
notification, Assignee-Debtor shall initiate a
stop payment action for such check and
upon confirmation that such check was not
previously negotiated shall promptly mail a
replacement check; or
receive a scheduled EFT payment, Payee or
Successor Payee shall notify AssigneeDebtor. Upon receipt of such notification,
Assignee-Debtor shall initiate a trace for
such payment and upon confirmation that
such payment was not credited to the
account shall promptly issue a replacement
EFT payment.
7. Acceleration, Transfer of Payment
Rights. None of the Periodic Payments and
no rights to or interest in any of the Periodic
Payments (all of the foregoing being
hereinafter collectively referred to as
Payment Rights) can be
i.
Accelerated, deferred, increased or

decreased by any recipient of any of the
Periodic Payments; or
ii.
Sold, assigned, pledged, hypothecated

or otherwise transferred or encumbered,
either directly or indirectly, unless such
sale, assignment, pledge, hypothecation
or other transfer or encumbrance (any
such transaction being hereinafter
referred to as a Transfer) has been
approved in advance in a Qualified
Order as defined in Section 5891(b)(2)
of the Code (a Qualified Order) and
otherwise complies with applicable state
law, including without limitation any
applicable state structured settlement
protection statute.
No Claimant-Secured Party, Payee or

Successor Payee shall have the power to
effect any Transfer of Payment Rights
except as provided in sub-paragraph (ii)
above, and any other purported Transfer of
Payment Rights shall be wholly void, invalid
and unenforceable. If Payment Rights under
this Agreement become the subject of a
SS-2
SS
-2000 (12/2013) [S]
Transfer approved in accordance with subparagraph (ii) above the rights of any direct
or indirect transferee of such Transfer shall
be subject to the terms of this Agreement
and any defense or claim in recoupment
arising hereunder.
8. Contingent Beneficiaries. Any Periodic
Payments to be made after the death of any
Claimant-Secured
Party,
Payee
or
Successor Payee shall be made to such
Su
party as shall have been designated in, or in
accordance with, the Settlement Agreement
or, if the Settlement Agreement does not
provide for such designation, then to the
party designated in conformity with this
paragraph 8. Any party so designated is
referred to in this Agreement as a
Contingent Beneficiary. If no Contingent
Beneficiary is living at the time of the death
of a Claimant-Secured Party, Payee or
Successor Payee, payment shall be made to
the decedents estate unless otherwise
provided in the Settlement Agreement. As
used in this Agreement the term Successor
Payee refers to a Contingent Beneficiary or
an estate that has become entitled to
receive Periodic Payments following the
death of a Claimant-Secured Party, Payee
or a Successor Payee. Except where a
designation has been made in the
Settlement Agreement, no designation or
change of designation of a Contingent
Beneficiary shall be effective unless such
designation or change (i) is requested in a
written request submitted to AssigneeDebtor in accordance with AssigneeDebtors
customary
procedures
for
processing such requests; and (ii) is
confirmed by Assignee-Debtor. However,
Assignee-Debtor will not be liable for any
payment made prior to receipt of the request
or so soon thereafter that payment could not
reasonably be stopped.
Except for a
designation that is expressly identified in the
Settlement Agreement as irrevocable, any
designation of a Contingent Beneficiary shall
be deemed to be revocable; and no party
that is designated as a Contingent
Beneficiary (other than a party irrevocably
designated as a Contingent Beneficiary in
the Settlement Agreement) shall, solely by
virtue of its designation as a Contingent
Beneficiary, be deemed to have any
cognizable interest in any Periodic
Payments.
9. Termination of Settlement Agreement /
Failure to Satisfy Section 130(c).
). If at any
time prior to completion of the Periodic
Payments, the Settlement Agreement is
Page 3 of 6
declared terminated in a final, nonappealable order of a court of competent

jurisdiction (or in the case of a workers
compensation settlement, a final order of the
applicable workers compensation authority)
or if it is determined in any final order or
ruling that the requirements of Section
130(c) of the Code have not been satisfied
in connection with this Agreement: (i) the
assignment by Assignor to Assignee-Debtor
of the liability to make the Periodic
Payments
and
Assignee-Debtors
acceptance of such assignment shall be of
no force or effect; (ii) Assignee-Debtor shall
be conclusively deemed to be acting as the
agent of Assignor; (iii) the Annuity shall be
owned by Assignor; (iv) in the event the
Settlement Agreement is not terminated,
Assignor shall retain the liability to make the
Periodic Payments; (v) Assignee-Debtor
shall have no liability to make any Periodic
Payments; and (vi
vi) the parties hereto agree
to cooperate in taking such actions as may
be necessary or appropriate to implement
the foregoing.
10. Governing
Law;
Binding
Insolvency of Assignee-Debtor.
i.
Effect;
This Agreement shall be governed by

and interpreted in accordance with the
internal laws of the state identified as
Governing Law above; provided,
however, that any Transfer of Payment
Rights under this Agreement may be
subject to the laws of other states in
addition to the state designated above.
ii. This Agreement shall be binding upon

the parties hereto and their respective
successors,
heirs,
executors,
administrators and permitted assigns,
including without limitation any party
asserting an interest in Payment Rights.
iii. If, due to insolvency or bankruptcy
Assignee-Debtor has failed to make any
of the Periodic Payments, and such
failure is continuing, Claimant-Secured
Party(ies), or in the event of the death of
applicable Claimant-Secured Party(ies),
Successor Payee shall have all of the
rights and remedies of a secured party
under the law then in effect in the State
of Nebraska.
11. Claimant-Secured Party Status AssigneeDebtor hereby pledges and grants to
Claimant-Secured Party(ies) a lien on and
security interest in all of Assignee-Debtors
right, title, and interest in the Annuity and all
payments therefrom in order to secure the
SS-2
SS
-2000 (12/2013) [S]
obligation of Assignee-Debtor to make the

Periodic Payments. Assignee-Debtor and
Claimant-Secured Party(ies) shall notify
Annuity Issuer of the lien created under this
Agreement, and Assignee-Debtor shall
deliver a copy of the Annuity to ClaimantSecured Party(ies) upon execution of this
Agreement and receipt by Assignee-Debtor
of the Annuity from Annuity Issuer.
12. Advice, Comprehension of Agreement. In
entering into this Agreement, each ClaimantSecured Party warrants, represents and
agrees that Claimant-Secured Party is solely
relying on the attorneys and advisors of
such
Claimant-Secured
Partys
own
choosing, and not upon Assignor, Assigneech
Debtor or their advisors, for advice regarding
the legal, government benefits and tax
advice regarding the consequences of this
Agreement. Each Claimant-Secured Party
further warrants, represents and agrees that
the terms of this Agreement have been
completely read by and explained to such
Claimant-Secured Party and are fully
understood and voluntarily accepted by such
Claimant-Secured Party. Furthermore, each
Claimant-Secured Party hereby releases
and discharges Assignor, Assignee-Debtor,
Annuity Issuer, their affiliates and their
respective
employees
and
advisors
(Releasees) from any and all claims,
rights, damages, costs or expenses of any
nature whatsoever that such ClaimantSecured Party now has or may have in the
future against such Releasees (i) with
respect to the present and future taxation of
this Agreement or the Periodic Payments; or
(ii) the impact that this Agreement or the
Periodic Payments may have on ClaimantSecured Partys eligibility for, and the
quantum of, any governmental benefit
payments.
13. Future Cooperation. All parties agree to
cooperate fully and to execute any and all
supplementary documents and take all
additional actions, which are not inconsistent
with its terms, which may be necessary or
appropriate to give full force and effect to the
terms and intent of this Qualified
Assignment,
Release
and
Pledge
Agreement.
Pursuant to its obligations
under this paragraph 13, and without
limitation, Assignor shall promptly provide
Assignee-Debtor with copies of any required
court approval with respect to the underlying
settlement and executed copies of all
required settlement documents.
Page 4 of 6
14. Description of Periodic Payments. The

Periodic Payments are as set forth in
attached Addendum No. 1, which is hereby
incorporated in and made a part of this

Agreement.
In the event of any conflict between this Agreement and the Settlement Agreement with respect to
City of Chicago
Assignor: _________________________________
By:
Title: Deputy Corporation Counsel
Assignee:
By:
Claimant(s) or Payee(s):
By:
, A Minor
By: ___________________________________
The Estate of LaQuan McDonald, deceased
Attorney for Claimant(s):

Approved as to Form and Content
By:
Michael Robbins
SS-2000 (12/2013) [S]
Page 5 of 6
Addendum No. 1
Payee:
Tariana Hunter
$1,850.00 per month ($22,200.00 per year) for the life of

guaranteed
37 years, beginning on July 1, 2023. The amount of the payment shall increase by 3%
compounding annually on July 1st of each year beginning July 1, 2024. The final
guaranteed payment will be on June 1, 2060.
$30,000.00 guaranteed lump sum payable on March 28, 2023.
INITIALS
Assignor:
________
Assignee-Debtor:
________
Claimant-Secured Party or Payee:

SS-2000 (12/2013) [S]
________ ________
________
Page 6 of 6
Qualified Assignment, Release and Pledge Agreement

In Accordance With Internal Revenue Code Section 130
"Claimant-Secured Party":

, A Minor
"Assignor(s)":
City of Chicago
"Assignee-Debtor":
Pacific Life & Annuity Services, Inc.
"Annuity Issuer":
Pacific Life
"Annuity" Policy No.:

"Effective Date":
This Qualified Assignment, Release, and Pledge Agreement is made and entered into by and among the parties
hereto as of the Effective Date with reference to the following facts:
A. Claimant-Secured Party has executed a settlement agreement or release dated
(the "Settlement Agreement") which requires Assignor to make certain periodic payments to or for the
benefit of the Claimant-Secured Party as stated in Addendum No. 1 of this Agreement (the "Periodic
Payments").
B. The parties desire to effect a "qualified assignment" within the meaning and subject to the conditions of
Section 130(c) of the Internal Revenue Code of 1986, as amended (the "Code").
C. The Assignee-Debtor desires to grant to Claimant-Secured Party a security interest to secure the liability
being assumed by Assignee-Debtor to make the Periodic Payments.
Now, therefore, in consideration of the foregoing and for other good and valuable consideration, the
parties agree as follows:
1. Subject to qualification under Section 130(c) of the Code, Assignor hereby assigns and
Assignee-Debtor hereby assumes all of Assignors liability to make the Periodic Payments.
Assignee-Debtor assumes no liability to make any other payment. Claimant-Secured Party hereby
accepts and consents to the assignment by Assignor and the assumption by Assignee-Debtor of the
liability to make the Periodic Payments, and upon the Effective Date Claimant-Secured Party releases
Assignor from all liability to make the Periodic Payments.
2. The Periodic Payments constitute damages on account of personal injury or sickness in a case
involving physical injury or physical sickness within the meaning of Sections 104(a)(1) or 104(a)(2)
and 130(c) of the Code.
Pacific Life refers to Pacific Life Insurance Company and its affiliates, including Pacific Life & Annuity Company. Insurance
products are issued by Pacific Life Insurance Company in all states except New York and in New York by Pacific Life &
Annuity Company. Product availability and features may vary by state. Each company is solely responsible for the financial
obligations accruing under the products it issues. Insurance product and rider guarantees are backed by the financial strength
and claims-paying ability of the issuing company.
PL QAR&P
v2012
3.
Assignee-Debtors liability to make the Periodic Payments is no greater than that of Assignor as determined
immediately prior to this Agreement. None of the Periodic Payments may be accelerated, deferred, increased or
decreased, anticipated, sold, assigned, pledged, or encumbered by Claimant-Secured Party.
4.
The obligation assumed by Assignee-Debtor to make each applicable Periodic Payment shall be fully discharged
upon the mailing of a valid check or wire transfer of funds on or before the due date for such Periodic Payment to
the address of record specified by Claimant-Secured Party.
5.
This Agreement shall be governed by and interpreted in accordance with the laws of the State of
Illinois .
6.
Assignee-Debtor may fund the Periodic Payments by purchasing the Annuity from Annuity Issuer to serve as a
"qualified funding asset" within the meaning of Section 130(d) of the Code. All rights of ownership and control of
the Annuity shall be and remain vested in the Assignee-Debtor except as provided in paragraphs 11 and 12 of
this Agreement.
7.
Assignee-Debtor may have the Annuity Issuer send payments from the Annuity directly to the payee(s) specified
in Addendum No.1. Such direction of payment shall be solely for Assignee-Debtor's convenience and shall not
provide Claimant-Secured Party or any payee with any rights of ownership or control over the Annuity or against
Annuity Issuer.
8.
Any Periodic Payments to be made after the death of any Claimant or Successor Payee shall be made to such
party as shall have been designated in, or in accordance with, the Settlement Agreement or, if the Settlement
Agreement does not provide for such designation, then to the party designated in conformity with this paragraph
8. Any party so designated is referred to in this Agreement as a "Contingent Beneficiary." If no Contingent
Beneficiary is living at the time of the death of a Claimant or Successor Payee, payment shall be made to the
decedents estate. As used in this agreement the term "Successor Payee" refers to a Contingent Beneficiary or
an estate that has become entitled to receive Periodic Payments following the death of a Claimant or a
Successor Payee. Except as otherwise provided in the Settlement Agreement, no designation or change of
designation of a Contingent Beneficiary shall be effective unless such change (i) is requested in a written request
submitted to Assignee (or its authorized agent) in accordance with Assignees customary procedures for
processing such requests; and (ii) is confirmed by Assignee (or its authorized agent). Except for a designation
that is expressly identified in the Settlement Agreement as irrevocable, any designation of a Contingent
Beneficiary shall be deemed to be revocable; and no party that is designated as a Contingent Beneficiary (other
than a party irrevocably designated as a Contingent Beneficiary in the Settlement Agreement) shall, solely by
virtue of its designation as a Contingent Beneficiary, be deemed to have any cognizable interest in any Periodic
Payments.
Note: Beneficiaries section only applies to guaranteed benefits (Period Certain, Lump Sum(s), Life with Certain
payments).
9.
Assignee-Debtor's liability to make the Periodic Payments shall continue without diminution regardless of any
bankruptcy or insolvency of Assignor.
10. In the event the Settlement Agreement is declared terminated by a court of competent jurisdiction the parties
shall act in accordance with the orders of the court; provided however that nothing in this paragraph shall
preclude a party to this Agreement from appealing any order or judgment of a court. In the event that Section
130(c) of the Code has not been satisfied, (i) the assignment by Assignor to Assignee-Debtor of the liability to
make the periodic payments to Claimant-Secured Party described in paragraph 1 of this Agreement shall be of
no force and effect, (ii) the Assignee-Debtor shall be acting in the transaction as the agent of the Assignor and
the Annuity shall be owned by Assignor which will continue to have the liability to make the Periodic Payments to
Claimant-Secured Party, (iii) Assignee-Debtor shall have no liability to make any Periodic Payment to
Claimant-Secured Party, and (iv) the parties hereto agree to cooperate in taking such actions as are reasonably
necessary or appropriate to achieve the foregoing.
PL QAR&P
v2012
11. This Agreement shall be binding upon the respective representatives, heirs, successors and assigns of the
parties hereto and upon any person or entity that may assert any right hereunder or to any of the Periodic
Payments.
12. Assignee-Debtor hereby pledges and grants to Claimant-Secured Party a lien on and security interest in all of
Assignee-Debtor's right, title, and interest in the Annuity and all payments therefrom in order to secure the
obligation of the Assignee-Debtor to make the Periodic Payments. Assignee-Debtor and Claimant-Secured Party
shall notify Annuity Issuer of the lien created under this Agreement, and Assignee-Debtor shall deliver the
Annuity to Claimant-Secured Party upon execution of this Agreement and receipt by Assignee-Debtor of the
Annuity from Annuity Issuer.
13. Assignee-Debtor shall have all rights of ownership and control in the Annuity, including the right to receive and
retain all benefits under the Annuity, which are not inconsistent with the security interest granted under
paragraph 12, and Claimant-Secured Party shall have no right to anticipate, sell, assign, pledge, encumber, or
otherwise exercise any right with respect to the Annuity, so long as Assignee-Debtor has not failed due to
insolvency or bankruptcy to make any of the Periodic Payments. If a failure occurs and is continuing,
Claimant-Secured Party shall have all of the rights and remedies of a secured party under the law then in effect
in the State of Illinois.
14. Any Annuity will bear the following legend:
"NOTICE"
"This annuity contract has been delivered to the possession of
for the sole
purpose of perfecting a lien and security interest of such person in this contract. The above named
is not the owner of, and has no ownership rights in, this contract and may not anticipate, sell,
assign, pledge, encumber or otherwise use this contract as any form of collateral. Please contact
the issuer for further information."
15. In entering into this Agreement, Claimant-Secured Party represents that he or she has relied on the advice of his
or her attorneys, who are the attorneys of his or her choice, concerning the legal and income tax consequences
of the Agreement; that the terms of the Agreement have been completely read by and explained to
Claimant-Secured Party; and that the terms of this Agreement are fully understood and voluntarily accepted by
Claimant-Secured Party. Assignee-Debtor makes no representations with respect to the tax consequences of
this Agreement or the adequacy of the security interest created hereby.
16. Any notice to a party hereunder shall be in writing and shall be deemed to have been given when mailed to the
party's address of record.
17. No financing statement in respect of the security interest granted herein shall be filed in any nonjudicial office of
any federal, state, or local governmental authority.
PL QAR&P
v2012
Assignor: City of Chicago
By:
Title:
Assignee: Pacific Life & Annuity Services, Inc.
Assignee: Pacific Life & Annuity Services, Inc.
By:
By:
Title:
Claimant:
Title:
Approved as to Form and Content:
A Minor
By:
Claimant's Attorney
Claimant:
By:
PL QAR&P
v2012
Addendum No. 1
Payee :
Benefit(s):
1. Period Certain Annuity - $17,500.00 payable semi-annually, guaranteed for 5 year(s) which is 10
payments, beginning on 07/01/2018, with the last guaranteed payment on 01/01/2023.
2. Period Certain Annuity - $500.00 payable monthly, guaranteed for 5 year(s) which is 60 payments,
beginning on 07/01/2018, with the last guaranteed payment on 06/01/2023.
3. Life Certain Annuity - Indexed - $1,678.75 for life, payable monthly, guaranteed for 37 year(s) which
is 444 payments, beginning on 07/01/2023, with the last guaranteed payment on 06/01/2060. The
Annuity Payment Amount may be subject to an annual increase every 07/01 beginning in one year after
the first payment and will be based on the lesser of the Index Return during the applicable Index Term
(first Index Term is 05/15/2023 to 05/15/2024) and the cap of 5%. If the Index Return during the
applicable Index Term is negative, there will be no increase in the Annuity Payment Amount.
Initials
Claimant-Secured Party:
Assignor(s):
Assignee-Debtor:
Assignee-Debtor:
Attorney for Claimant-Secured Party:
PL QAR&P
v2012
From:
Sent:
To:
Subject:
McGregor, Lorraine
Wednesday, August 12, 2015 11:09 AM
Platt, Thomas
RE: Hunter (EO LaQuan McDonald)
Thanks.Justchecking.
From: Platt, Thomas

Sent: Wednesday, August 12, 2015 11:08 AM
Subject: RE: Hunter (EO LaQuan McDonald)
Thatistrue.Thereisnothingtodoatthistime
From: McGregor, Lorraine

To: Platt, Thomas
Subject: Hunter (EO LaQuan McDonald)
Importance: High
IstilldonthaveanysigneddocumentsorthirdComptrollerrequestform.Frommyunderstanding,thedocumentswere
goingtoberevised.
From:
Sent:
To:
Cc:
Subject:
Michael Robbins <[email protected]>

Wednesday, August 12, 2015 12:02 PM
Platt, Thomas
Jeff Neslund;Laura Coronado
McDonald -
Tom,
Per your request, and based upon the information I have received from the Dan Goodmann and
Don Engles, upon receipt of a fully executed Agreement, and the requisite court order, the City
will issue checks to the payees in the amounts listed below. The revised Settlement and Release,
which reflects these amounts and payees, has been forwarded to yourself as well as attorneys
representing the minor's interest.
1.$2,386,667.00payabletoTinaHunter,asIndependentAdministratoroftheEstateof
LaquanMcDonaldandit'sattorneys,theLawOfficesofJeffreyJ.
NeslundandMichaelD.Robbins&Associates(per:Para.6(i)oftheReleaseand
SettlementAgreement);
2.$800,000.00payabletoBHGStructuredSettlements,Inc.(forTinaHunters
structure);(per:Para.6(iv)oftheReleaseandSettlementAgreement);
3.$916,090.00payabletoPacificLife&AnnuityServices,Inc.(for
structure);(per:Para.6(ii)oftheReleaseandSettlementAgreement);
4.$897,243.00payabletoBHGStructuredSettlements,Inc.(for
structure);(per:Para.6(iii)oftheReleaseandSettlementAgreement);
Totaldisbursement:$5,000,000,asprovidedforinPara.6oftheReleaseandSettlement
Agreement.
Thanks,Mike
Michael D. Robbins
Michael D. Robbins & Associates
20 North Wacker Dr.
Suite 3710
Chicago, IL 60606
312/899-8000
1

[email protected]
Thisemailmaycontainprivilegedand/orconfidentialinformation.ifyouarenottheintendedrecipient,pleasedonot
MichaelD.Robbins&Associatesatthephonenumberprovidedaboveanddeletetheemailfromyoursystem
From:
Sent:
To:
Cc:
Subject:
Attachments:
Platt, Thomas
Real, Elizabeth
Goodmann, Daniel
Hunter
Guardian).docx
DearLiz:
Thisisthemostrecentrevisedversionofthereleasefortheabovecase.ThiswaspreparedJuly21,2015.
ThomasJ.Platt
3127444833

)
)
)
)
)
)
)
No. 14 P 7092

the Estate of LaQuan McDonald), and mother of decedent LaQuan McDonald (also known as
a minor beneficiary of the Estate of
LaQuan McDonald by her court appointed guardian, (also designated herein as a Payee) and
City of Chicago, by its attorney, Stephen R. Patton, Corporation Counsel of the City of Chicago,
by one of his attorneys, Thomas Platt, Deputy Corporation Counsel, herein stipulate and agree to
the following:
1.
2.

3.

current or former officers, agents and employees.
The parties and their respective attorneys
1
economy.
4.
Survival Act and claims under 42 U.S.C 1983 against City of Chicago, Officer Jason Van
settlement, with each party bearing its own costs and attorneys fees. The Estate of LaQuan
the Citys presentation of the settlement agreement to the Chicago City Council and that the
5.
The City of Chicago and Estate of LaQuan McDonald agree that the fact or existence
2
6.
(i)
Cash Payment at Settlement:
Thousand Six Hundred Sixty Seven and 00/100 Dollars ($3,176,667.00) payable to Tina
Hunter, as Independent Administrator of the Estate of LaQuan McDonald, and their
attorneys, the Law Office of Jeffrey J. Neslund, to be disbursed as directed by the Circuit
(ii)
Nine Hundred Twenty Six
Services, Inc. in order to fund the future periodic payments set forth below in Section
6.2(a).
(iii)
Eight Hundred Ninety Seven
in Section 6.2(b).
6.2
Future periodic payments (the Periodic Payments) made according to the

(a)
Payee:
guaranteed 37
years, beginning on July 1, 2023, with the last guaranteed payment on
June 1, 2060. The Annuity Payment Amount may be subject to an
annual increase every July 1st beginning one (1) year after the first
3
(b)
Payee:
guaranteed 37
years, beginning on July 1, 2023, increasing at 3% compounded annually.
7.
(a)
(b)
hereinafter referred to as a Transfer) has been approved in advance in a qualified order as
outlined in Section 5891(b)(2) of the Internal Revenue Code of 1986, as amended (a Qualified
Order), and approved by the Circuit Court, County of Cook, State of Illinois, Probate
all applicable state structured settlement protection statues. Any such qualified order must be

(c)
8.1

the estate of
Once reaching the age of majority, any payments to be made
pursuant to the terms of this Release and Settlement Agreement after the death of Payee
shall be made to such person or entity as designated in writing by Payee
to
the City of Chicagos Assignee. If no person or entity is so designated by Payee

once reaching age of majority, or if the person designated is not living at the time of the Payee's
8.2
writing and delivered to the City of Chicago or the City of Chicagos Assignee.
The
designation must be in a form acceptable to the City of Chicago or the City of Chicagos
Assignee before such payments are made, but in no event shall the request of the Payee be
9.1
qualified assignment, within the meaning of Section 130 (c) of the Internal Revenue Code of
The Assignees obligation for payment of the Periodic Payments shall be no greater than
9.2
absolute.
5
10.

The City of Chicago, or the Assignees, may have the
Annuity Issuers mail payments directly to the Payee.
The Payee shall be responsible for
11.
Payment shall be discharged upon the mailing of a valid check or electronic funds transfer
12.
The Citys obligation pursuant to this Release and Settlement Agreement are
settlement Agreement until the following events occur:
(1) the City receives a copy of this
13.
paragraph 6 herein within thirty (30) days of receipt by the Corporation Counsels Office of a
County for the disposition of funds, whichever is received latest.
The sums shall be payable
will not seek payment from any source other than the City of Chicago. The settlement checks
will be make payable as set forth in paragraph 6.
Each party hereto shall bear its own
14.

6
losses, damages or expenses, including attorneys fees and costs, incurred, or which may be
15.
of Chicago.
16.
17.
18.
7
completely read and explained to the Independent Administrator by its attorney, and that those
Estate
referred to herein.
19.
City of Chicago
Stephen R. Patton
Corporation Counsel
BY:_________________________________
Claimant
BY:________________________________
Thomas J. Platt
(312) 744-4833
Address: _____________________________
_________________________________
Date of birth: __________________________
DATE: ______________________________
BY:__________________________________
Jeffrey J. Neslund
(312) 223-1100
FEIN: ___________
DATE: ______________________________
BY:_________________________________
Michael Robbins
(312) 899-8000
Attorney No. ______________
FEIN: ___________________
DATE:______________________________
BY:_____________________________________
Court appointed Guardian of the Estate of
,
a Minor beneficiary of the Estate of LaQuan McDonald
Address: _________________________________
_________________________________________
DATE: __________________________________
From:
Sent:
To:
Subject:
Collins, Adam
Wednesday, August 19, 2015 11:36 AM
Rountree, Janey;Guglielmi, Anthony
RE: Quick question
Follow Up Flag:
Flag Status:
Follow up
Completed
Ithinkthiscoversit

To: Guglielmi, Anthony; Collins, Adam
Subject: RE: Quick question
Thanks!

To: Rountree, Janey; Collins, Adam
Subject: RE: Quick question
Here'sthelistofitemsthatIamincludinginthebudgetprepprettyclosetoyours.
Levelofviolence
Nationaltrendsinviolence
ACLU
Departmentracebreakdown
HomanSquare
AccesstoCounsel
HowBPDcountscrime
LaquanMcDonald
DanteServin
IPRA/PoliceBoard
__
Anthony Guglielmi
Phone: 312-745-6110
Cell: 312-545-3251
1

From: Rountree, Janey [mailto:[email protected]]
To: Collins, Adam; Guglielmi, Anthony
Subject: Quick question
Higuys,
Sincewehaveanewchiefofstaffhere,ImupdatingthememoIwrotelastspringforForrest.Onesectionisonurgent
pressissues.WhatwouldyouputonthatlistinadditiontowhatIhavebelow?
ongoingstoriesaboutuptickinviolence
laquanmcdonald
acluagreement(doesitgofarenough)
IPRALorenzoDavis&nonconcurrentpolicies
tanningsaloncase
laquanmcdonald
homansquare,ongoingreportingbytheguardian
DanteServin(IPRA)
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Thursday, August 20, 2015 5:53 PM
Rountree, Janey
Memo for the Chief of Staff_August 19.docx
Memo for the Chief of Staff_August 19.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
From:
Sent:
To:
Cc:
Subject:
Attachments:
Laura Coronado <[email protected]>

Platt, Thomas
Michael Robbins;[email protected]
Estate of Laquan McDonald
PLATT 8-26-15.pdf; 08-19-15 Order Appointment Bruce Bornstein.pdf; 8-23-15 Order
approving settlement.pdf; LETTERS of OFFICE - 08-25-15-BORNSTEIN.pdf; Qualified
Assignment & Release Agr signed by Tina.pdf; Release and Settlement Agr signed by
Tina-Bruce-Jeff-Mike.pdf
DearMr.Platt,
AttachedpleasefindcorrespondenceanddocumentsfromMr.RobbinsandMr.Neslund.
Thankyou,
LauraCoronado
AssistanttoMichaelD.Robbins
MichaelD.Robbins&Associates
20NorthWackerDrive,Suite3710
Chicago,IL60606
(312)8998000
Fax:(312)7819123
[email protected]
www.lawmdr.com
Thisemailmaycontainprivilegedand/orconfidentialinformation.Ifyouarenottheintendedrecipient,pleasedonot
MichaelD.Robbins&Associatesatthephonenumberprovidedaboveanddeletethisemailfromyoursystem.
MICHAEL D. ROBBINS & ASSOCIATES

Attorneys at Law
(312) 899-8000
Fax (312) 781-9123
[email protected]
August 26, 2015
VIA EMAIL & HAND DELIVERY

[email protected]
Thomas Platt
City of Chicago Federal Civil Rights Litigation
30 N. LaSalle Street, Suite 900
Chicago, IL 60604
Re:
In re: the Estate of Laquan McDonald, deceased
Dear Tom:
Enclosed please find the following documents:
1.
Release and Settlement Agreement executed by Tina Hunter, as Independent

Administrator of the Estate of Laquan McDonald, deceased; Bruce Bornstein as
a Minor; Jeff Neslund and myself;
2.
A copy of the Court Order entered on August 26, 2015, which finds the settlement
to be fair and reasonable and provides for the payouts for the structured
settlements, and other disbursement pursuant to the terms of the Settlement
Agreement;
3.
A copy of the Court Order August 19, 2015 appointing Bruce Bornstein Guardian
of Minor,
4.
Letters of Office appointing Bruce Bornstein Guardian of Minor,

and
5.
The Qualified Assignment and Release Agreement executed by Tina Hunter.
The originals of the Release and Qualified Assignment and Release Agreement will be
hand delivered to you on Monday, August 31, 2015.
Thomas Platt
August 26, 2015
Page Two
Please provide me with copies of the Release and Settlement Agreement and the
Qualified Assignment and Release Agreement, countersigned of the City.
Feel free to call with any questions you may have.
Sincerely,
/s/Michael D. Robbins
Michael D. Robbins
MDR:lc
Enclosures
cc:
Jeffrey J. Neslund
From:
Sent:
To:
Subject:
Roussel)
Thursday, August 27, 2015 12:00 PM
Perri; Denise C.
Fw: Meeting invite
From: Guglielmi, Anthony

Sent: Thursday, August 27, 2015 11:56 AM
To: Roussel), James M.
Subject: Meeting invite
Chief For the upcoming budget hearing, can we set up a meeting with the following subject matter experts in order to
develop prep materials for the Supt and 15Y Deputy.
ATTENDEES:
John Johnson
Wayne Gulliford
John Escalante
Eugene Williams
Bob Tracy
Eric Washington
Ralph Price
Mary Shear
~ Tony Riccio
Juan Rivera
Brendan Deenihan
~ Jim Roussel)
Anthony Guglielmi
EMAIL:
In anticipation of the upcoming budget process, the Mayor will be holding a series of public, town hall meetings to solicit
public feedback on his proposed budget. Public safety and policing will be a major topic area and we would like to
convene a meeting to help create briefing for the Superintendent and First Deputy. Each of you have been selected to
provide updates and a "current state of affairs" for the below topic areas. Anthony Guglielmi will spearhead the
development of a Q&A briefing document which we will use for both the town hall meetings and the formal budget
hearings before the City Council
Overtime Spending John Johnson /Gene Williams

Hiring of more Police Officers -John Johnson /Gene Wiliams
Levels of Violence, National Trends Bob Tracy
Community Relationships Eric Washington / Wayne Gulliford
ACLU Settlement Ralph Price
Race Breakdown -John Johnson /Gene Williams
Homan Square Tony Riccio /Ralph Price
Access to Counsel Ralph Price
1
How the CPD counts crime Bob Tracy

Bad Businesses /Padlock Ordinance? John Escalante /Ralph Price
Police Board Ralph Price
IAD subpoena power Ralph Price
Police Misconduct / IPRA - Brenden Deenihan /Ralph Price
Laquan McDonald video Ralph Price /Juan Rivera
Anthony Guglielmi
Director, Communications &News Affairs
Phone: 312-745-6110
CelI: 312-545-3251
@AJGuglielmi ~ @Chicago_Police
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Friday, August 28, 2015 12:40 PM
Rountree, Janey;Guglielmi, Anthony
Q&A
Budget Town Hall Q&A.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
Attached.Keepinmindwereallycan'texpecthimtogetintoanymoredetailthanthis,andeventhismightbe
abitmuch.TherearealotofagenciesandI'mnotsurehowwecancrameverythingintohisheadandexpect
himtoretainitall.
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Friday, August 28, 2015 1:04 PM
Adam Collins ([email protected]);Guglielmi, Anthony
([email protected])
Budget Town Hall QA (2)_jor edits.docx
Budget Town Hall QA (2)_jor edits.docx
Follow Up Flag:
Flag Status:
Follow up
Completed
Myredlineattached.IhighlightedsomeissueswhereIthinkwemaywanttoprephimtojustkickitimmediatelytothe
departmentheads.Also,IaddedinablurbabouttheCommission.Ifthatsnottherightplaceforit,weshouldputit
somewhereelsejustwanttomakesureheisremindedabouthisbiggestviolencepreventioneffortbeforethese
meetings.
From:
Sent:
To:
Subject:
Collins, Adam
Sunday, August 30, 2015 11:18 AM
Ewing, Clothilde;Quinn, Kelley
Finishing the budget Q&A
Follow Up Flag:
Flag Status:
Follow up
Completed
ThisiswhatIhavefortopics.Anythingmissing?
ITEMS INCLUDED:
Overallbudgetmessage
Aviation
o
CityColleges
o
Education
Familyandsupportservices
o
Health
Police
o
Transportation
o
From:
Sent:
To:
Subject:
Attachments:
Collins, Adam
Sunday, August 30, 2015 12:46 PM
Mitchell, Eileen;Spielfogel, David;Ewing, Clothilde;Rendina, Michael;Deal, Joe;Quinn,
Kelley
Budget town hall Q&A
Budget Town Hall Q&A.docx
HappySundayeveryone!
AttachedisaQ&AdocumentIplantogettoMREat5pmtoday.ItcoversanarrayoftopicsIthinkmightcome
upatthisweek'stownhalls.IknowthesearenotexpectedtobeQ&Asessions,butthinkit'simportantfor
himtobeabletobeconversantonthesetopicsshouldtheneedarise.They'renotreallyfocusedonthe
budgetasmuchasonalltheotherthingsthatmaycomeup.
Thegoalwitheachoftheanswersistoprovidealittleinsightorvaluesstatementontheissue,thenkickitto
theappropriatecommissioner.Theycanaddressitinmoredetailasneeded,ortalktotheindividual
afterwards.
Pleaseletmeknowifyouhaveanythoughts,editsoradditions.
Thanks
From:
Sent:
To:
Subject:
Attachments:
Platt, Thomas
Tuesday, September 01, 2015 1:42 PM
Real, Elizabeth
RE: Hunter
letters qualified assignments-09012015.pdf; mcdonald laquan release
9012015-09012015.1.pdf; mcdonald laquan release 9012015-09012015.pdf
Herearethesignedaninitialeddocs
From: Real, Elizabeth [mailto:[email protected]]

Sent: Tuesday, September 01, 2015 11:36 AM
To: Platt, Thomas
Subject: FW: Hunter
Importance: High
Goodmorning,aswediscussed,pleaseseetheattached;
PremiumCheck(s)Request080715:Pleasenote,thepremiumcheckisdueinourofficebySeptember11,2015
inordertomaintainthecurrentcostandbenefits.
FCRLDCOMPTROLLERCHECKLIST(BERKSHIRE)080715:Thisisforboth
andTinasstructure
FCRLDCOMPTROLLERCHECKLIST(PACIFIC)080715
Ifyouhaveanyquestions,pleasedonothesitatetocontactus.
Thankyou.
Liz
Elizabeth Real, CSSC
Account Manager Structured Settlements
Mesirow Financial Structured Settlements (MFSS)
t 312.595.7058
t 877.772.4436
f 312.595.4439
e [email protected]
This communication may contain privileged and/or confidential information. It is intended solely for the use of the addressee. If you are
not the intended recipient, you are strictly prohibited from disclosing, copying, distributing or using any of this information. If you
received this communication in error, please contact the sender immediately and destroy the material in its entirety, whether electronic
or hard copy. Confidential, proprietary or time-sensitive communications should not be transmitted via the Internet, as there can be no
assurance of actual or timely delivery, receipt and/or confidentiality. This is not an offer, or solicitation of any offer to buy or sell any
security, investment or other product.
1


LeQUAN McDONALD,deceased, by its
)
)
1
~
No. 14 P 7092

Tina Hunter, Independent Administrator of the Estate of LaQuan McDonald,(hereinafter,
"the Estate of LaQuan McDonald"), (also designated herein as a "Payee"), and mother of
decedent LaQuan McDonald (also known as LeQuan McDonald) by her attorneys, Law Offices
of Jeffrey J. Neslund and Michael D. Robbins &Associates, the estate of
,a
minor by her guardian ad litem, a beneficiary of the Estate of Laquan McDonald, (also
designated herein as a "Payee") and City of Chicago, by its attorney, Stephen R. Patton,
Corporation Counsel of the City of Chicago, by one of his attorneys, Thomas Platt, Deputy
Corporation Counsel, herein stipulate and agree to the following:
1.
The Estate of LaQuan McDonald 14 P 7092, Circuit Court of Cook County,(also
designated herein as "Claimant") has brought a claim against City of Chicago and its employees,
2.
City of Chicago denies Estate of LaQuan McDonald's allegations of wrongdoing

3.

current or former officers, agents and employees. The parties and their respective attorneys
economy.
4.
Survival Act and claims under 42 U.S.0 1983 against City of Chicago, Officer Jason Van
settlement, with each party bearing its own costs and attorneys' fees. The Estate of LaQuan
the City's presentation of the settlement agreement to the Chicago City Council and that the
5.
ordinance authorizing this agreement. The City of Chicago and Estate of LaQuan McDonald and
its attorneys further acknowledge and agree that there is an ongoing criminal investigation by the
federal and state authorities of the incident which is the subject of this release and settlement
agreement ("incident"), and that potential evidence and materials ("materials") relating to this
investigation and potential criminal charges, were obtained by the Estate of LaQuan McDonald in
response to subpoenas issued in the matter of Estate of LaQuan McDonald, 14 P 7092, Circuit
Court of Cook County. The City of Chicago submits that release or dissemination of these
through subpoenas issued in 14 P 7092("materials"), until the completion ofthe pending criminal
investigations and, if criminal charges are brought, the conclusion ofsuch criminal charges by way
2
any publication, dissemination of release ofthe above mentioned materials.
6.
($5,000,000.00), inclusive of all costs and attorney's fees, payable as follows:
(i)
Cash Payment at Settlement: Two Million Three Hundred Eighty Six
Thousand Six Hundred Sixty Seven and 00/100 Dollars ($2,386,667.00) payable to Tina
Hunter, as Independent Administrator of the Estate of LaQuan McDonald, and their
attorneys, the Law Office of Jeffrey J. Neslund and Michael D. Robbins &Associates, to
be disbursed as directed by the Circuit Court of Cook County, Illinois, Probate Division,
Case No. 14 P 7092.
(ii)
Structured
Settlement/Annuity Funding:
Nine Hundred
Sixteen
Services, Inc. in order to fund the future periodic payments set forth below in Section
6.2(a).
(iii)
Structured Settlement/Annuity Funding: Eight Hundred Ninety Seven
in Section 6.2(b).
(iv)
Structured Settlement/Annuity Funding: Eight Hundred Thousand and
no/100 Dollars ($800,000.00) payable to BHG Structured Settlements, Inc. in order to

fund the future periodic payments set forth below in Section 6.2(c).
6.2
Future periodic payments (the "Periodic Payments") made according to the
schedules) as set forth below:

(a)
Payee:
3

, guaranteed 37
years, beginning on July 1, 2023, with the last guaranteed payment on
June 1, 2060. The Annuity Payment Amount may be subject to an
annual increase every July 1 St beginning one (1) year after the first
2024)and the cap of 5%. If the Index Return during the applicable Index
(b)
Payee:
, guaranteed 37
years, beginning on July 1, 2023, increasing at 3%compounded annually.
(c)
Payee: Tina Hunter

$2,821.00 per month for the lifetime of Tina Hunter, guaranteed 20 years,
beginning on October 25, 2015, The final guaranteed payment will be
due on September 25, 2035.
within the meaning of Section 104(a)(2)ofthe Internal Revenue Code of 1986, as amended.
7.
thereto or interest therein (collectively,"Payment Rights") can be:
(a)
(b)
hereinafter referred to as a "Transfer") has been approved in advance in a "qualified order" as
outlined in Section 5891(b)(2) of the Internal Revenue Code of 1986, as amended (a "Qualified
Order"), and approved by the Circuit Court, County of Cook, State of Illinois, Probate
all applicable state structured settlement protection statues. Any such "qualified order" must be
(c)
8.1
Any remaining guaranteed periodic payments to be made after the death of any
Payee pursuant to the terms of this Release and Settlement Agreement shall be made to such
person or entity as shall be designated in writing by any Payee (once reaching the age of majority),
to the City of Chicago or the City of Chicago's Assignee. If no person or entity is so designated
by any Payee, or if the person designated is not living at the time of the Payees' death, such
payments shall be made to the estate ofthe Payee(s).
8.2
writing and delivered to the City of Chicago or the City of Chicago's Assignee.
The
designation must be in a form acceptable to the City of Chicago or the City of Chicago's
Assignee before such payments are made, but in no event shall the request of any Payee be
9.1
"qualified assignment," within the meaning of Section 130 (c) of the Internal Revenue Code of
1986, as amended, of the City of Chicago's liability to make the Periodic Payments set forth in:
Section 6.2(a) to Pacific Life &Annuity Services, Inc.;
Section 6.2(c) to BHG Structured Settlements, Inc.;
The Assignee's obligation for payment of the Periodic Payments shall be no greater than
5

9.2
Payments obligation assigned to the Assignees. The Claimant recognizes that, in the event of
absolute.
10.

Section 6.2(a)from Pacific Life Insurance Company;
Section 6.2(c) from Berkshire Hathaway Life Insurance Company of Nebraksa;
(collectively the "Annuity Issuers").
shall have all rights of ownership. The City of Chicago, or the Assignees, may have the
Annuity Issuers mail payments directly to the Payees. The Payees shall be responsible for
maintaining a current mailing address for the Payees with the Annuity Issuers.
11.
Payment shall be discharged upon the mailing of a valid check or "electronic funds transfer"
12.
The City's obligation pursuant to this Release and Settlement Agreement are
settlement Agreement until the following events occur: (1) the City receives a copy of this
an ordinance on April 15, 2015 approving the total amount ofthe settlement.
13.
paragraph 6 herein within thirty (30) days of receipt by the Corporation Counsel's Office of a
D
County for the disposition of funds, whichever is received latest. The sums shall be payable
will not seek payment from any source other than the City of Chicago. The settlement checks
will be make payable as set forth in paragraph 6. Each party hereto shall bear its own
attorney's fees and costs in connection with this Release and Settlement Agreement, the matters
14.
losses, damages or expenses, including attorneys' fees and costs, incurred, or which may be
15.
of Chicago.
16.
7
17.
18.
completely read and explained to the Independent Adninistrator by its attorney, and that those
terms are fully understood and voluntarily accepted by the Estate of LaQuan McDonald. Estate
referred to herein.
19.
B~~~
City of Chicago
Stephen R. Patton
Corporation Counsel
~~~,

Claimant
BY:
Thomas J. Platt
(312)744-4833
~ /d6 ~
Attorney No.
02U/S
DATE:
Address: ~~O~ (n~ l I ~~~
~.'h,'cago, ~~ ~0~~3
Date of birth: l~ "~(~~
~~
BY
Jeff
Attc
20 N. Wacker Drive -Suite 3710
(312)223-1100
Attorney No.
~ ~~
FEIN: ~]- Z~5 ~fC~78
BY:
Michael Robbins
Law Office of Michael D. Robbins &Assoc.
(312)899-8000
Attorney No.
~`~_
DATE:
BY: ~I~~W~.~Id
Guardian ofthe Estate of
, A Minor
Address: 2
'~ ~ ~ ~tS~ ~~ ~ ?,3~~
C~~C~Ibb sG 6QboI
DATE:
~'2.6~%S
G]
t>r'(IC'
:~~1~)(t(lTlii~ ~~uardiai~
~~f' ~~ii~~or
(Itc~. O');O6/13~ (~(~(' I)3~i~
I\ ")~FII'. ("Iit('i'I'1~ ('O[ K'I~ Uh ('OUh ('O[ \"I~1', Il.,l.f\Ulti

('Ul \'I'1' U!?I'.1R'1~~11\'1' - t'RO13,~"C P. [)11'I~+IO\
r..~;itc of
15 P 4746
1linor
ORUC?k :1PPOI\'I'I\(: Gl',~RUi.~ti OI~ ~t(tiOIt
Ox~ the ~~ciificcl ~~etition ~f~_BRUCE B~RNSTEIN
s~p~~nintnlcnt o1' n ;;uarcti.~n, duc notice having hero
_._._. f'~~r
given
fftl' ('Otlt't rla~'irl~~
considered the evidenr.e,

t"I' (SiURDEItI?U that:
~.
BRUCE BORNSTEIN
,},,.
is appnittted the ~:uar~liau of
ESTATE
~
letifxtci
Q 125h
of the f~ilinwiu~ minor:

(estate :~nJ persons
d25'
-----------(prrsunl
Q a22i
2. I h~~ bond ~~f the ~u.~rdian is
approved
(appr114cd J6I I)
1aivi,d ~36z~)
3. Letters of ~uarciia~rship slixll issue;

x-#. Tl~e guardian of the estate shall file :in iiiventar~ in Room 1810
2015
~ L~ ~0`~. r` Zi ~
~t 1O:f10 ~.rn.
nn
. lticli~u~~l .I. I)nlc~~ ('e~iirr

i-~z;u,
~~5. 7'i~e ;;uxrdi~n of the estate sh:Il deposit the minor'. }'i~n~ts in an account in tlae us~mc ~f tl~c niiu~~r, subject t+~
itt~dra~v-;~1 ~~nl~~ cn ~~rder of court nr upnn the att~inrnent of'maj~rit~, in an institution qualified to erci~ c ttie dep~sit.
2015
d
~1'hc guardian shall file a report ~f receipts acl cli~l~ursements, ro~;ether with vouchi~rs, nn
~t 10 a.m.
.~~1.!anon appr~~val of the rep~~rt, the ~;uArdi~n ~~nd surc:t~ shstl be ~lischs~r~ect
in Rootu _~ 810s__
r~z~ua ~az~i~
,end the c~~:ite closed.
.~tl~. ~~ir: ~ ~ 22$

,~~{~; Edward Y. Lau
~:;r~ ~;r~: Law Office of Edward Y. Lau
\ttv. i'or!'ctitioner: Bruce Bornstein
.~a~ires~: 30 N. LaSalle St., #3200
C'it~~/St~ftc~%ip: Chicago, IL 60602
"I'clephonc: (312) 346-1155
a~a5~ ~:~ ~M1~ L.;4ci,;r:~~~;

,Y
~
--
~U~'I~10':~i
.J,...
:~ ,, .~ s
^..r~USy f:~.~~:.
':~trikc iP not :~pplic~ble

I)ORO'('1~1Y t3RO'\, Ct.l~,ltK O1~ "I'i11: ('tltt't?1'i' CO[TR~' OF('OOk ('O1'\'fl~, t[.1,1\c)f~+
.GETTERS Or QFFIC~GUAi2U1A~1 QT+ ESTATE
(Rcv, 12/23/00 GCC'0~1G
IN THE CIRCUIT C(JUl2T 4F COt)K GOUN"CY,1l~LN()I'

COUN"I'Y uGl'Al2TMCNT-f'ROF3/1TCD1 VISIUN
estate of
lYo. 2t}l5 F Q0~746

C?oekeC
Minor
I'atic
UTTERS 4F OrFICE - GUA12Y)IAN OF ~STAT~
has been appointee
BRUCE BOIZN~'1'E1~1
;uardian pf tE~e estate

,i minor, barn on Tuesday,
200U
ancf is autborizec! tahave undc>r the directir~rti ai'th~ court the care, m:~i~.~g~nzent and investment of the minor's
an~i to d~ .ill Picts rc~quirGd by lR~v.
estrite
~.ti
wi~rN[:5~, A~i~ust 19, 2015
Doratt~y Brawn
Cicrlcc~i'tt~c t'ircuitCaurt
CEI2TIF'tCATE
1 crrtif} that this is n copy ui'the letters of offitc npw in Yo~ce iii this est:~ie.
Dl3
DURU"I'1-ilr' liIZt)W N,Cl.l~:lt K()1~'Tf-I l{, CI C2C[).t'r'COURT t)I+COOK LOUN'I'Y,IL~,INUIS
Qu~iif~~~ Assignmer~t, R.el~~se end Pi~dge Agre~me~t

~n Acccrrdarce nth
Internal i?ev+~nue Gode $e~tian y~0
'Claimam~t~ecured ~arty(ies)~~: ~~e Es#~t~ of LaQuan McDonald, Deceased, arrd
'~A~ssigr~~or": ,,~ixy of Chicago
'Scttl~rt'n~rlt Agreement": R~L~AS~ AND S~i"T'LEMENT AGRE~M~NT~

~Eic~ct title of Sottlomer~t Agr~emont or C~r~dor]
_.~ M __..
R~ov~ming i~~w"~: IAinais

~"ASsif~~e~-I~ef~tQr"';
SHG S~'~iUCTU~iENJ._S~'F'~`~~F'1!~F~1~~. 7NC_
""Annu~ty~ Issuer": ~~~KSHiRE MATHAI~/AY LIFE INSURANG~
coMPANY o~ N~eRAsrc~
~~~ffecti~re Date":
""P~'yee(S)": ,A,~ sk~ar~m :Ln X~Idendum No. 1, De,sCxi~ta:on off_ ~er~.od;Lc Payments
Ar~nyity Contract No.:
"his Q~u~fi~ied Assignment, Release' and

Pledge ,RIgK'e~eKertt ("Agreement"} is made and
~ntel~ed irltA as of the Effective Date by and
among the undersigned patfieS with ~ferehce tq
the fallov~+~ng facts;
A. Claimant-Secured Par'kypes) and Assignor
are parties to or are aEherwisE subjact to tha
above-refoc~nced Set~lamertt Agreement
under whrch Assignor des liability to m~kb
certain periodic payments to tho d~sigr~~ted
Payees) as speciTied in Addendum No, 9 of
this Agr2em~nt (tt~e "periodic I'~yments").
Where no Pay~~(s) other than GlaimantSeCul'ed P~rty(ies) art shown in Addendum
N4, 1, ii is undel5tood that any re4erences
herein to Payees) shall apply to Cfaimant~
Sectored Party(ies),
SS-200(12/2093)~S]
~. Assignor ~n~d AS~ignee-Debtor w(sh to effi~ct

a "qualrfied assignment" within the meaning
and subject to tlt~ cdndik~ans of Section
13Q(c) of the Intem~f Revenue ~tid~ of
1986, ~s amentted {the "Code".
C_ Assignee-D~btdP desil~s #0 grant t4
Claimant-Secut~d Party(ie5) a secured
irlkerest to secure the liability being assumed
by Assignee-C~ebtnr to make the Periodic
Payr~ents.
D. This Agl'~Qn'i~nt wlq be effective contingent
upon /~ssig~ee,bebtor's receipt of the full
premium to fund the Periodic Payments
contained herein.
~~ge ~ d~~
Novi, therefore, in consideraY,lon of the

foregoing and fpr other good and valuable
conskiet~tfon, the parties agree as folic~ws;
1. Assiyne~1t end AssumptRan; Rel~~se of
Assignor. Assignor h~rEby assigns #o
Assi~ne~-Debtor, end Assigrlee~[]ebtor
hereby accepts end assumes, III of
Assignor's liability to make the Periodic
Payments. each Claimant-SEcurod Party
helre~by aCCepts end consents 10 Such
~ssi~nrneM by Assignor and ~ssumpt~on by
AsSi~rre~beb#qr. ~ffectivs vn the Effective
Dike, aach ClaimarrtSecured Party hereby
r~ieases and diSCh2rgos Assignor from all
fi~bility tp make the Reripdic Paymonts,
il~cludir~g the 'Pilate bf ASSignee~Debtor tq
make any of the Periodic Payments andlor
Annuity Issuer to fund any of the Periodic
Payments Tor any reason whatsoevret.
2. Nature ~ P~ripd~c P~ym~nts. The F'eri~ic
Pay~rlents GOrl5tikut8:
i, damages (~therthan punitive damages),
5.
~hekher by suit or agreement, or
ii. coRnpk~nsation under a vvorkers'
compensation aGt,
on aCCount cif personal injury ar sickness In
a case Involving physical injury or physic~i
siCkn~ss, within the me&ring of Sections
130(c) and 10a(a) afihe CodQ.
3. ~xte~nt Q~' ,Assignee-I~~bto~r's ~,iability,
Assl~ne~DEbtor's liabpfi~y t0 rr~~ke the
Periodic Payments shall be no greater than
the Ifabiltty pf Assiglrtor as of the effective
Date. AsSig~Ee-Debtor assumes no liability
other than the 1fab11lty to make the Periafic
Payments. Assignae-Dobtor's liabiliky to
liquidation ar rehabilitation of Assignor.
~, Qualified Funding Asset. Assignee-Debtor
wf11 fund the Periodic payments by
purchasing from Annuity Issuer a "qualified
iundimg asset," a~ defln~d in Section 13U(d)
of the Code, in i~te fomn of an annuiky
contr~Ct (the "Ar~rluft}~') issued by Annuity
Issuer and providing for payments
ca~respontling to the E~erlodlc Payments.
Assi~n~Debtor shall be designated as the
owner Of th8 Annuity. AN rights of legal
ownership and control of the Annuity shall
6.
(subJect to pa~r~gr$ph 9 of this Agreemen#)
b~ and remain vested exclusiv~l~ in
Assiglnee-F7~btor, including the right to
roCoivB end t~tain aN benefits under the
Annu{ry which are nut inconsistant with the
secu~'ity .n#e~'est grant~tl under paragraph
11; ptOwd~Cl, however, that~the Annufty shall
SS-2000(12/2093)(SJ
Page 2 df 6
be used by gssignee~Debtor to fund the

Periodic payments and shall ax all times be
des9gn~ked by Asslgnee~~ebtnr nn its
cords as being taken into accoun#, under
Sec#ipn 130 of the Code, wi#h respect to this
Agreement_ Nokwithst~tldi~tg ~nyth9ng to She
contrary cot~inecl in this Agreerrlont,
neither any Claimant-Secured Party, any
Payee, nor any Successor Payee (as
defined in p~r~graph 8 of this Agr~eernen#)
shall have any rights wikh respeck to ih~
Annuity or the payments thereunder that
would cause any amount attributable to the
Annuity to be currently includible in the
recipient's income ar would o#herwi~e affect
the det~llmin2tion of when any recip~eni is
t~ated ~s having ~eceiv~d any payment for
income tax purposes, or would otherwi5fl
prevent tfnis Agre~mnnt from satisfying all of
the conditions fora "quatih~d assigrtmer~t"
within the rt'1~aning of Section 13U(c) 4f the
Lode.
delivery of Payments. Assignee~Debxor
may instruct Annuity Issuor to send
payments directly to Payee or Successor
F~ayee, or ~a deriver payments by electronic
funds transfer ("E~~ to an FDIC-Ensured
deposRory institution in the United Stites for
crodit (directly ar ir~diractly) td an insured
account In the name oT such Rayee or
Successor Payee. Such direckion of
payments under the Annuity shall npt be
deemed to afford Clafmant~SeCured Marty,
Payee or any Successgr Payee any rights at
ownership or corrtrai ofthe Armuity.
each Clafm~nt-Secured Party, F'ayoe and
any Successor Payee shall at all times keep
Annuity Issuer apprised of such ClaimantSecured Party's, Payee's or Successor
Payee's current mailing address and
t~l+~phone numbar and, 'rf Payee ar
accourrt name and account number to which
the payments are to be Creditet9, Such
notices shall be in ~ form provided by
gnnui~y Issuer and must be received at least
thirty (3U) days prior to thc~ date ~~yment is
due.
Discharge of Liability. Assignee-D~btOf's
li~biliky #p make etch PeripdiG Paymet~# to
any Payee or Successor Payee dEsignated
to r+~C~ive suoh payment shall be fully
discharged upon:
i. the mailing of a valid chick on or bergr~
t~ddress of record spEci~ed by Payee or

SuCCessor PayeO; ot`
il_ the in~ti~ion of an ~,FT pay~tlent on ar
1'he Unit~tl dates ~nana~al institution
account desigr~atQd by Payee qr
SuCCessarPayee
If Payee or Successor F~ayee does not
r+~celve a scheduled payment by check,
Pay~+e br Successor P~tye~ shall notify
Assl~nee~aebtor. Upori t~Ceipt of such
nptificatinn, Assignee~Debtor shall initiate ~
sttp pa~rrnent ackiolt for such check and
uporn CAnfi~mation that such check was Itgt
previously negati~ted shall promptly mail a
replacement check; or
ff payee ar Succassnr Payee does not
receive a scheduled AFT psymer~t, P~y~ ar
SuCcossor Payee sn~ll notify Ass~gneeDebtor. Upon receipt of such notification,
AssignorDebtor shAll initiate a trace for
such payment and upon cvr~firma#ion that
such paymen# was not cred~ked to the
account shall promptly issue a replacement
AFT payment.
7. Acceleration, Trartgl`er o~ Palyment
Rights. None of the 1'eriodio Payments and
no rights tv or intr~r~5t in any of the Periodic
Payments (a11 of the foreg~in~ being
hereinafter coll~ctivefy ref~rr~d to as
"PayMnent Rights' can be
i_ Accelerated, deferred, increased oP
cl~creased by any recipiEnt of any of the
Periodic Paymen#$; or
n, Sold, assigned, pledged, hypothecated
cr otherwise trans#erred or ~ncumb~red,
nr c~her trans~r or encumbrance (any
such transaction beirg h~rein~ftet
referred to as a "Transfer's has been
approved En advance in a "Qualined
~rdcr" as defined in Section 5891(b)(2)
~f the Cgde (~ "Qual'~red Order") and
c~therwiso cbmpti~s with applicable stato
applic,~bl~ stag structu~d sattlemerrt
pr+nteclion st~t~te,
No Claimant-Secured Party, Payee or
Successor Payee shall have the power to
elect any Transfer of Payment Rights
except as provided in sub paragraph (i)
~bov~, 8r~d any other purported Transfer of
Payment Rights shall be wholly void, invalid
and ~unenforneable. 1f Psymer~ Rights undgr
this Agreement become the subject of a
s5,2oo0(1212013)(sj
Transfer approved in accarrl~~lCe with sub

paragraph (ii) sbave tho fights of any direct
or indirect transf~rae of such Transfer shall
be suhjcct to the terms of this Ag~ement
and any defense oP C18im in reGqu~mEflt
~risir~g h~Peunder_
8. Conti~ge~t ~e~teficiaries. Any Pe~icldia
Payments to be made aRer the death of any
Claimant-S~ur+ed
Ratty, Payee
or
SuGCes~or F~ayee shill be made #d SUCK
party as Khali have been designatdd in, or (n
a[;cordance wiCh, the Settlement Agreement
or, if the 3ettiemen; q,greerx~ent does not
provide for such deslgn~tibn, iht~r~ to the
party design~t~d in canTarmi~y with this
~~g~ph 8. Any patty so designated is
referred to fn this Agreement as a
"Contingent ~ene~ci~ty." If no Contingent
B~n~fici~ry is living ftt the time df tha da~th
of a Claimant-Secured Party, Payee or
Successor Payee, payment shall ba made to
the deC~dent's ~stat~ unless othenMse
prgvided in the Set#lement Agr~eem~nt. As
used in this Agreement the term "successor
Payee" refers to a Contingent Beneflclary or
receive Periodic Paymen4s following the
death of a Cl~~mant-Secured Parley, Payee
or a SIIGcessor Payee. Except where a
designation hays been made in the
Settlement Agreement, no designakion or
cha~l~e of designation of a Contingent
~an~ciary shall be effeciiva unless such
designation pr change (f) is quested in a
written request submitted t~ Assign~eDebt~r in accordance wi#h AssigneeDebtar'S
customary
procedures for
processing such requests; and (ii) is
confirmed by Assignee-pebkor. HoweUer,
AssigrteemDebtor will not be liable fvr any
payment made prior tc~ receipt pfthe reques#
or say scan #hereafter xhat payment could not
re~sonabty be stopped. Except tot 2
design~tiort that is expressly identified in she
S~lement Agreement as imevticable, any
d~signati~n of ~ Contingent Beneficiary shall
b~ deemed #o be revocable; and no party
that is dt~signat~d ~s ~ Contingent
beneficiary (other thin a party irrevocably
designated as e Contingent 6eneHciary in
vi~ue pf H~ desfgnatioll as a Contingent
Beneficiary, be deemed to h~v~ any
P~ylments,
9. Tertnir~tian of Settlement Agreemerrt /
Failure to Satisfy Section 13U(cy. If at any
time prier to cnrnple#tan of the Periatic
Payments, the SettlemaM Agreom~nt is
Rage ~ of ~
declared terminated in a frnal, nonapp~alable order of a court of Campotent

jurisr~icti~n (ar in the case of a workers'
aonnpensation settlement, a final orrlr~r ofthe

applicable workers' campensatfon authority)
or if it is determined 'm any final order or
130(c) of the Cade have not beEn satisfied
fn cC>nnection wRh this Agreement: () the
assignment by Assignor to Assignee-Debtor
of the liability to make the Periodic
P~yme7ks
And
Assignee-D~btar's
acceptance of such assignment shill b~^ of
na tome of effect; (I~ Assignee-Debtor shall
be ccanclusi~ly deemed to be acting as the
agent of Assignor; (ffi) the Annuity shall be
owned by Assignor, (i~ ire the even# the
Settlement Agreemenx fs not tormin~t~d,
Assignor shall reCain the liabilky to make the
Periodic F'~yments; (v) ASSigne~Debtor
shall have nd liability to make s~ny Periodic
Rayrnents; and (~i) the parties hereto agrees
to cooperate in taking such fictions ~s may
be necessary or appropriate to implement
the faregging.
10. Gev~rraing
~avv;
~~ndin+g
~l~ct;
insolvency of Ass~~nee-D~abtor.
This Agreerr~ent shill be governed by
and interpreted in acccar~al~ce v~ith the
internal laves of the state identified as
Coveming I~aw above; prgvided,
obligation of Assignee~Deb#or to make the

Periodic Payments. Assignee-Debtor and
Claiman#-Secured Party(ies) shall npKify
Annuity Issuer of the Gen created under this
Agreement, and
uecured Parky(ies) upon execution of this

A,greetllEnt and receipt by Assignee-debtor
ofthe Annuity f`~prtt Annuity Issuer.
'12, Advice, Comprehet~$ion of Agreem+~~tit. In
entering into this Agr~emen#, each Clalmantsecured Party warrants, repr~s~nts and
agrees that Claim~nt~eCu~Od Party is solely
relying 4n the atta~eys and advisor3 pf

such GlaimantSecured P1fty's awn
chop$ing, end not upon Assignor, Asslgnee~ebtor dr their advisors, fir advice regarzlPng
the legal, government bt~n~fits anCl tax
advice ~egarrling the consequences of this
Agr~em~nt. each Clafmar~-S~aur~ed Party
fUrkher warrants, represents and agr~eeS that
the teens of this Agreement hive been
completely read by and explained to such
Claimant-Secured Parley and are fully
understood and voluntarily acc~~pted by such
~laimar~t-Secured Forty. Furthermore, eBCh
Claimant-Seeunecl Parley hereby releases

end discharges Assignor, Assignee,Debtor,
Annuity Issuer, their affiliates and their

rEspective
employees and
adUrsors
{"Releasees") fiom any and a!I claims,
na~ur+~ whatsoever that such Claim~ntSecured Party now has or may have in the
futare agates# such Releasers (i) with
f~SpECt to 1h~ p~sent aC~d futu~ taxation of
this Agreement or the Periodic Payments; or
(i'r'k the implct that this AgroEme~t or the
Periodic P~ymen#5 may havQ on ~I~liman#Secured Party's eifgibillty for, and the
quantum af, any ~av~r~m~r~faf benefit
paymEnts,

s~bjeCt to tt1E laws of Other states in
addition !o the state designated 8bov~e.
ii. "this A~reeme~t shall be binding upon
the part~~s hereto and their r~spe~tive

successors,
executors,
heirs,
administr~tars and permitted assigns,
including without #imitation any party
~~serting ~n int~r~st in Paynitr~nt Rights.
Qii.lf, dui to insolvency or bankruptcy
Asslgne~a-pebt~r has tailed #o make any
o~F the Periodic fi~ayments, and such
f2iilure is continuing, ~faimant~ecured
13. Futu~ Cooperation. All parties agreo to

CODperahE fully end t0 tl~Gute ~riy,and III
supplementary documents and ts~ke all
Patty(ies), ~r in the ev~r~# o~f the death of
applicable C{apmant~ecur~d Party(ies),

SucCE~ssor Payee sha11 have all of the
rights and remedies of a secured party

urtld~r the law then in efFect in the Stato
o~ Nebraska.
19 , Clairn~nk~ecur~d Party Status AssigneeDebtar h~~~by pledges and grants to

claimant-Secured Party(ieS) a Lien nn and
security in#rest in a!f ofAssignee-~eptor's
right, title, end interest in the AnnuiEy end all
payments thetafl~pm in Or~l~r to sECure the

S5-2000(12/2013)[S]
Assign-Qebtor 8h~ll
deliver a copy of the Annuity to Cfaimant-
Page 4 of 6
additiana#actions, which are not inconsistent


Assignment,
R~I~ase
and
Pledge
Agreement. Pursuant to its obligations
under this paragraph 13, and wikhout
(imitation, Assignor shall promptly provide
Assignee-Debtor with rgpie$ of any requix3d
.court approval wi#h respect to the underlying
settlement and execu#ed copies of all
required settlement documents.
14. des~rip~ior~ o~F Periodic Paymepts, The

Pe~tr,~dfa Payments are ~s set forth in
attached Add~r~dum No. 7, which is hereby
iraprpp~ted in and made a park of phis

Agreement.
~n t't~e ew+~rrt o~ ~.r1y cor~tTict beMreen this ~Agreement~nd the ~ettlennent Agreer~li~rrt ~nrith respect to
the F'erRoda Paym~rrts or the ~ssignrr~ent made herein, the tentts and canditpon~ of #his
~gifeemprrt shall prevail;
This Qu~ali~ad Assignmentand I~ele~se A~reerx~n~k n'ay b~ signed in one or more courrterparts,
Assignoa~_ ~i~y t7f ChiC,d~O
~y:
Tit(; Q~p~tY corporation Gounse!

Assignee:
~ir~G stx~u.ctured s~~tl~m.~aa~~, tr~n.
By.
Authariz~ci Reprosentativ~
~~aiman~t{s) or Pay~e(s)t
, A Minor
The estate of LaQuan McDonald, d~c~3~sgd
Attom~y for ClaYmant(s):

,Ap
ved as to Fo
.. Y
and Content
'~J'
Mic a~i Robbins
SS-2000(1212013)(SJ
Page 5 of6
Addendum Na. 1
De~~raption of Periodic Payments
Payee:
T~ri~n~ Hinter
$~,$5Q.00 per month ($22,200.00 per year)for the life o~

, guaranteed
37 years, beginning ~r~ July 1, 2Q23_ T'h~ amount ~f the payment shall increase by 3%
campo~nding annually on July i st of each year beginning July 1,X024. The final
guaran~eed payment aril! be on June 1, 20 0.
~30,OQq.00 guara~t~ed lump sum payable on March 28, 2023.
$60,Od0.00 guaranteed lump surrti payable an /larch 28, 2030,
$75,000.Op gu~rant~~d lump sum payable on Il~arch 28, 20~1d.
$125,OQC}.00 guaranXeed lump sum payable on March 28, 205 .
$225,00 .00 guaranteed lump sum payable on March 28,206 _
INITIALS
Assignor:
(~Q
~I ~
Assignee-Debtolr.
Cla~r~n~~.S~~Cured Part~r or Payee:
AttOrn~y for Clai~'Inant:
552UOD(12J2013)[S~
Page 6 of 6
~,11~UI'ttr SI~M~CES. 1N~.
C2uakified Assignment, ~elea~~ ~n~! Pledge A,gr~~ment

~n Accc~rdanc~ Wi~i~ Interxaal Revenue Dade Section 130
"~Iafmantn5ecured F'~rty":
Thy E.~~t~ of LaQuan MCDonafd,deceased

, A Minor
"Assignor(S)":
City of Chicago
"Assignee-Dabtnr":
pac[t~c I.pT~ 8, Annuity Services, lnc.
"Annuity issuer":
R~cifi~ I~il~
"Annuity" Paticy Nv_~

"effective pak~":
This Qualified Assignment, Release, and Pledge Agreement is made and entered into by and among the p~~ti~s
hereto as of the ~~'eGtive Qate vuith re#ere~ce to the fallowing facts;
A. Cl~irrr~nt-Secured Party has execwted a se#tlement agr~em~nt or re~pase dated
(the "Settlement Agreement') which requires Assignor ko mike certain peri0di~ payments to or for the
benefit of the Claimant-Secured Party as stated in Addendum Np, 1 df this Agr~~menk (the "Periodic
F~yments").
B. The parties desire its effect a "quaiitied assignment' within the meaning and subJect to the conditions of
Sectiron 130(c)of the Internal R~v~nue Code of 9986, as amended (the "Code).
C. Thy Assignee-C~ebk~r desires to grant to claimant-Secured Party a securtty inkerQst to sQcure the li~b~li~+
beina~ assumed by Assignee~Debtor to make the Perfc~diC Payments.
Now,therefore, In cansideratian of the forgoing end for ofiher good and valuable consideration, the
parties agree a~ follow$;
1. ~ubje~t t~ qu~lfication under Section 130(e) of the Code, Assignor herby assigns and
Assignee-Dabtor heteby assumes all of Assignor's liability t4 make the Periddi~ Payments.
Assignee-L7ebtor assumes no liabtlfty to mike any other payment. Cl2~im~nt-~eGured Party hereby
accepks end cartsents to the ~ssi~nment by Assignor and the assume#ion by Assignee-Qebtar of the
liablllty to mike the Perit~dic Payments, end upon the Effective Date Claimant-Secured Party reie~ses
As$ignor from all liability to make the Periodic ~'ayments.
?. The Periodic Payments constitute damages an account of perst~n~l inaury or sickness in a r,~se
involving physical fnJury pr physical si~knes5 within the me~nir~g of Sections 9d4(a)(1) pr 1040)(.2)
anct 130(G) of the Code.
Pacific Life refers tc~ Pacific Life Insurance Company and its affiliates, including Paoific Life R Annuity Company. Insurance
products ire issued by Paelflo Life Insurance Company in atl states excopt Now Yerk and in tJew Yvrk by F'acfic Life &
Annuity Company, Product availability and features may vary by state. ~aoh company is solely resp~nsieie for the Flnancl~i
abNgatinna accruing undor the products ft issues, Inaur~nce product and rider guarantees are backed by the financial strength
antl cl~lms-peying ability ref the issuing company.
PL. QAR&P
v2012
3. AssignerQebtor's liability to make the Par~odia Payments Is no grater than that of

Assignor
immedla't~ly prior to this Agreement, None of the Perfodic payments may be accelerated, as determined
defmrred, inct~eased or
c~ecre~sed, antiaip~tnd, sold, assi~netl, pledged, or encumbered by ClaimanR-Secured
Marty,
4. The oblig8~tion assumed by Assignee-ClebSor to make e~Ch ~pplicabl~ Periodic Payment
shall be fu(iy disoh~rged
upon khe mailing of a valid check of wire transfer of lands on or before the due date fbr such
PeModic Payment to
the atldross of ~ecsrd specifiQd by GlaimantSecx,r~d Party.
5, 1"his AgreeAlent shaft b~ govemetl by and interpretetl in ~cCordancp with the lauvs of the State of
_l~l~_6. fls~ignee,0el~tar may fund the periodic f~ayments by purchasing tno Annuity from Annuity Issuer tp serge ~s a
"qu2~li~ed funding asset" within the meaning of Section 13p(d)of the Code. All rlght~+ of ownership artd ~ontrul
of
the Annuity shall be and 1'emain vested in the Assign~e~Debtor except as pP~bvided in paragraphs 19 artd 12 of
this Agreement.
7, Assignee-I]ebtor may have the An~uiky Issuer send payments from the Annuity directly to the payees)specified
in Addendum No.1. Such dl~ction of payment shall be solely for Assignee-~+Debtor'~ convenieno~ ar~tl shall not
R~v~a~ Claimant-Secured Wa~#y or any payee with any rights of ownership or control over the Annuity or against
Annuity Issuer,
8. Any Periodic Payments to be matle aftQr the death of any Claimant or Successor Payee sha11 be made to such
party as shall have been deslgn~t~d in, or in acevrdanoe with, the S~tllernent Agreement or, if the S~ttiement
Agreement does hot pl"ovide for such designation, then t4 the pa~Yy designated in confo~mlty with this paragraph
8. Any party so d~~ignated is referred to in this Agr~emont as a "Contingent 8er~efioiary. It no Contingent
E~enefls~ary is riving at tn~ elms of the death of a Claimant or Successor Payee, pagment shall be made to the
~deceder~~'s estate. As used in this agreement the term "Sucpessor Payee" refers to a contingent B~neflclary or
an estate that has beFome enHfled to receive Periodic Payments fallowing the death of a Cl~imani or a
Successor Payee. ~xc~pt as otherwl~e provided in the Seftlement Agreement, no des~gnattan or ohange of
designation Of a Contingent 8aneficiary shat) be eifective unless such Change (i) is r'~squesfed in a written request
submitted to Assignee (er its authorized agent)in accordance with Ae~fgnee's customary procedures far
processing such rQquests; and (il) Is confirmed by Assignee (or its authorized agen#}, except For a deslgnatian
that la Qxpressly identified in the Settlement Agreement as Irrevocable, any designation of a Cnntin~ent
beneficiary shelf be deemed to be revor,~ble; and nn party that is designated as a ConU~~ent Beneficiary (other
than a patty irfevoc~bly designated as a Contingent Btnefloiary in the Settlement 1~greement)sha11, solely by
virtue of its dEslgna#{on as a Contingent Benefloiary, be deemed to have any oognlz~ble interest in any Periodic
Payments.
mote: Beneficfanes seotion only applies to guaranteed benefits(Period Certain, Lump Sum(s), Lice with Certain
payment&).
8. As~ig~ee~Debtor's liability to make the Porfadia Payments shall continuE without diminution regardless of any
bankruptcy or insolvency of Assignor.
10, 1n fha event the SOttiement Agreement I& dec~arod terminated by a court of bompotent jurisdiction the parties
sl~all act in accorclanCe With the ortiers of the court; prpvfded hov~+eVer that nbthirtg in this paragraph sh~11
preclutl~ a party #o this Agr,~ement fmm appealing any order or Judgment of a court. In the event that Section
13Q(c)of the Code has nok been sat~stied,(t) the assignment by Assignor to Asa~gnee-Qebtor of the liability to
mike the peripdf~C payments to ClBiman!-Secured Party described in p8rsgraph 1 of this Agr~omerit shad be of
no force and Qffect, (ii) the Assigne~Debtor shall ba ~cking in the h~a~sactlon as the agent of the Hssig~or and
the Annuity shall be owned by Assignor whloh will continue to have #ho liability to make the Periodla Payments t~
Claimant-Secured Party, (iii) Assignee-Clebtor shall have no liability to mike env periodic Payment to
Claimant-Secured Party, and (iv)the parties hereto agree to cooperate fn taking such actions as pro reasonably
necessary or appropriate to achieve the foregoing.
PL QARB~P
V20'i2
1 i. 'This Algr+eement sh~fl be binding upon the respective repreSentS~tives, hQir~, successors
2nd assigns of the
~aarties heroto and upon any person or entity that may assert any right hereurdor or tv any of the
Petfodic
P'aymests.
12. Assignee-Debtbt' hereby pledges antl granCs tc~ Cl~irnantSeGufed Party a lien on and security in~e~sS all of
In
A&sfgnee-debtors right, title, and intePe9t in the Annuity and all payments therefrom in ordor to Secure the
obligation ofthe Assignoe-pebtor to make the Periodio Payments. Assignee-bebtor and Claimant
-Secured Pally
sh&II notify Annuity issuer ofthe Iles created under this Agreement, and Assignee-t~ebtor shall deliver the
~nnufty to Claimant-S~ou~d P~Ry upon execution of this Agreamert and receipt by Assignee-Debtor of the
Annuity Cram Annuity Issuer.
7 3. Asslgnee~Debtor shall have alI rights of owner~hlp antl control in the AnnuiSy, including She right ro receive
and
retain all benefits under the Annuity, which are not inconsistent with the security intcrost granted under
paragraph 12, and Claimant-Secured Party shall have no right to anticipate, sell, assign, pledge, encumber, br
otheruvlsa exercise eny right with respect to the Anttuity, so long as Assignee-fJebtor has not failed due to
insolvency ar bankruptoy to make any of the P~riodlc Payments. If a ~ailuro Qoours and is continuing,
C;laimen#-Secured Party shall have a1) of the rights and rem~dfes of8 secured party under the {aw then In eff~Gt
lid t}le StAte of I Inois,
14, any Annuity wNl bear the following legend:
,.Nd'CIC~"
"This annuity cnnttact has boon delivered to the possession of
for the soli
purpose of perfecting a Ilen and security interest of such person fn this oantract. 7'he above named
Is not the owner of, and has np awnet'ship rights in, this contrack and may nat anticipate, se11,
assign, pledge, encumber or otherwise use this contraG as any iorrn of coflat~ral, wlease contact
the issuer For further (ntam'tdtion."
15, In en#ering into #hip Agreement, Claimant-Securod Par#y represer~ that he or she has reli~tl on the advlcQ of hla
or her attorneys, who are the altameys of his or her choice, concerning the 1e9a1 and income tax aonsequan~es
of the Agreerr~ent; that the 1~erm~ of the Agreement have been completely read by and explained Yo
filair~ant~~oured F~arty; and that the terrns oP this AgreQment are fully understood and voruntarily accepted by
Claimant-Secured Par#y, As~}gnee-Debtor makes no represents#ions with respect to the tax oonsequenc.~s of
this Agreement or the adequacy of the secuMiy internst created Hereby.
16. Any notice to a party hereunder eh~ll be in vvriting and shat) be deemed to have been given when mailed to the
party's address of Bcord.
17. {fit, financing staternenR in re&pact of the security interest granted het+e}n shill ~e filed in any nonjudicial off{oe of
any federal, state, ar lo~al,govemmental authority,
PL QAR&P
v20'12
Assig
r: City of GhicB~a
~Y=
AutRo ~
Represen ativr~
Tftle;
Assggnem: Paolflc Life 8, Annuity ~ervlces,_~na
psslgnee: ~~cific Life &Annuity Services, Inc.
By.
By;
Authorised Repr~sentativ~
Title: --.....
----._.
claimant:
y:
Authorized RepresentaS~~e
Title
Approved as to Fom~r a~ld GonL~ent:
, A Minor
M.
C1al ant's Attorney
CfaYmant; The ~stat~ of LaQua~t Mcbonald, deceased

._.. .
pL QAR&P
v2U12
Addendum Na. 1
~escriptiar~ of perodic payments
PayeC:
TAx~iAgA k~plitcr
C3enefit(S):
1. Pcr~od Certnf~ A,nneity - $17,500,00 payable seen#-~nnunily,
$uarunteed for 5 yea~(s) which is l0
payments, beginning on 07/01/2018, With tha lAsi gust'anteed
pAgment on 0i/0 ~/2023.
2. R'CMiod CEN'Gtiin A,AIAIAAty - $500.00 payable monthly, guaranteed
for 5 years) which is 60 paymcats,
beginning on 07/b)./2018, with the l~,gt gua~raitteed pnyrnem ors 06/01/2
023.
3. Life Certain ,A,nnuity W Indexed - $1.,678.751'or life, pvyable
monthly, guaranteed for 37 yCar(s) wflic)n
is 44~ paym;ents, beginning on 07'I01/2023, with the last gu2~rantsed
p~j+ment ott 06/Ol/2.OG0. 7'he
A,~nuity Payment Amount may he sabject to az annual i~or~ase every
07!(l l beginning in ore yet~r a1~mr
the first paytnont and with ba baged on the 1ess~r ofthe index .Retur:~ during
the applicable Izdcx Toren
(first Index ~'cYm is Q5/I5/2023 to 05/15/2024) Red the oRp of
5"Jo, Ifthe lrrd~ Return during the
applicable tadex Term is negative, theta will be no increAsc in the
A,nhuity Pstytr~~tt Amoutrt.
Initials
Clpirr~ant-Secured Parry:
I 1 ~ U"
~ssignor(s):
ASsi~nee-Debtor:
Asslgnce-i~ebCor..
Attorney for Claimant-~ccured Party;
PL QAR&P
X2012
Qualified Assignment and Release Agreement

In Accordance With
Internal Revenue Code Section 130
"Claimant(s)": Tina Hunter
Assignor": Clty of ChlCago
"Settlement Agreement":

[Exact title of Settlement Agreement or Order]
"Governing Law": ~~~IIIOIS

"Assignee":
BHG STRUCTURED SETTLEMENTS, INC.
"Annuity Issuer": BERKSHIRE HATHAWAY LIFE INSURANCE COMPANY OF NEBRASKA

"Effective Date":
"Payees)":As shown in Addendum No. 1, Description of Periodic Payments
Annuity Contract No:

Assignment and Assumption; Release of
Assignor. Assignor hereby assigns to
Assignee, and Assignee hereby accepts and
assumes, all of Assignor's liability to make
the Periodic Payments. Each Claimant
hereby accepts and consents to such
assignment by Assignor and assumption by
Assignee. Effective on the Effective Date,
each Claimant hereby releases and
discharges Assignor from all liability to make
the Periodic Payments, including the failure
of Assignee to make any of the Periodic
Payments and/or Annuity Issuer to fund any
of the Periodic Payments for any reason
whatsoever.
This Qualified Assignment and Release

Agreement ("Agreement") is made and entered
into as of the Effective Date by and among the
undersigned parties with reference to the
following facts:
A. Claimants) and Assignor are parties to or
are otherwise subject to the abovereferenced Settlement Agreement under
which Assignor has liability to make certain
periodic payments to the designated
Payees) as specified in Addendum No. 1 of
this Agreement (the "Periodic Payments").
Where no Payees) other than Claimants)
are shown in Addendum No. 1, it is
understood that any references herein to
Payees) shall apply to Claimant(s).
2. Nature of Periodic Payments. The Periodic

Payments constitute:
B. Assignor and Assignee wish to effect a

"qualified assignment" within the meaning
and subject to the conditions of Section
130(c) of the Internal Revenue Code of
1986, as amended (the "Code").
i,
damages (other than punitive damages),

whether by suit or agreement, or
ii.
compensation
under
compensation act,
workers'
C. This Agreement will be effective contingent

upon Assignee's receipt of the full premium
to fund the Periodic Payments contained
herein.
on account of personal injury or sickness in

a case involving physical injury or physical
sickness, within the meaning of Sections
130(c) and 104(a) of the Code.
Now, therefore, in consideration of the

foregoing and for other good and valuable
consideration, the parties agree as follows:
3. Extent of Assignee's Liability. Assignee's

liability to make the Periodic Payments shall
be no greater than the liability of Assignor as
SS-1000 (12/2013)[S]
Page 1 of 6
of the Effective Date. Assignee is not

required to set aside specific assets to
secure the Periodic Payments. Claimant(s),
Payees) and Successor Payees) have no
rights against Assignee greater than those
of a general creditor. Assignee assumes no
liability other than the liability to make the
Periodic Payments. Assignee's liability to
liquidation or rehabilitation of Assignor.
4. Qualified Funding Asset. Assignee will
fund the Periodic Payments by purchasing
from Annuity Issuer a "qualified funding
asset," as defined in Section 130(d) of the
Code, in the form of an annuity contract (the
"Annuity") issued by Annuity Issuer and
providing for payments corresponding to the
Periodic Payments. Assignee shall be
designated as the owner of the Annuity. All
rights of legal ownership and control of the
Annuity shall (subject to paragraph 9 of this
Agreement) be and remain vested
exclusively in Assignee; provided, however,
that the Annuity shall be used by Assignee
to fund the Periodic Payments and shall at
all times be designated by Assignee on its
records as being taken into account, under
Section 130 of the Code, with respect to this
Agreement. Notwithstanding anything to the
contrary contained in this Agreement,
neither any Claimant, any Payee, nor any
Successor Payee (as defined in paragraph 8
of this Agreement) shall have any rights with
respect to the Annuity or the payments
thereunder that would cause any amount
attributable to the Annuity to be currently
includable in the recipient's income or would
otherwise affect the determination of when
any recipient is treated as having received
any payment for income tax purposes, or
would otherwise prevent this Agreement
from satisfying all of the conditions for a
"qualified assignment" within the meaning of
Section 130(c) of the Code.
5. Delivery of Payments. Assignee may
instruct Annuity Issuer to send payments
directly to Payee or Successor Payee, or to
deliver payments by electronic funds
transfer ("EFT") to an FDIC-insured
depository institution in the United States for
credit (directly or indirectly) to an insured
account in the name of such Payee or
Successor Payee. Such direction of
payments under the Annuity shall not be
deemed to afford Claimant, Payee or any
Successor Payee any rights of ownership or
control of the Annuity.
apprised of such Claimant's, Payee's or

Successor Payee's current mailing address
and telephone number and, if Payee or
account name and account number to which
the payments are to be credited.
Such
notices shall be in a form provided by
Annuity Issuer and must be received at least
thirty (30) days prior to the date payment is
due.
6. Discharge of Liability. Assignee's liability
to make each Periodic Payment to any
Payee or Successor Payee designated to
receive such payment shall be fully
discharged upon:
the mailing of a valid check on or before
address of record specified by Payee or
Successor Payee; or
ii.
the initiation of an EFT payment on or

the United Sates financial institution
account designated by Payee or
Successor Payee

receive a scheduled payment by check,
Payee or Successor Payee shall notify
Assignee. Upon receipt of such notification,
Assignee shall initiate a stop payment action
for such check and upon confirmation that
such check was not previously negotiated
shall promptly mail a replacement check; or
receive a scheduled EFT payment, Payee or
Successor Payee shall notify Assignee.
Upon receipt of such notification, Assignee
shall initiate a trace for such payment and
upon confirmation that such payment was
not credited to the account shall promptly
issue a replacement EFT payment.
7. Acceleration, Transfer of Payment
Rights. None of the Periodic Payments and
no rights to or interest in any of the Periodic
Payments (all of the foregoing being
hereinafter collectively referred to as
"Payment Rights") can be
Each Claimant, Payee and any Successor

Payee shall at all times keep Annuity Issuer
SS-1000 (12/2013)[S]
i.
Page 2 of 6
i.
Accelerated, deferred, increased or

decreased by any recipient of any of the
Periodic Payments; or
ii.
Sold, assigned, pledged, hypothecated

or otherwise transferred or encumbered,
or other transfer or encumbrance (any
such transaction being hereinafter

referred to as a "Transfer") has been
approved in advance in a "Qualified
Order" as defined in Section 5891(b)(2)
of the Code (a "Qualified Order") and
otherwise complies with applicable state
applicable state structured settlement
protection statute.
No Claimant, Payee or Successor Payee
shall have the power to effect any Transfer
of Payment Rights except as provided in
sub-paragraph (ii) above, and any other
purported Transfer of Payment Rights shall
be wholly void, invalid and unenforceable. If
Payment Rights under this Agreement
become the subject of a Transfer approved
in accordance with sub-paragraph (ii) above
the rights of any direct or indirect transferee
of such Transfer shall be subject to the
terms of this Agreement and any defense or
claim in recoupment arising hereunder.
8. Contingent Beneficiaries. Any, Periodic
Payments to be made after the death of any
Claimant, Payee or Successor Payee shall
be made to such party as shall have been
designated in, or in accordance with, the
Settlement Agreement or, if the Settlement
Agreement does not provide for such
designation, then to the party designated in
conformity with this paragraph 8. Any party
so designated is referred to in this
Agreement as a "Contingent Beneficiary." If
no Contingent Beneficiary is living at the
time of the death of a Claimant, Payee or
Successor Payee, payment shall be made to
the decedent's estate unless otherwise
provided in the Settlement Agreement. As
used in this Agreement the term "Successor
Payee" refers to a Contingent Beneficiary or
receive Periodic Payments following the
death of a Claimant, Payee or a Successor
Payee. Except where a designation has
been made in the Settlement Agreement, no
designation or change of designation of a
Contingent Beneficiary shall be effective
unless such designation or change (i) is
requested in a written request submitted to
Assignee in accordance with Assignee's
customary procedures for processing such
requests; and (ii) is confirmed by Assignee.
However, Assignee will not be liable for any
payment made prior to receipt of the request
or so soon thereafter that payment could not
reasonably be stopped.
Except for a
designation that is expressly identified in the
Settlement Agreement as irrevocable, any
designation of a Contingent Beneficiary shall
be deemed to be revocable; and no party
SS-1000 (12/2013)[S]
that is designated as a Contingent

Beneficiary (other than a party irrevocably
designated as a Contingent Beneficiary in
virtue of its designation as a Contingent
Beneficiary, be deemed to have any
Payments.
9. Termination of Settlement Agreement
Failure to Satisfy Section 130(c). If at any
time prior to completion of the Periodic
Payments, the Settlement Agreement is
declared terminated in a final, nonappealable order of a court of competent
jurisdiction (or in the case of a workers'
compensation settlement, a final order of the
applicable workers' compensation authority)
or if it is determined in any final order or
130(c) of the Code have not been satisfied
in connection with this Agreement: (i) the
assignment by Assignor to Assignee of the
liability to make the Periodic Payments and
Assignee's acceptance of such assignment
shall be of no force or effect; (ii) Assignee
shall be conclusively deemed to be acting as
the agent of Assignor; (iii) the Annuity shall
be owned by Assignor; (iv) in the event the
Settlement Agreement is not terminated,
Assignor shall retain the liability to make the
Periodic Payments; (v) Assignee shall have
no liability to make any Periodic Payments;
and (vi) the parties hereto agree to
cooperate in taking such actions as may be
necessary or appropriate to implement the
foregoing.
10. Governing Law; Binding Effect.
i.
ii.
This Agreement shall be governed by

and interpreted in accordance with the
internal laws of the state identified as
Governing Law above; provided,
subject to the laws of other states in
addition to the state designated above.
This Agreement shall be binding upon

the parties hereto and their respective
successors,
heirs,
executors,
administrators and permitted assigns,
including without limitation any party
asserting an interest in Payment Rights.
11. Advice, Comprehension of Agreement. In
entering into this Agreement, each Claimant
warrants, represents and agrees that
Claimant is solely relying on the attorneys
and advisors of such Claimants own
choosing, and not upon Assignor, Assignee
or their advisors, for advice regarding the
legal, government benefits and tax
Page 3 of 6
consequences of this Agreement. Each

Claimant further warrants, represents and
agrees that the terms of this Agreement
have been completely read by and
explained to such Claimant and are fully
understood and voluntarily accepted by such
Claimant. Furthermore, each Claimant
hereby releases and discharges Assignor,
Assignee, Annuity Issuer, their affiliates and
their respective employees and advisors
("Releasees") from any and ali claims,
nature whatsoever that such Claimant now
has or may have in the future against such
Releasees (i) with respect to the present
and future taxation of this Agreement or the
Periodic Payments; or (ii) the impact that
this Agreement or the Periodic Payments
may have on Claimant's eligibility for, and
the quantum of, any governmental benefit
payments.
SS-1000 (12/2013)[S]
12. Future Cooperation. All parties agree to

cooperate fully and to execute any and all
supplementary documents and take all
additional actions, which are not inconsistent
Assignment and Release Agreement.
Pursuant to its obligations under this
paragraph 12, and without limitation,
Assignor shall promptly provide Assignee
with copies of any required court approval
with respect to fhe" underlying settlement
and executed copies of all required
settlement documents.
13. Description of Periodic Payments. The
Periodic Payments are as set forth in
attached Addendum No. 1 which is hereby
incorporated in and made a part of this
Agreement.
Page 4 of 6
In the event of any conflict befinreen this Agreement and the Settlement Agreement with respect to
Assignor: City of Chicago
By: J
Title:
y,
~~,~/y~/~
Assignee:
By:
Title:
Claimants) or Payee(s):
By:
Tina Hunter
Attorney for CI
Ap~ro
a
(s):
nd Content
By:
SS-1000(12/2013)[S]
Page 5 of 6
Addendum No. 1
Payee:
Tina Hunter
$2,821.00 per month for the lifetime of Tina Hunter, guaranteed 20 years, beginning on
October 25, 2015, The final guaranteed payment will be due on September 25, 2035.
INITIALS
Assignor:
Assignee:
Claimant or Payee:
SS-1000(12/2013)[S]
Page 6 of 6
TN THE CIRCUIT COURT OF COOK COUNTY,ILLINOIS

COUNTY DEPARTMENT PROBATE DIVISION
ESTATE OF LAQUAN MCDONALD,
)
Case No: 14 P 7092
Deceased
)
C~'~
This matter coming to be heard on the Amended Petition to Approve Settlement, the
Minor's Settlement, Qualified Structured Annuity, and the Attorney's Fees, and the Court being
advised in the premises:
THE COURT FINDS:
1.
The settlement of $5,000,000.00 is fair and reasonable.
WHEREFORE,IT IS HEREBY ORDERED:

1.
The minor's portion of 55% of the settlement amount in the amount of
$2,750,000.00 is approved.
2.
That the legal fees of the Law Offices of Michael D. Robbins and Jeffrey J.
Neslund in the amount of 1/3rd of the minor's portion or $916,667.00 is approved. No other
deductions from the minor's portion shall be allowed.
3.
Of the net amount remaining, $20,000.00 shall be paid to Bruce Bornstein as the
Guardian ofthe Estate of
, a minor.
4,
As to
, the minor, the remainder of $1,813,333.00,. will be used to
acquire two qualified structured annuities for the sole benefit of
, a minor and the
following future Periodic Payments will be made payable as indicated below, said payments to
be provided through a qualified assignment to the Assignees, within the meaning of Section
130(c) of the Internal Revenue Code of 1986, as amended, and the issuance of annuity policies
from the Annuity Issuers, all as more fully described and in accordance with the terms and
conditions of the Release and Settlement Agreement, which has been approved by the Court:
A.
As to
, Structured Settlement/Annuity Funding: Nine
Hundred Sixteen Thousand, Ninety and no/100 Dollars ($916,090.00) payable to Pacific Life &
Annuity Services, Inc. in order to fund the future periodic payments set forth below:
Page 1 of4
Payee:
Assignee:
Annuity Issuer:
Pacific Life &Annuity Services, Inc.

Pacific Life Insurance Company

$17,500.00 payable semi-annually, guaranteed 5 years, beginning on July 1, 2018
(10 payments total).
The final guaranteed payment will be due on January 1, 2023.
, guaranteed 37 years, beginning
on July 1, 2023, with the last guaranteed payment on June 1, 2060. The Annuity Payment
Amount may be subject to' an annual increase every July 1 S` beginning one (1) year after
the first payment and will be based on the lesser of the Index Return during the applicable'
Index Term (first Index Term May 15, 2023 through May 15, 2024)and the cap of5%. If
the Index Return during the applicable Index Term is negative, there will be no increase
in the annuity payment amount.
B.
As to
, Structured SettlemendAnnuity Funding: Eight
Hundred Ninety Seven Thousand, Two Hundred
Three and no/100 Dollars ($897,243.00)
payable to BHG Structured settlements, Inc. in order to fund the future periodic payments set
forth below:
Forty
Payee:
Assignee:
Annuity Issuer:

Berkshire Hathaway Life Insurance Company ofNebraska

, guaranteed 37 years, beginning
on July 1, 2023, increasing at 3% compounded annually. The final guaranteed payment
will be due on June 1, 2060.
$75,000.00 guaranteed lump sum, payable on March 28,2040.
$125,000.00 guaranteed lump sum, payable on March 28,2050.
$225,000.00 guaranteed ]ump sum, payable on March 28, 2060.
5.
Tina Hunter's portion of 45% of the settlement amount in the amount of
$2,250,000.00 is approved.
Page 2 of4
6.
That the legal fees of Law Offices of Michael D. Robbins and Jeffrey J. Neslund
in the amount of40% of Tina Hunter's portion, in the amount of$900,000.00, is approved.
7.
As to Tina Hunter, $800,000.00 will be used to acquire a qualified structured
annuity for the sole benefit of Tina Hunter and the following future Periodic Payments will be
made payable as indicated below, said payments to be provided through a qualified assignment
to the Assignees, within the meaning of Section 130(c) of the Internal Revenue Code of 1986, as
amended, and the issuance of annuity policies from the Annuity Issuers, all as more fully
described and in accordance with the terms and conditions of the Release and Settlement
Agreement, which has been approved by the Court:
Payee:
Assignee:
Annuity Issuer:
Tina Hunter
Berkshire Hathaway Life Insurance Company of Nebraska
$2,821.00 per month for the lifetime of Tina Hunter, guaranteed 20 years, beginning on
October 25,2015. The final guaranteed payment will be due on September 25, 2035.
8.
That the legal fees and costs of the Law Office of Edward Y. Lau shall be borne
by and paid by the Law Offices of Michael D. Robbins and Jeffrey J. Neslund.
9.
That all costs of the administration of this decedent's estate, case number 14 P
7092, shall be borne by and paid by the Law Offices of Michael D. Robbins and Jeffrey. J.
Neslund.
10.
That the City of Chicago is directed to make the following payments:
A.
Two Million Three Hundred Eighty Six Thousand Six Hundred Sixty
Seven and 00/100 Dollars ($2,386,667.00) payable to Tina Hunter, asIndependent Administrator
of the Estate of LaQuan McDonald, and their attorneys, the Law Office of Jeffrey J. Neslund and
Michael D. Robbins &Associates;
B.
Nine Hundred Sixteen Thousand, Ninety and no/100 Dollars
($916,090.00) payable to Pacific Life &Annuity Services, Inc. in order to fund the future
;
periodic payments as set forth above for
C.
Eight Hundred Ninety Seven Thousand, Two Hundred Forty Three and
no/100 Dollars ($897,243.00) payable to BHG Structured Settlements, Inc. in order to fund the
; and
future periodic payments as set forth above for
Page 3 of4
D.
Eight Hundred Thousand and no/100 Dollars ($800,000.00) payable to
BHG Structured Settlements, Inc. in order to fund the future periodic payments set forth above
for Tina Hunter.
ENTERED:
Judge
~UG 2 ~ 201a
Assoc. Jad'~~Sus~~ ~,,Isman 1 T47
Attorney No: 11228

Law Office of Edward Y. Lau
Attorney for Administrator -Tina Hunter
30 North LaSalle Street; Suite 3200
(312)346-1155
Page 4 of4
Judge's no.
From:
Sent:
To:
Cc:
Subject:
Quinn, Kelley
Friday, September 04, 2015 6:48 PM
Spielfogel, David
Rountree, Janey;Mitchell, Eileen;Collins, Adam;Patton, Stephen
Re: Confidential - police issue
Follow Up Flag:
Flag Status:
Follow up
Completed
Agree.Thanksfortheheadsup.
OnSep4,2015,at6:11PM,Spielfogel,David<[email protected]>wrote:
Assumingtheseareallthefacts,Iagreewestaywithourplan.

Sent: Friday, September 04, 2015 6:10 PM
To: Spielfogel, David; Mitchell, Eileen; Collins, Adam; Quinn, Kelley
Cc: Patton, Stephen
Subject: Confidential - police issue
Dearall,
NextFriday,Sept.11,thelawdepartmenthasastatushearingintheFOIAcaserelatedtotheshooting
ofLaquanMcDonald(17yearoldwithaknife/officerunderfederalinvestigation).Plaintiffshavesued
thecitytotrytoforceustoreleasethevideo.WehavenotreleasedthevideobecausetheUS
Attorneysofficeconvenedafederalgrandjuryandtheshootingisundercriminalinvestigation.Thelast
timewediscussedthisissue,weallagreedthattheCitywouldproactivelyreleasethisvideo,alongwith
theresultsoftheIPRAinvestigation,assoonasthegrandjuryisfinished.Ifthatisstilltheplan,Iwould
liketogivethelawdepartmentthegreenlighttosaythatinthestatushearingnextFriday.Clearly
statingthatwewillreleasethevideocouldhelpmootthelitigation.Ithinkwehavethereleasethe
video,andseemsbettertogetthisallofthewayatthemomentweexpectanindictment.Evenifthe
grandjurydoesnothanddowntheindictment,wewillprobablybeforcedtoreleasethevideobythe
courtatthatpointanyway.IncludingStevehereforanyadditionalcounsel.
AdamandKelleyalsowantedyoutobegenerallyawarethatthiscomingsincethepressmaycoverthe
statushearingnextFriday.
Janey
1
From:
Sent:
To:
Subject:
Dunn, James
Wednesday, September 09, 2015 10:15 AM
McGregor, Lorraine;Platt, Thomas;Fuentes, Angelina;Harrison, Gwendolyn
RE: LaQuan McDonald
Pleasedonotcallthecomptroller.
From: McGregor, Lorraine

Sent: Wednesday, September 09, 2015 10:03 AM
To: Platt, Thomas; Dunn, James; Fuentes, Angelina; Harrison, Gwendolyn
Subject: RE: LaQuan McDonald
Isentthepaperworkforward.IwillcheckwiththeComptrollersOfficetofindoutiftheywillhavethefundstopaythe
checkson9/11.
From: Platt, Thomas

Sent: Tuesday, September 08, 2015 1:20 PM
To: McGregor, Lorraine; Dunn, James; Fuentes, Angelina; Harrison, Gwendolyn
Subject: LaQuan McDonald
Isscheduledforpayment(4checkstotaling$5million)onSept.11.Isthisconfirmedwithcomptroller?
ThomasJ.Platt
3127444833
From:
Sent:
To:
Cc:
Subject:
Real, Elizabeth <[email protected]>

Platt, Thomas;McGregor, Lorraine;Dunn, James
Goodmann, Daniel
Hunter (EO LaQuan McDonald) - No. 14 P 7092
Goodafternoon,
Iamwritingtoconfirmthatwereceivedthefollowingpremiumchecks,whichfundstheagreeduponperiodicpayments
forTinaHunterand
.
1. $800,000.00toBHGStructuredSettlements,Inc.forTinaHunter;
2. $897,243.00toBHGStructuredSettlements,Inc.for
3. $916,090.00toPacificLife&AnnuityServices,Inc.for
The final documents for the Hunters structured settlement have been submitted to Berkshire Hathaway Life Insurance
CompanyofNebraksaandPacificLifeInsuranceCompanyforapprovalandexecutionbytheAssignees.Oncewereceive
copies of the annuity policies and fully executed qualified assignments, we will email copies to you for your respective
files.Copieswillalsobeforwardedtotheplaintiffsstructuredsettlementrepresentativefordeliverytotheplaintiffsand
theirattorney.
Inthemeantime,ifyouhaveanyquestions,pleasedonothesitatetocontactme.
Thankyouverymuchforyourcooperation.
Liz
ElizabethReal,CSSC
AccountManager
MesirowFinancial
353NorthClarkStreet
t877.772.4436
f312.595.4440
[email protected]
Thiscommunicationmaycontainprivilegedand/orconfidentialinformation.Itisintendedsolelyfortheuseoftheaddressee.Ifyou
arenottheintendedrecipient,youarestrictlyprohibitedfromdisclosing,copying,distributingorusinganyofthisinformation.Ifyou
receivedthiscommunicationinerror,pleasecontactthesenderimmediatelyanddestroythematerialinitsentirety,whether
electronicorhardcopy.Confidential,proprietaryortimesensitivecommunicationsshouldnotbetransmittedviatheInternet,as
therecanbenoassuranceofactualortimelydelivery,receiptand/orconfidentiality.Thisisnotanoffer,orsolicitationofanyofferto
buyorsellanysecurity,investmentorotherproduct.

1
From:
Sent:
To:
Subject:
Price
Roussell; James M.; Guglielmi; Anthony
Fwd: Brandon Smith v. CPD FOIA lawsuit -preservation request
Communication)
(Attorney-Client
FYI
Ralph Price
From: "Peters, Lynda" <Lynda.Peters@cityofchica~o.or~>
Date: September 11, 2015 at 5:17:24 PM CDT
To:"Wade, Landon J." <Landon.Wade@chica~opolice.or~>,"Bazarek, William"
<William.Bazarek@chica~opolice.or~>,"Rasmas, Chloe" <Chloe.Rasmas@citvofchica~o.org>,
"Muellenbach, Eric" <Eric.Muellenbach(c~iprachica~o.or~>, "Platt, Thomas"
<[email protected]~>
Cc: "Ritter, Amber <Amber.Ritter@citYofchica~o.or~>, "Rocks, Pat" <[email protected]>,
"Price, Ralph M." <Ralph.Price@chica~opolice.or~>,"Breymaier, Shannon"

<Shannon.Brevmaier@cityofchica~o.or~>,"Franklin, Liza" <Liza.Franklin@cityofchica~o.or~>
Subject: Brandon Smith v. CPD FOIA lawsuit -preservation request(Attorney-Client Communication)
Hi everyone
We just received the following preservation request from Matt Topic on the FOIA lawsuit involving the
Laquan McDonald shooting:
we ask that CPD, the Mayor's Office, and every other City of Chicago entity preserve all records
related to Smith's request, other FOIA requests for the video, the investigations related to the
video, the potential release of the video, attempts to delay the release of the video, the
anticipated impact that release of the video would have, and anything else that maybe relevant to
Smith`s claim that CPD has willfully and intentionally violated FOIA or otherwise acted in bad
faith.
Please take the appropriate steps to preserve whatever of the described items your Department has in its
possession.
Thank you,
Lynda
Lynda A. Peters
iity Prosecutor
Legal Information, Investigations &Prosecutions Division
Chicago, IL 60602
312-744-2816
This e-mail, and any attachments thereto, is intended only for use by the addressees) named
intended recipient ofthis e-mail(or the person responsible for delivering this document to the
copying ofthis e-mail, and any attachment thereto, is strictly prohibited. If you have received
From:
Sent:
To:
Subject:
Attachments:
Rountree, Janey
Monday, September 28, 2015 11:10 AM
Adam Collins ([email protected])
Follow Up Flag:
Flag Status:
Follow up
Completed
Illworkonupdatingthis,ifthatmakessense.
From:
Sent:
To:
Subject:
Attachments:
Holden, John
Tuesday, October 06, 2015 9:38 AM
Notz, Jane
Budget Q&A
Budget 2016 QA Draft 1.doc
From:
Sent:
To:
Henry, Vance
Sunday, October 11, 2015 5:15 PM
Bennett, Kenneth;Rountree, Janey
Follow Up Flag:
Flag Status:
Follow up
Completed
HeyTeam,
Overtheweekend,Iwasinformedbysomeofourfriendsandalliesthatstreetchatterandorganizinghasincreased
considerablyaroundthependingoutcomesoftheDet.DanteServineandLaquanMcDonaldcases,respectively.
Thatsaid,andgiventhenationalclimatearoundpolicemisconduct,andmorespecifically,recenttensionsatthelast
CPDBoardmtg.'s,I'drespectfullyrecommendwemeetinternallyanddiscussproactivecommunityengagementsteps,
topreventanycommunitydisorder.
Asyouraware,giventheclimate,we'dbesmarttoacttimelyandstrategically,inadvanceofanyfurtherpublic
decisions,intherespectivecases.
IthinkitwouldbehelpfultoincludeLaurieLightfoot,asBoardChairofCPDandalsoRet.Supt.Hillardbecauseofhis
streetcreditabilityandhissubjectmatterexpertise.
Plsletmeknowyourthoughts.
Respectfully,
________________________________
Subject:
Location:
Pending police dept. misconduct

Ken's office
Start:
End:
Show Time As:
Wed 10/14/2015 4:15 PM

Wed 10/14/2015 4:45 PM
Tentative
Recurrence:
(none)
Meeting Status:
Not yet responded
Organizer:
Required Attendees:
Collier, Laurie
Bennett, Kenneth ([email protected]); Henry, Vance; Rountree, Janey
InformationprovidedbyVanceHenry
DanteServin
LaquanMcDonaldcamerafootage
incidentthattookplaceonKingDr.camerafootage
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
From:
Sent:
To:
Cc:
Subject:
Attachments:
Platt, Thomas
Tuesday, October 13, 2015 5:43 PM
Nikoleta Lamprinakos
McGregor, Lorraine
RE: Hale v. City of Chicago/Release and Settlement Agreement
COMPTROLLER LETTER REQUEST FORM (2).doc
PleasefilloutthecomptrollerrequestformforLorraineandshewillpreparetheletter.Thecheckisissued60daysfrom
thedateofdismissal.
From: Nikoleta Lamprinakos [mailto:[email protected]]

Sent: Tuesday, October 13, 2015 3:44 PM
To: Platt, Thomas
Subject: RE: Hale v. City of Chicago/Release and Settlement Agreement
Mr.Platt,
Attachedpleasefindthestipulationtodismissandthedismissalorder.Pleaseletmeknowwhenthesettlementcheck
hasbeenissued.
Thanks
Niki
NikoletaLamprinakos
Attorney
RobbinsSchwartz
55W.MonroeSt.,Suite800
p:312.332.7760f:312.332.7768
[email protected]
Thismessageisconfidential.Thismessagemayalsobeprivilegedorprotectedbyworkproductimmunityorotherlawsandregulations.Ifyouhavereceiveditby
mistake,pleaseresendthiscommunicationtothesenderanddeleteitfromyoursystemwithoutcopyingitordisclosingitscontentstoanyone.
Sent:Tuesday,September29,201512:39PM
To:NikoletaLamprinakos<[email protected]>
Subject:RE:Halev.CityofChicago/ReleaseandSettlementAgreement
Thankyouforcollectingthedocsfromprotorder.Youmayshredthematyouroffice.Astothesettlementagreement,
onceyougivemeareleasesignedbyyou(theattacheddoesnothaveStevessignature)andyouprovideastipand
dismissalorder,wewillorderthecomptrollerletter.Paymentis60daysfromthedateofthecasedismissalorder.

Sent: Tuesday, September 29, 2015 12:14 PM
1
To: Platt, Thomas

Subject: RE: Hale v. City of Chicago/Release and Settlement Agreement
Mr.Platt,
Attachedpleasefindtheexecutedreleaseandsettlementagreement.Approximatelyhowlongwillittaketogetthe
settlementdraft.
PlaintiffscounselhasalsoreturnedallthedocumentsthatwerecoveredundertheProtectiveOrdertoour
office.Wouldyoulikeourofficetoshredsaiddocumentsorwouldyoupreferthatwereturnthemtoyou?Pleaselet
meknow.
Thanks
Niki
NikoletaLamprinakos
Attorney
RobbinsSchwartz
p:312.332.7760f:312.332.7768
[email protected]
Sent:Thursday,September10,20152:08PM
To:NikoletaLamprinakos<[email protected]>
Subject:RE:Halev.CityofChicago/ReleaseandSettlementAgreement
Pleaseomitpar.13oftherelease.Thatisnotoneofourstandardparagraphs.Samematerialiscoveredinpar.8.

Sent: Thursday, September 10, 2015 10:53 AM
To: Platt, Thomas
Cc: Stephen Miller
Subject: Hale v. City of Chicago/Release and Settlement Agreement
Mr.Platt,
AttachedpleasefindourproposedsettlementagreementinreferencetotheHalematter.
Pleasereviewandletmeknowifyouhaveanycomments,correctionsoradditions.
Thanks.
Niki

NikoletaLamprinakos
Attorney
RobbinsSchwartz
p:312.332.7760f:312.332.7768
[email protected]

PLEASE FILL OUT COMPLETELY
FCRL Attorney_Thomas J Platt____Sept 1, 2015____________

Case Name & Number:
In the Matter of the Estate of LaQuan McDonald also known as
LeQuan McDonald, deceased, by its Independent Administrator, Tina Hunter 14 P 7092
Date of Incident: _October 20, 2014
__x__Settlement
Judge ______Cook County Probate Judge Susan Cole______________
Liens ____ Yes ____ No (If so, provide below)
Amount: $2,386,667.00
1099 Reporting __x__ Yes ____ No
Plaintiff(s) Estate of LaQuan McDonald by its independent administrator, Tina Hunter

Male _x___ Female ____
Plaintiffs Attorneys Firm Name:
Jeffrey Neslund
Law Offices of Jeffrey J. Neslund
20 N. Wacker Dr. Suite 3750
Chicago Illinois 60606
Michael D. Robbins
Michael D. Robbins and Associates
20 N. Wacker Dr. Suite 3710
END FILES TO STORAGE
_X_Yes __No
_________________Paralegal
For Settlements
_x___ Signed/dated settlement documents
__x City Council Ordinance
____ DEPOSITIONS (Must provide-if available)
GIVE DEPOSITIONS TO PARALEGAL FOR
SCANNING. GIVE COPY OF DEPOSITIONS TO
AAD
Verdicts/Judgments
_____ Court-entered judgments/verdicts
_____ Interest added (effective date of
interest _____________________)
Where are depositions located in Shared
Drive?____________________________
Please indicate any special instructions (INCLUDIING lien info.) below:
From:
Sent:
To:
Cc:
Subject:
Ewing, Clothilde
Tuesday, October 20, 2015 8:47 AM
Collins, Adam
Quinn, Kelley
Fw: (NEWS) SUN TIMES: Mitchell: Mistrust of cops hurts communities
Follow Up Flag:
Flag Status:
Follow up
Completed
SorryifImissedit,butdidyoucirculatethefetalnarrativeyesterday?
From: NewsClips <[email protected]>
Sent: Tuesday, October 20, 2015 8:23 AM
Subject: (NEWS) SUN TIMES: Mitchell: Mistrust of cops hurts communities
Mitchell:Mistrustofcopshurtscommunities
SUNTIMES//MaryMitchell//October19,2015
Imthefirsttoarguethataroguecopshouldbetakenoffthestreetjustasquick,ifnotquicker,than
criminals.
Afterall,policeofficersareheldtoahigherstandardbecausetheyarearmedandhavetheauthoritytodetain
citizens.
Ascitizens,wehavetherighttodemandcompensationwhenpoliceofficersviolatethepublictrust.
Butwearelosingsightofwhatshouldbeourultimategoal:reducingthegunviolence.
Sofarthisyear,Chicagopolicehaveseizedmorethan5,500illegalguns.
Andthegundeathshaveincludedagrandfatherunloadinggroceriesinfrontofhishomeandamotherand
grandmothergunneddownontheirdoorsteps.
Yetprosecutorssayitistoughertogetconvictionsonguncasesbecauseofagrowingmistrustof
police,accordingtoareportbyChicagoSunTimesreportersMickDumkeandFrankMain.
EvenMayorRahmEmanuelisblamingthepoliceshootingsofAfricanAmericansnationallyforChicagosspike
ingunviolence,arguingthatpoliceofficersareshyingawayfromsituationsthatcouldresultinalawsuit.
Wehaveallowedourpolicedepartmenttogetfetal,anditshavingadirectconsequence.Theyhavepulled
backfromtheabilitytointerdict...theydontwanttobeanewsstorythemselves,Emanuelsaidina
meetingwithAttorneyGeneralLorettaLynchlastweek.
Chicagohasitsownproblemswithrespecttopolicemisconduct.
Recently,theIndependentPoliceReviewAuthorityrecommendedthatSupt.GarryMcCarthyfiredetective
DanteServinforfatallyshootingRekiaBoydin2012.
Servin,whowasoffdutyatthetime,firedintoacrowd,killingBoyd.Ajudgeacquittedhimofinvoluntary
manslaughter,arguingthecasewaschargedincorrectly.
Inanothercontroversialpoliceshooting,theFBIisinvestigatingthefatalshootingof17yearoldLaquan
McDonald.McDonaldwasshot16timesbyaChicagopoliceofficer.Thecityagreedtoamultimilliondollar
settlementbeforelawyersforMcDonaldsfamilyevenfiledalawsuit.
SoEmanuelhadtolooknofartherthanhisownbackyardforexamplesofcasesthatunderminethetrust
betweenpoliceofficersandcitizens.
1
Yetthevastmajorityofpoliceofficersarestillriskingtheirliveseverydaybypursuingarmedcriminalsin
dangerousneighborhoods.
Policearenotinafetalpositionnotwhenofficershavemade250,000stopandfriskarrests,saidTio
Hardiman,theformerheadofCeaseFireIllinois,andnowCEOofViolenceInterrupters,anonforprofitanti
violenceorganization.
RahmkeepsmakingexcusesforSupt.GarryMcCarthy.Theneedlehasnotmovedwhenitcomestoreducing
homicides,Hardimanpointedout.
Whenitcomestopolicing,AfricanAmericancommunitieshavetostrikeabalancebetweenprotecting
ourselvesfromabusivecopsandprotectingourfamiliesfromwantonshooters.
Yes,theFourthAmendmentbarspoliceofficersfromconductingsearcheswithoutareasonablesuspicion.
Butwhenshootersarefiringgunsfrombicyclesinthemiddleoftheafternoon,whatisreasonable?
Weknowwhattodowhenindividualpoliceofficersmistreatus.Butwedontknowhowtogetthegunsoff
thestreet.
Forthat,wehavetodependonChicagopoliceofficers,andthoseofficersarenotRobocops.
Thetruthis,incommunitiesundersiegefromgunviolence,mistrustisthebiggestenemy.
Ifwereallywantsafercommunities,wehavetogetoutofthewayandtrustpoliceofficerstodotheirjobs.
From:
Sent:
To:
Subject:
Guglielmi, Anthony <[email protected]>

Monday, October 26, 2015 9:30 AM
Collins, Adam;Rountree, Janey
RE: Channel 5 News request
Follow Up Flag:
Flag Status:
Follow up
Completed
Done. We chatted about this Friday and I called him back
--Anthony Guglielmi
Phone: 312-745-6110
Cell: 312-545-3251
@ajguglielmi | @Chicago_Police
-------- Original message -------From: "Collins, Adam" <[email protected]>

Date: 10/26/2015 9:19 AM (GMT-06:00)
To: "Guglielmi, Anthony" <[email protected]>, "Rountree, Janey"
<[email protected]>
Subject: RE: Channel 5 News request
+Janey
Ithinkwehavetosaysomethinglike:Asyouknow,thismatterisunderinvestigationbythefederalauthoritiesandasa
resultwecannotdiscussitfurther.

Sent: Thursday, October 22, 2015 4:53 PM
To: Collins, Adam
Subject: Fwd: Channel 5 News request
Declining this, looks like it's a documentary. We can give a written statement
--Anthony Guglielmi
Director, Communications / News Affairs
Phone: 312-745-6110
Cell:
-------- Original message -------From: [email protected]

Date: 10/22/2015 2:23 PM (GMT-05:00)
To: "Guglielmi, Anthony" <[email protected]>
Cc: [email protected], News Affairs <[email protected]>
Subject: Channel 5 News request
Anthony,
My name is Don Moseley and I work with Carol Marin at Channel 5. We have done a series of stories in the last 6 months
regarding the police involved shooting of 17-year old LaQuan McDonald. We are working on a new stroy regarding police
dash cameras. It is our understanding that on the night of the shooting (October 20, 2014) 5 police Tahoe's were on the
scene but only two videos were produced out of the five vehicles. We have questions about why there was no video from
the other three?
Were they equipped with cameras? By October 2014 we are led to believe that all such units were outfitted with dash
cameras. Plus we have interviewed defense lawyers who state that it is the exception rather than the rule that the
cameras either: don't work or are switched off or do not engage. We would like to interview on camera someone from the
Department who can address these questions.
Don Moseley
NBC5 News
773-793-1566
www.carolmarin.com
From:
Sent:
To:
Cc:
Subject:
Peters, Lynda
Wednesday, October 28, 2015 5:58 PM
Platt, Thomas;Franklin, Liza;Patton, Stephen;Rocks, Pat;Notz, Jane
Ritter, Amber;Stepien, Michael C. (Chicago) ([email protected])
McDonald news article
http://www.nbcchicago.com/news/local/Judge-to-Rule-on-Video-of-Chicago-Police-Shooting-Teen-16-Times338084772.html
A Cook County judge will rule Nov. 18 on a motion to release police dash-cam video showing the fatal shooting of a
Chicago teen last year.
LaQuan McDonald, who was 17 at the time of the incident, was shot 16 times by a Chicago police officer on Oct. 20,
2014, prompting investigations by the FBI, the Cook County State's Attorney's Office and the Independent Police Review
Authority (IPRA).
Chancery Court Judge Franklin Valderrama heard arguments by Patrick Rocks, representing the Chicago Police
Department, who argued the release of the video would harm the ongoing investigation by IPRA and plaintiff's attorney
Matt Topic, who said the release "is an issue of significant public interest."
On the night that McDonald was killed, police responded to a call of a man with a knife. Attorneys for the McDonald family
said the 17-year-old was not posing a danger at the time of the shooting and was walking away when the officer, who has
not been publicly named, opened fire.
The City of Chicago quickly moved to settle even before a lawsuit was filed. The $5 million settlement was announced in
April.
Both sides in court acknowledged the existence of a federal grand jury and FBI probe, though there was no motion from
the U.S. Attorney's office or the FBI relating to whether to release the video.
Lynda A. Peters
City Prosecutor
Legal Information, Investigations & Prosecutions Division
Chicago, IL 60602
312-744-2816
From:
Sent:
To:
Subject:
Patton, Stephen
Saturday, October 31, 2015 7:29 AM
McCaffrey, Bill
Re: Video footage request.
ConsultwithAmberandLynda,butIsuspectwewillmakethesameresponse.
From:McCaffrey,Bill
Sent:Friday,October30,20155:56:17PM
To:Patton,Stephen
Subject:FW:Videofootagerequest.
FYIthisjustarrived.WecanprovidethesamerepliesaspreviousFOIAs,unlessyouhavedifferentthoughts.

Sent: Friday, October 30, 2015 5:47 PM
To: LAWFOIA
Subject: Video footage request.
Importance: High
Goodafternoon,
ItsJeremyGornerfromtheChicagoTribune.
ImfilingarequestundertheIllinoisFreedomofInformationActforanyandallvideofootagepertainingtotheOctober
20,2014deathofLaquanMcDonald,17(D.O.B.09/24/1997).HewasshotandkilledbyaChicagopoliceofficernear
41stStreetandPulaskiRoad.
Imlookingforanyandallvideofootagethatwasrecoveredasevidenceforthecase.Thisincludes,butisnotlimitedto,
squadcardashboardcameravideothatmayormaynotincludeaudio,anyfootagefromPODcameras,etc.
Ifinyourviewanyoftheaboverecordscontaininformationyoudeemtobeexemptfromdisclosurepleaseredact
thatportionoftherecordandprovidetheremainder,specifyingtheprecisenatureoftheredactedinformationand
thespecificexemptiononwhichyouwouldrelyintheeventIwastoaskforitsdisclosure.
Thanks!
JeremyGorner
ReporterChicagoTribune
O:3122224569
C:3129123967
1

Part 2 - May Through October

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From:

Rottner, Jennifer E. <[email protected]>

FYI for you both

Gentlemen, FYI below...

FYI for you both

Rottner, Jennifer E. <[email protected]>

P.O. Thomas Haughey

From: Holden, John

I think we handled this right

Rottner, Jennifer E. <[email protected]>

Just FYI-this is going out.

From: Haughey, Thomas R.

P.O. Thomas Haughey

Department of Police City of Chicago

NOTICE OF RESPONSE TO FOIA REQUEST

P.O. Thomas Haughey

From: Haughey, Thomas R.

P.O. Thomas Haughey

FYf, this is going out today

P.O. Thomas Haughey

From: Haughey, Thomas R.

P.O. Thomas Haughey

Gentlemen, Please see below...

From: Breymaier, Shannon

I nominate you since you have the info

From: Franklin, Liza

From: Collins, Adam

From: Breymaier, Shannon

From: Breymaier, Shannon

From: Collins, Adam

From: Breymaier, Shannon

I nominate you since you have the info

From: Franklin, Liza

Ando, Scott <[email protected]>

Theres nothing attached at the bottom.

From: Collins, Adam [mailto:[email protected]]

From: Maloney, Martin [mailto:[email protected]]

From: Holden, John [mailto:[email protected]]

From: Maloney, Martin [mailto:[email protected]]

From: Collins, Adam [mailto:[email protected]]

From: Maloney, Martin [mailto:[email protected]]

From: Collins, Adam [mailto:[email protected]]

From: Breymaier, Shannon

From: Escalante, John J.

"Maloney, Martin" <Martin.Maloney~c~chica~opolice.org> wrote:

From: Escalante, John J.

"Maloney, Martin" <Martin.Maloney~a

From: dmose92480@aoLcom [mailto:[email protected]]

From: Carol Marin [mailto:carolmarinCo)aol.com]

-----Original Message----From: Don Moseley <dmose92480(a~aol.com>

From: Maloney, Martin

From: dmose92480Cc~aol.com [mailto:[email protected]]

DePaul Documentary Project

-----Original Message----From: Maloney, Martin <Martin.Maloney(a~chicagopolice.orq>

From: Carol Marin [mailto:[email protected]]

Short answer yes, it is nonsense.

From: Maloney, Martin

Subject: FW: A couple of specifics about tonight's story

From: [email protected] [mailto:[email protected]]

-----Original Message----From: Maloney, Martin <Martin.Maloney(a~chicagopolice.org>

From: Carol Marin [mailto:carolmarinCa~aol.com]

-----Original Message----From: Don Moseley <dmose92480(c~aol.com>