IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

ERIC CAINE, ) 

 ) 

Plaintiff, ) 

 ) 

v. ) Case No. 11-CV-08996 

 ) 

JON BURGE, JAMES PIENTA, ) Honorable Judge Durkin 

RAYMOND MADIGAN, WILLIAM ) 

MARLEY, WILLIAM PEDERSON, ) 

DANIEL MCWEENY, CITY OF ) 

CHICAGO and UNIDENTIFIED ) 

EMPLOYEES OF THE CITY OF ) 

CHICAGO, ) JURY TRIAL DEMANDED 

 ) 

Defendants. ) 

PLAINTIFF’S EXHIBITS IN SUPPORT OF 

LOCAL RULE 56.1 STATEMENT OF ADDITIONAL FACTS 

 

Exhibit 1: Caine Certificate of Innocence 

 

 Exhibit 2: Eric Caine Deposition Dated February 7, 2013 

Exhibit 3: Record of Proceedings, People v. Patterson, September 25, 1989, 

 Eric Caine Trial Testimony 

Exhibit 4: Order Granting Certificate of Innocence to Aaron Patterson 

Exhibit 5: Aaron Patterson Deposition, Patterson v. Burge, 

 Dated December 8, 2005 

Exhibit 6: Supplementary Report Dated April 21, 1986 

Exhibit 7: Supplementary Report Dated May 7, 1986 

Exhibit 8: Jon Burge Deposition Dated December 18, 2012 

Exhibit 9: Raymond Madigan Deposition Dated May 12, 2012 

Exhibit 10: Daniel McWeeny Deposition Dated August 8, 2012 

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Exhibit 11: William Pedersen Deposition Dated July 10, 2012 

Exhibit 12: William Marley Deposition Dated May 29, 2012 

Exhibit 13: James Pienta Deposition Dates May 22, 2012 

Exhibit 14: Jon Burge Response to Interrogatory #1 

Exhibit 15: Jon Burge Response to Interrogatory #2 

Exhibit 16: Raymond Madigan Response to Interrogatory #1 

Exhibit 17: Raymond Madigan Response to Interrogatory #2 

Exhibit 18: Daniel Mcweeny Response to Interrogatory #1 

Exhibit 19: Daniel Mcweeny Response to Interrogatory #2 

Exhibit 20: William Pedersen Response to Interrogatory #1 

Exhibit 21: William Pedersen Response to Interrogatory #2 

Exhibit 22: William Marley Response to Interrogatory #1 

Exhibit 23: William Marley Response to Interrogatory #2 

Exhibit 24: James Pienta Response to Interrogatory #1 

Exhibit 25: James Pienta Response to Interrogatory #2 

Exhibit 26: Jon Burge Answer to Complaint 

Exhibit 27: Raymond Madigan Answer to Complaint 

Exhibit 28: Daniel McWeeny Answer to Complaint 

Exhibit 29: William Pedersen Answer to Complaint 

Exhibit 30: William Marley Answer to Complaint 

Exhibit 31: James Pienta Answer to Complaint 

Exhibit 32: Jon Burge Personnel Record (Filed Under Seal) 

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Exhibit 33: Transcript of Proceedings, United States v. Burge, Jon Burge 

 Testimony, Dated June 17, 2010 

Exhibit 34: Findings and Decision, Before the Police Board of the City of 

 Chicago, In re Jon Burge, No. 91-1856 

Exhibit 35: Deposition of Jon Burge in Wilson v. City of Chicago, Dated 

 September 22, 1988 

Exhibit 36: Court Reported Statement of Lonza Homes, 

 Dated April 19, 2004 

Exhibit 37: Report of Proceedings, Homes v. The People of The State of 

 Illinois, Testimony of Jon Burge, Dated Feb. 24, 1986 

Exhibit 38: Report of Proceedings, People v. Mumin, Testimony of 

 Jon Burge, Dated May 13, 1987 

Exhibit 39: Initial Incident Report Dated April 19, 1986 

Exhibit 40: Report of Proceedings, People v. Patterson, Testimony of Dennis 

 McGuire, Dated Sept. 19, 1989 

Exhibit 41: Memorandum from William Marley and James Pienta 

 to Jon Burge 

Exhibit 42: Court Appearance Authorizations 

Exhibit 43: General Progress Reports 

Exhibit 44: Affidavit of Michael Arbuckle, People v. Patterson

Exhibit 45: Deposition of Michael Arbuckle, People v. Patterson, 

 Dated November 19, 2004 

Exhibit 46: Affidavit of Aaron Patterson 

Exhibit 47: Report of Proceedings, People v. Patterson, Testimony of 

 Aaron Patterson, Dated March 3, 1988 

Exhibit 48: Report of Proceedings, People v. Patterson, Testimony of Peter 

 Troy, Dated Sept. 22, 1989 

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Exhibit 49: Unsigned Statement Attributed to Aaron Patterson, 

 Eric Caine’s Signed Statement 

Exhibit 50: Affidavit of Ike Carothers, People v. Patterson 

Exhibit 51: Deposition of Richard Burnette Dated January 10, 2013 

Exhibit 52: Report of Proceedings, People v. Patterson, Testimony of James 

 Pienta, Dated Sept. 20, 1989 

Exhibit 53: Deposition of Eric Caine, Patterson v. Burge, 

 Dated January 18, 2005 

Exhibit 54: Affidavit of Dr. Ross W. Romine 

Exhibit 55: Report of Proceedings, People v. Patterson, Initial Appearance of 

 Caine and Patterson, Dated May 2, 1986 

Exhibit 56: Affidavit of Illya Rowland Affidavit 

Exhibit 57: Deposition of Illya Rowland, Patterson v. Burge, 

 Dated November 24, 2004 

Exhibit 58: State’s Response to Discovery Request 

Exhibit 59: Report of Proceedings, People v. Caine, Testimony of Peter Troy 

 Dated Sept. 26, 1989 

Exhibit 60: Report of Proceedings, People v. Caine, Closing Arguments, 

 Sept. 26, 1989 

Exhibit 61: Reports of Goldston and Sanders 

Exhibit 62: Memorandum of Opinion, In the Circuit Court of Cook 

 County, Appeal from Discharge Order Before the Police Board 

Exhibit 63: OPS Report Closing Number of Allegations as Unsustained 

Exhibit 64: OPS Report Regarding Eric Smith’s Allegations 

Exhibit 65: Terry Harris OPS statement 

Exhibit 66: Diggins Statement 

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Exhibit 67: Report of the Special Prosecutor Part A 

Exhibit 68: Report of the Special Prosecutors Part B 

Exhibit 69: Report of the Special Prosecutors Part C 

Exhibit 70: Report of the Special Prosecutors Part D 

Exhibit 71: Report of the Special Prosecutors Part E 

Exhibit 72: Report of the Special Prosecutors Part F 

Exhibit 73: Report of the Special Prosecutors Part G 

Exhibit 74: Report of the Special Prosecutors Part H 

Exhibit 75: Report of the Special Prosecutors Part I 

Exhibit 76: Report of the Special Prosecutors Part J 

Exhibit 77: Report of the Special Prosecutors Part K 

Exhibit 78: Report of the Special Prosecutors Part L 

Exhibit 79: Report of the Special Prosecutors Part M 

Exhibit 80: Report of the Special Prosecutors Part N 

Exhibit 81: Report of the Special Prosecutors Part O 

Exhibit 82: Report of the Special Prosecutors Part P 

Exhibit 83: Report of the Special Prosecutors Part Q 

Exhibit 84: Report of the Special Prosecutors Part R 

Exhibit 85: Commendations (Filed Under Seal) 

Exhibit 86: Memorandum and Order In Re Appointment of 

 Special Prosecutor, Dated May 19, 2006 

Exhibit 87: City Memorandum in Opposition to Motion to Bar Testimony, 

 Dated Jan. 22, 1992 

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Exhibit 88: Statement of Mayor Richard M. Daley 

Exhibit 89: Darrell Cannon OPS File 

Exhibit 90: Philip Adkins OPS File 

Exhibit 91: Gregory Banks OPS File 

Exhibit 92: Stanley Howard OPS File 

Exhibit 93: Michael Johnson OPS Report 

Exhibit 94: LC Riley Testimony, Dated Mar. 13, 1987 

Exhibit 95: Affidavit of Leanoard Kidd 

Exhibit 96: Report of Proceedings, People v. Holmes,Testimony of Lonza 

 Holmes, Dated Dec. 12, 1985 and Report of Proceedings, 

 Testimony of Lonza Holmes, Dates June 26, 1986 

Exhibit 97: Report of Proceedings, People v. Andrews, Testimony of James 

 Andrews, Dated Oct. 1, 1984 

Exhibit 98: Report of Proceedings, People v. Coleman, Testimony of Michael 

 Coleman, Dated Nov. 20, 1980 

Exhibit 99: Court-Reported Statement of Anthony Holmes 

Exhibit 100: Transcript of Proceedings, Judge Lefkow Sentencing 

 Jon Burge, Dated Jan. 21, 2011 

Exhibit 101: Transcript of Proceedings, Adam Green Testimony, 

 Filed July 1, 2011 

Exhibit 102: Affidavit of Flint Taylor 

Exhibit 103: Chicago Police Department Statistics for 1973 

Exhibit 104: Chicago Police Department Statistics for 1974 

Exhibit 105: Chicago Police Department Statistics for 1975 

Exhibit 106: Chicago Police Department Statistics for 1976 

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Exhibit 107: Chicago Police Department Statistics for 1977 

Exhibit 108: Chicago Police Department Statistics for 1978 

Exhibit 109: Chicago Police Department Statistics for 1979 

Exhibit 110: Chicago Police Department Statistics for 1980 

Exhibit 111: Chicago Police Department Statistics for 1981 

Exhibit 112: Chicago Police Department Statistics for 1982 

Exhibit 113: Chicago Police Department Statistics for 1983 

Exhibit 114: Chicago Police Department Statistics for 1984 

Exhibit 115: Chicago Police Department Statistics for 1985 

Exhibit 116: Chicago Police Department Statistics for 1986 

Exhibit 117: Order of Hon. Paul Biebel Appointing Special Prosecutor, 

 Dated April 11, 2013 

 RESPECTFULLY SUBMITTED, 

 /s/ David B. Owens

 David B. Owens 

 Counsel for Plaintiff

Arthur Loevy 

Jon Loevy 

Michael Kanovitz 

Russell Ainsworth 

Pier Petersen 

David B. Owens 

LOEVY & LOEVY 

312 N. May Street, Suite 100 

Chicago, Illinois 60607 

Tel. (312) 243-5900 

Fax (312) 243-5902 

Counsel for Plaintiff

 

 

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CERTIFICATE OF SERVICE 

 I, Russell Ainsworth, an attorney, certify that I served the foregoing Exhibit 

Listto all Counsel of Record by electronic means on April 15, 2013. 

 _/s/ David B. Owens

 David B. Owens 

 Counsel for Plaintiff

 

 

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