IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

JACQUES RIVERA, 

Plaintiff,

v.

REYNALDO GUEVARA, et al.,

Defendants.

)

)

)

)

)

)

)

)

)

)

Case No. 12 C 4428 

Hon. Joan B. Gottschall, 

District Judge 

Hon. Mary M. Rowland, 

Magistrate Judge 

JURY TRIAL DEMANDED 

PLAINTIFFS’ CONSOLIDATED RESPONSE IN 

OPPOSITION TO DEFENDANTS’ SUMMARY JUDGMENT MOTIONS 

EXHIBIT 12 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 1 of 433 PageID #:15422
Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 2 of 433 PageID #:15423
IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

JACQUES RIVERA, 

 Plaintiff, 

 v. 

REYNALDO GUEVARA, et al.,

 Defendants. 

)

)

)

)

)

)

)

)

)

)

Case No. 12 C 4428 

Hon. Joan B. Gottschall, 

District Judge 

Hon. Mary M. Rowland, 

Magistrate Judge 

JURY TRIAL DEMANDED 

EXHIBIT A TO THE DECLARATION OF MICHAEL BRASFIELD 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 3 of 433 PageID #:15424
1

Michael Brasfield and Associates, Inc.

641 Olele Point Road Phone: 360-301-4465

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

Jacques Rivera v. Guevara, et al.

No. 12 CV 4428

Report of Plaintiff’s Expert – Michael D. Brasfield

December 30, 2016

INTRODUCTION

Anand Swaminathan with the law firm of Loevy & Loevy, representing the plaintiff in 

this matter, contacted and retained me more than a year ago to assess whether there were any 

deviations from generally accepted police practices in the actions of numerous employees of the 

Chicago Police Department (“CPD”), specifically as they relate to matters stemming from the 

arrest and eventual incarceration of Jacques Rivera for his alleged murder of Felix Valentin. 

These events occurred over more than a 20 year period – beginning in 1988 and ending in 2011. 

Jacques Rivera spent more than 20 years in a maximum security prison as the result of the 

actions of the defendants. As a result of my review of the materials provided to me, I have 

concluded to a reasonable degree of professional certainty that the defendants and the CPD failed 

to conduct even a cursory investigation of the facts and that they intentionally and willfully 

manufactured and falsified evidence, manipulated witnesses, and withheld critically relevant 

information from the defendant and his attorneys. I have also concluded that the defendants and 

the CPD had a widespread practice or custom of acting in the same manner in similar cases for 

many years. In my opinion, there were numerous departures from generally accepted police 

practices in the Felix Valentin homicide investigation; and, the CPD, through its policies, 

practices, commissions and omissions created an environment where officers could routinely 

ignore city policies and the law with impunity and that such behavior was not only tolerated, but 

encouraged. Despite the City’s formal written policies related to investigations and 

accountability, the evidence demonstrates that as a matter of unofficial policy or widespread 

practice, police officers routinely violated common and accepted police investigative practices. 

I have also reviewed the CPD’s policies and practices related to the creation, 

maintenance, storage, preservation, and disclosure of investigative materials in homicide cases, 

as concerning the Rivera v. City of Chicago case discussed below, and more broadly. To that 

end, I reviewed documents regarding CPD’s policies and practices governing homicide 

investigative files. I also reviewed numerous files created by CPD detectives during homicide 

investigations and compared those files to defense attorneys’ files to assess whether relevant 

investigative material was disclosed or withheld. I have also relied upon the substantial 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 4 of 433 PageID #:15425
2

knowledge and experience I have gained from reviewing hundreds of CPD homicide 

investigation files and tens of thousands of pages of material in other cases involving the 

withholding of exculpatory information in so-called street files, including Fields v. City of 

Chicago and Kluppelberg v. City of Chicago. Through those cases and this one, I have reviewed 

hundreds of homicide files across different detective areas of the city, and maintained and stored 

in different locations. Based on my review, I have concluded to a reasonable degree of 

professional certainty that the CPD’s policies and practices related to the creation, maintenance, 

storage, preservation, and disclosure of investigative material deviated substantially from 

generally accepted police practices and resulted in the routine failure to disclose important 

investigative materials to criminal defendants.

My opinions and the facts upon which I base my opinions are discussed in greater detail 

below.

I have been an active-duty municipal and/or county law enforcement official for 

approximately 39 years. I retired from active governmental service in 2009. I have served as the 

Chief of Police of the Fort Lauderdale Police Department, the Assistant Chief of the Seattle 

Police Department, and the elected Sheriff of Jefferson County, Washington. Over the last 20 

years I have also been actively engaged as a consultant, trainer, case reviewer and expert witness 

in law enforcement related matters. An overview of my qualifications follows in Section I.A.

As a police practices expert, I have testified in state and federal courts for both plaintiffs and 

defendants. 

A list of cases will be found in Attachment A; material reviewed for this case is in 

Attachment B; my rate of compensation in Attachment C; and a complete and detailed resume in 

Attachment D; a list of reference materials in Attachment E; summary of my file-by-file 

comparisons in Attachment F; a spreadsheet of my data analysis in Attachment G; a copy of my 

expert report in Fields v. City of Chicago in Attachment H; and a copy of my expert report in 

Kluppelberg v. City of Chicago in Attachment I.

I reserve the right to alter my opinions and/or form additional opinions regarding this 

case upon disclosure to me of further information or documentation related to this case.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 5 of 433 PageID #:15426
3

TABLE OF CONTENTS

I. Background

A. Expert Witness Qualifications

B. Materials and Other Information Reviewed and Used in Forming Opinions

II. Summary of Relevant Facts

III. Deviations from professional homicide investigation standards in Felix Valentin 

homicide investigation

IV. Failures in CPD’s internal investigation and disciplinary processes allowed Defendant 

Reynaldo Guevara to engage in the sort of investigative misconduct alleged here

V. The CPD’s policies and practices related to the creation, maintenance, storage, 

preservation, and disclosure of investigative material deviated substantially from 

generally accepted police practices

A. Standard police practices for maintaining and disclosing investigative files requires a 

single, comprehensive file 

B. Jones and Palmer litigation highlight Chicago’s “Street File” problem

C. CPD personnel consistently use multiple files during a criminal investigation, and fail 

to disclose all relevant materials to criminal defendants.

1. Multiple files are created for a single investigation, creating a serious risk that 

investigative materials are not disclosed. 

2. The CPD’s ad hoc response to subpoenas exacerbates the problem

D. Criminal defense files show that important investigative materials are regularly 

withheld from criminal defendants

1. Background on the Area North investigative files and my file review in this 

case

2. Criminal defense files are missing pages from the police investigative files

3. Issuing a subpoena does little to ensure disclosure of all relevant materials

4. The missing pages contain important and relevant information that should 

have been disclosed to criminal defendants

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 6 of 433 PageID #:15427
4

E. CPD’s policies after Jones and Palmer don’t ensure disclosure of all relevant 

investigative materials

1. The policies are insufficient to remedy the “street files” problem

2. The City failed to provide proper training and oversight to ensure compliance 

with the special orders

F. The police investigative files show that the directives were not properly implemented

1. The police files from the 1985 to 1989 time period show that CPD’s policies 

were not followed 

a. Handwritten notes, not on general progress reports, are still routinely 

used

b. To-from memos are still being used

c. Review of permanent retention files: all relevant information in 

unofficial documents is not transcribed in official reports 

d. Inventories are missing or incomplete

2. The investigative files confirm that there was no training, auditing, or 

oversight to ensure compliance with the policies 

G. There is strong evidence in the police investigative files, the Valentin investigation 

itself, and other CPD street file cases that there are yet other investigative files and 

documents that are unaccounted for by CPD and inaccessible to the prosecutors and 

criminal defendants

1. My analysis of hundreds of files indicates that investigative information is 

being kept in other repositories or being destroyed

2. The documents and testimony from this case provide further evidence of the 

existence of additional files and the failure to preserve investigative 

information. 

3. Kluppelberg and Fields are additional examples of cases in which previously 

missing street files containing highly exculpatory information were discovered 

in civil litigation decades after the original criminal trials

a. Fields v. City of Chicago

b. Kluppelberg v. City of Chicago

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 7 of 433 PageID #:15428
5

H. The failure to turn over files in Jacques Rivera’s case was a direct result of these 

practices and inadequate policies

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 8 of 433 PageID #:15429
6

I. Background

A. Expert Witness Qualifications

I began my 41-year law enforcement career in 1968 as a patrol officer with the City of 

Mercer Island, Washington. In 1969, I joined the Seattle Police Department and served Seattle 

as a police officer, detective, sergeant, lieutenant, captain, major, and assistant chief. In addition 

to uniformed patrol, my investigative assignments as a detective included traffic homicide 

investigation, burglary and theft, and vice (gambling and prostitution). As a sergeant, I served in 

patrol, the tactical squad, and internal investigations. As a lieutenant, I served as a watch 

commander in charge of 50 patrol officers, and later as the commander of the Washington State 

Criminal Justice Training Commission’s Basic Law Enforcement Academy for 2 years. This 

academy was responsible for developing and providing the initial law enforcement training for 

all commissioned law enforcement officers in Washington State. As a captain, I served as 

commander at both the downtown and north precincts, with responsibility for over 125 officers 

at each location. I also served as the commander of the Internal Investigations section of the 

Seattle Police Department for 2 years. I was the major in command of the inspectional services 

division for 4 years. This division was responsible for developing, implementing, and 

monitoring departmental policies and procedures. This division was also responsible for 

developing and administering a budget in excess of $120 million. My last 5 years with the 

Seattle Police Department were served as assistant chief in command of the support services 

bureau. I was responsible for, and oversaw the activity of, nine uniquely different divisions 

including: internal investigations; training; personnel, intelligence; crime prevention; 

communications; records & evidence, which included the maintenance and control of homicide 

files; data processing; and fiscal, property, & fleet management. In this capacity I routinely 

served as the acting Chief of Police. I retired from the agency in 1995.

I was selected by the City of Fort Lauderdale as their Police Chief in 1995. The 33 

square mile city has a full time resident population of 165,000. An estimated additional 60,000 

“snow bird” residents return to second homes in the city during the 6-month winter season. Fort 

Lauderdale serves as the seat of government for the county of 1.5 million and is in the heart of a 

diverse tri-county (Dade, Broward, and the Palm Beach) population of 4 million. As one of the 

premier tourist destinations in South Florida, over 12 million passengers come through the 

airport each year. The ocean port handles the second largest number of cruise ship sailings in the 

world. Fort Lauderdale serves as the governmental and business hub of the County. The Fort 

Lauderdale Police Department had a budget of $60 million and consisted of 500 sworn positions 

and 300 civilian positions. In 2000, the department received 600,000 calls for service, 

dispatched over 200,000 of those calls, made over 20,000 arrests, and issued 65,000 traffic 

citations. The Department is now nationally recognized as an innovative leader in the field of 

community policing and was one of only a handful of cities nationwide to be selected as a 

Community Policing Demonstration Site by the Department of Justice. I oversaw the operation 

of the only municipal jail in the state of Florida. Under my tenure, Fort Lauderdale became the 

first major agency to obtain accreditation. After over 6 years as the police chief of Fort

Lauderdale, I retired from law enforcement a second time and returned to the Seattle area in the 

fall of 2001.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 9 of 433 PageID #:15430
7

After retiring as Chief of the Fort Lauderdale Police Department I returned to my 

retirement home in Washington State. After a year and a half, I chose to run for, and was elected 

to, the office of Jefferson County Sheriff. I served in that capacity for over 6 years, and retired 

for the third (and final) time in the spring of 2009.

As both a Police Chief (6 years) and Sheriff (6 years), I have reviewed and approved 

policy and procedures of every kind. These included (but not limited to) criminal investigations, 

maintenance of police records, complaints against police officers, training, supervision and 

discipline.

Of specific relevance to this case - During my 4 years as a supervisor and commander of 

the Internal Investigation Section of the Seattle Police Department I was directly involved with 

thousands of investigations of allegations of employee misconduct, including failure to adhere to 

rules and regulations. These included criminal investigations, up to and including evidence and 

witness tampering, burglary, robbery, sexual assault, and homicide investigations in officer 

involved shootings.

Of specific relevance to this case - During my 31 years in a supervisory and management 

capacity as a Sergeant, Lieutenant, Captain, Major, Assistant Chief, Chief of Police, and Sheriff, 

I have been responsible for the review and processing of hundreds of disciplinary actions up to 

and including termination.

Of specific relevance to this case - I am the past chair of the Washington State Board on 

Law Enforcement Training, Standards, and Education. As such we regularly examined and 

reviewed issues and criteria that define standards and norms related to the practice and 

administration of law enforcement practices and operations. 

Of specific relevance to this case - Since the enactment of legislation establishing the 

Washington Peace Officer Certification Revocation Hearing process, I participated as a member 

of that panel in more Revocation Hearings than any other sworn law enforcement officer to date.

Of specific relevance to this case – During my 2 years as Commander of the Washington 

State Basic Law Enforcement Academy in Burien, I was responsible for the administration of the 

training program provided to all Washington State Law Enforcement Officers. This was also my 

role as the Assistant Chief of the Seattle Police Department responsible for in-service and 

advanced training at the Academy over a subsequent 5 year period.

Of specific relevance to this case - I have been responsible for the development, 

formulation and updating of police policy and procedures as the Commander (6 years) of the 

Seattle Police Department’s Inspectional Services Division.

As an independent consultant and sub-contractor, I have completed on-site visits to 

analyze 6 major U.S. City (Boston, Baltimore, Memphis, Oxnard, Cleveland & Seattle) police 

agencies to evaluate community policing in public housing. I have also served as a visiting 

management assessor for the cities of New Orleans (LA), Columbus (OH), Portland, (OR), San 

Francisco (CA), Bremerton (WA). Upon my return to Seattle in 2001, I provided contract 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 10 of 433 PageID #:15431
8

professional services as a consultant and program director for the non-profit South Downtown 

Foundation. I had responsibility for administering several million dollars for improving public 

safety in the International District, SoDo, and Pioneer Square neighborhoods of Seattle. In this 

capacity I coordinated efforts with the City of Seattle, the Seattle Police Department and various 

interest and civic groups in the area.

In 2002, I became a candidate for the Sheriff of Jefferson County, Washington. I was 

successful and assumed that office on January 1, 2003. I successfully ran for re-election in 2006 

and was returned to office with 80% of the popular vote. I held a gubernatorial appointment to 

the Washington State Sentencing Guidelines Commission, serving as the only law enforcement 

official on this body of judicial, legislative and governmental representatives. I chaired the 

Washington State Criminal Justice Training Commission’s Board on Law Enforcement Training, 

Standards, and Education. Members of this board monitor and evaluate the training of police 

officers and participate in law enforcement decertification hearings.

Over the last 40 years I have received extensive, specialized professional training in 

nearly all areas of law enforcement. There has been particular emphasis in the areas of training, 

internal investigations, accident investigation, use of force, ethics and police liability. I was 

awarded “life member” status with the International Association of Chiefs of Police in 2005. I 

was also awarded “life member” status with the Washington Association of Sheriffs and Police 

Chiefs in 2009. I am also a “life member” of the National Sheriffs Association. I have also been 

a member of the Washington State Sheriff’s Association and served on the executive board of 

that organization.

During my career, I have been required to investigate and/or review hundreds of internal 

investigations. I have supervised hundreds of officers, and have had to review their compliance 

with standards of behavior and truthfulness. As both a supervisor, and later a commander of 

internal investigations with the Seattle Police Department, I have reviewed and evaluated the 

thoroughness of well over hundreds of such investigations. As a police chief and as a sheriff, I 

have had the ultimate responsibility of passing judgment on such actions by law enforcement 

officers in situations ranging from traffic stops to fatal shootings.

I received a Bachelor of Arts degree in Criminal Justice from the University of 

Washington in Seattle. I also am a graduate of the Senior Management Institute for Police 

(SMIP) of the Police Executive Research Forum. A copy of my Curriculum Vitae is attached as 

Appendix A.

B. Materials and Other Information Reviewed and Used in Forming Opinions

The following opinions are based upon my four decades of knowledge, education, training, and 

experience as a police officer, detective, police supervisor, commander, police chief, and sheriff. 

In particular, they are based on my lengthy experience with the law enforcement specialties of 

inspections, training, policy development, accreditation, jail operations and police internal 

investigations. My opinions are also based on the extensive materials I have been provided by 

counsel. I have attached a list of those documents as Attachment B. I have formed the following 

opinions based on a reasonable degree of certainty within the field of law enforcement practices 

and procedures. It is my practice to evaluate the reasonableness of police policies, practices, and 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 11 of 433 PageID #:15432
9

procedures on a case-by-case basis from the perspective of a police reviewing authority. My 

experience and qualifications are briefly outlined above and documented in my complete resume 

in Attachment D of this document.

II. Summary of Relevant Facts

On Saturday afternoon, the 27th of August 1988, Israel Valentin (age 22) and his younger 

brother Felix Valentin (age 16) drove to an apartment building located at 3324 West Cortland 

Street in the City of Chicago, Illinois. Israel exited their car and went inside the building to pick 

up his girlfriend, Marilyn Lopez, to attend a wedding. While Israel was in the building, Felix 

waited in the driver’s seat of their car. An individual approached the car and shot Felix multiple 

times, then jumped into a waiting car driven by another individual and fled the scene. Shortly 

thereafter, Israel returned to the vehicle and discovered his younger brother seriously wounded. 

Police communications received the call at 3:39 pm. Israel took Felix to Norwegian Hospital and 

he was eventually transferred to Cook County Hospital. 

Felix succumbed to his wounds nearly 3 weeks later on 9/14/1988. Felix’s hospital 

treatment is related in the deposition of Dr. Arthur Sharkey. Felix suffered from multiple gunshot 

wounds and was treated in the intensive care unit over a period of nearly 3 weeks. Police reports 

document his poor condition and inability to interact with officers (Wron 00031- 00036). As of 

9/9/1988, Valentin was not responsive to painful or verbal stimuli, his pupils did not react to 

light, he was on a ventilator and a moving bed, he was not breathing on his own, he was on 

medication to paralyze him, and he was suffering from a major infection. According to Dr. 

Sharkey, there is no indication in the medical records that Valentin regained responsiveness 

between 9/9/1988 and his death on 9/14/1988.

On 8/27/1988, responding police units who arrived at Norwegian Hospital were furnished 

with descriptions of the suspect and his “getaway” driver. The victim Felix described both 

subjects as Hispanic males between the ages of 16-18 driving an older brown vehicle – possibly 

a Toyota hatchback (Hickey 00002). Responding police units reported also that Felix related that 

the suspect had been wearing a yellow baseball hat and was of light to medium complexion 

(Hickey 00004).

Detectives McLaughlin and Leonard responded to the hospital at 5:15 p.m. 8/27/1988 to 

interview Felix and Israel. Detectives created a general progress report and police report 

reflecting the interview. The general progress report relates Israel’s description of the events 

surrounding the shooting. It does not contain a description of the suspect and getaway driver. In 

addition, the general progress report contains information that Marilyn Lopez’s younger brother, 

Orlando “Macho” Lopez (age 12) may have observed some portion of the shooting but had not 

been interviewed (Wron 00069). The police report (Wron 00031-Wrong 00033) contains a 

description of the suspect – Hispanic male between the ages of 18-22 with brown eyes, dark hair, 

a black jean jacket, dark pants, and gym shoes – and getaway driver – Hispanic male between the 

ages of 18-22. The description is not attributed to any person and the report does not describe the 

origin of the description. In addition, the description does not appear in the general progress 

report and is different than the description reported by responding police units. The police report 

omits any reference to Orlando Lopez.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 12 of 433 PageID #:15433
10

Additional detectives Letrich and Moriarty interviewed Felix Valentin at the hospital on 

8/30/1988 (Wron 00039). Felix stated that the two suspects were members of the “Imperial 

Gangsters”. Detectives presented an Imperial Gangster photo album (“gang book”) to Felix. 

Felix identified the shooter as Jose Antonio “Chequin” Rodriguez, and the driver of the getaway 

car as Phillip Nieves. Based on the identification provided by the shooting victim, Rodriguez 

was arrested just 3 blocks from the scene of the shooting at 1 a.m. on 8/31/1988 by Officers 

Moriarity, Vergara and Wojcik (at the request of Letrich) as the suspect in the shooting (Wron 

00058). A hold dated 8/31/1988 was placed on Rodriguez that stated that officers expected to 

charge him with aggravated assault on Felix Valentin by 1 a.m. on 9/2/1988 (Wron 00059). The 

hold also stated that a line-up was to be viewed by the witness in the case. A release form dated 

8/31/1988 states that the victim was unable to identify the defendant, due to being heavily 

sedated for pain (Wron 0063).

A photograph of Rodriguez was provided to me during my review of the case (RFC 

1420) as part of a set of six photographs (RFC 1415-1420). These photographs are not part of the 

police, prosecutor, or criminal defense files provided to me. The numbered photographs appear 

to correspond to detective Leonard’s general progress report dated 8/31/1988 (Wron 0064), and 

to the photograph evidence form dated 8/31/1988 11:45 p.m. (Wron 0062). 

Gang Specialists Guevara and Gawrys reported on 9/16/1988 that they showed 

photographs of Rodriguez and Nieves to Orlando Lopez following a physical lineup on 

9/15/1988. The report states that Lopez denied that Rodriguez and Nieves were involved in the 

shooting of Felix Valentin (Wron 00010). There is no photo of Nieves in the file.

With the exception of the above, there is no further reference to Rodriguez or to Nieves 

in the material. 

Detectives McLaughlin and Leonard reported that on 8/29/1988 they interviewed 

Orlando Lopez. The report states (Wron 00030):

LOPEZ was coming from the store at corner of Kimball and Cortland. LOPEZ observed 

a copper colored GM-type car coming out of the alley, traveling northbound at 

approximately 3319 W. Cortland. LOPEZ indicated that said vehicle contained 2 

M/WH’s one of whom exited from the passenger’s side of the vehicle and began to walk 

toward 3320 W. Cortland where the victim was seated behind the wheel of his vehicle. 

Suddenly, the M/WH began to run toward vehicle and LOPEZ noticed a gun in M/WH’s 

hand. LOPEZ believed he heard three (3) shots but indicated that they were not very 

loud. LOPEZ indicated that LOPEZ saw the victim lean forward and to the right in the 

vehicle which victim had been seated.

LOPEZ informed R/D’s that LOPEZ could identify the shooter because LOPEZ 

recognized the shooter as a M/WH who played baseball at Humboldt Park and LOPEZ 

had observed him there on a few occasions. LOPEZ did not know shooters name but was 

aware that shooter was affiliated with the Latin Kings. LOPEZ then viewed books and 

made an identification of one RIOS, Jose (16-D LATIN KING Page 40D) as the M/WH 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 13 of 433 PageID #:15434
11

who exited the copper car and shot the victim. At this time there is no identification of the 

driver. 

On 9/16/1988, Gang Specialists Guevara and Gawrys also reported that Orlando Lopez 

was located and brought to Gang Crimes North on 8/29/1988, at which point he looked at photo 

books and selected a picture of Rivera (Wron 00009-00010). No photo albums were preserved or 

inventoried as evidence. 

A police report of Detectives McLaughlin and Leonard dated 9/1/1988 (Wron 00035) 

states that attempts were made to have Lopez view a physical lineup including Rivera and 

Rodriguez on 8/31/1988 or 9/1/1988 but Lopez’s parents would not allow him to participate at 

night and Lopez could not be located.

On 8/30/1988, Gang Specialist Reynaldo Guevara and other defendants arrested 22 year 

old Jacques Rivera (Wron 00056). Guevara claims to have based the arrest solely on an alleged 

identification of Rivera by 12 year old Orlando Lopez on 8/29/1988. However, a rap sheet of 

Rivera was requested on the day of the shooting on 8/27/1988 (Wron 00055). The arrest report 

states that hold papers were submitted “due to the fact that the witness is not available to view a 

physical line-up which will be held on 31 Aug. 88” (Wron 00056). A hold dated 8/30/1988 was 

placed on Rivera that stated that officers expected to charge him with aggravated battery on Felix 

Valentin by 7 p.m. on 8/31/1988 (Wron 00057). The hold also stated “the witness to this case 

will not be available until tomorrows date, and Felony review will not approve charges until they 

can interview the witness.” On 8/31/1988 or 9/1/1988, Rivera was released without charges. 

Rivera was steadily employed at the Humboldt Park Institute. He was living with his 

spouse and children; was 4 to 6 years older than the descriptions of the suspects; had no known

connection to the victim; and lacked identifying physical characteristics contained in the 

description of the suspects. Guevara had no physical evidence to support the arrest of Rivera.

Following the death of Felix Valentin on 9/14/1988, reports indicate that Orlando Lopez 

viewed a physical lineup at Area Five on 9/15/1988 and identified Rivera. Photographs were 

taken of the lineup and inventoried. 

Lopez has testified numerous times that during the 9/15/1988 lineup he told police that 

Jacques Rivera was not the person who shot Felix Valentin, and that the police responded that he 

should not be afraid to make an identification (Lopez Dep., Lopez Hearing and Trial Testimony). 

Lopez testified that this conversation occurred with a detective with an afro, a mustache, and 

glasses and a woman with blond or white hair. I have been provided with photographs of 

Reynaldo Guevara, which show him with an afro, mustache, and glasses.

Lopez has also testified numerous times that there were actually 2 separate physical

lineups that he viewed. Lopez testified that the first lineup was conducted within a few days of 

the shooting of Valentin. The same detective with an afro, a mustache, and glasses accompanied 

Lopez to the first lineup. In Lopez’s view, he (Lopez) selected Rivera from the first lineup as 

well. Following the first lineup, Lopez saw the person who had shot Felix Valentin on the street. 

The person was an Imperial Gangster and was not Jacques Rivera. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 14 of 433 PageID #:15435
12

Jacques Rivera has also testified that there were actually 2 separate physical lineups. 

Rivera testified that Guevara asked him to be a filler in a lineup, after which he was held for a 

period of time and then placed in a lineup. Rivera testified that he was not told during the first 

lineup what crime he was standing in a lineup for or who was viewing the lineup. Rivera testified 

that he was released after the first lineup. 

The testimony of Lopez and Rivera on this point directly contradicts the “official” record 

produced by the defendants. The police reports produced by the defendants do not contain any 

report of a physical lineup before 9/15/1988. A report of McLaughlin and Leonard describes a 

failed attempt to conduct a physical lineup with Lopez on 9/1/1988, after which they report they 

attempted to show photos to Felix Valentin at the hospital (Wron 00034-00035).

Documents in the investigative file support Lopez and Rivera’s testimony that there were 

actually 2 physical lineups. As I discuss above, arrest reports, hold reports, and release reports 

state that on 8/31/1988 and/or 9/1/1988 both Rivera and Jose Rodriguez were being held to 

participate in a physical lineup with a witness. A general progress report written by Leonard on 

8/31/1988 lists the names of Rivera and Rodriguez, along with four other individuals acting as 

fillers – Villafane, Olivero, Ruiz, Ramon Lopez. Photographs of all six individuals, apparently 

taken at the same time against the same backdrop, were submitted into evidence on 8/31/1988 

(RFC 1415-1420, Wron 00062, 00064).

Testimony from Villafane, Olivero, and Ruiz also supports Orlando Lopez and Rivera’s 

testimony that there were actually 2 physical lineups. Villafane testified that he only once 

participated in a lineup in his life in the summer of 1988 (Villafane Dep, pp. 13-14). Olivero also 

testified that he participated in a lineup for a shooting in the summer of 1988 (Olivero Dep, pp. 

13-14). Ruiz testified that he had been in a lineup for the shooting of Felix Valentin, who was a 

friend of Ruiz (Ruiz Dep, pp. 26-27).

Taken together, there is strong evidence supporting Lopez and Rivera’s testimony that 

there were 2 physical lineups.

Following the second physical lineup on 9/15/1988, Reynaldo Guevara and other 

defendants arrested Jacques Rivera for murder (Wron 00051). Later on the same night, Guevara 

and Gawrys submitted a supplementary report (Wron 00009), which states that Lopez identified 

Rivera in a photo album on 8/29/1988 and at a physical lineup on 9/15/1988. The report states 

further that Lopez was shown photos of Rodriguez and Nieves after the 9/15/1988 physical 

lineup and stated that they were not involved in shooting Felix Valentin (Wron 00010). Lopez 

testified that he was not shown photographs other than the photo albums (Lopez Dep, p. 177). 

Finally, the report states that on 9/10/1988, Guevara and Gawrys showed the victim Felix 

Valentin a photo album at the hospital and that Valentin identified Jacques Rivera as the person 

who had shot him (Wron 00010). Such an identification would have been impossible given the 

course of Felix Valentin’s medical treatment described above. Dr. Sharkey testified on 

9/10/1988, Valentin could not reasonably have spoken to another person, he could not have 

looked through a photo album, and he could not even have communicated with his eyes (Sharkey 

Dep., pp. 55-56).

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 15 of 433 PageID #:15436
13

In spite of numerous intentional malicious acts by Guevara and others of omission and/or 

commission; witness manipulation; false testimony and reporting; withholding of evidence; etc., 

murder charges were successfully filed against Jacques Rivera. 

Rivera was convicted in July 1990 for the murder of Felix Valentin, based on the 

testimony and in-court identification of then 13-year-old juvenile, Orlando Lopez, and the 

testimony of Reynaldo Guevara. Lopez’s testimony was the only evidence of Rivera’s guilt 

presented at Rivera’s criminal trial. Investigative materials in the possession of the Chicago 

Police Department were not provided to Mr. Rivera and his attorney, Judge Wadas, as described 

in detail below. Rivera was sentenced to 80 years in state prison and incarcerated for over 20 

years.

Rivera represented himself pro se in parts of his post-conviction case and attempted to 

use FOIA to obtain documents from the Chicago Police Department relating to a physical lineup

conducted on or about 8/31/1988. Later, Rivera was represented in his post-conviction case by 

the Center on Wrongful Convictions at Northwestern University.

In September 23, 2011, the Circuit Court of Cook County granted Rivera a new trial 

based on the conclusion that there was sufficient evidence of his innocence. Cook County 

prosecutors elected in October of 2011 not to retry Rivera and dropped the charges against him. 

In September 2012, the Circuit Court of Cook County granted Rivera a certificate of innocence.

III. Deviations from professional homicide investigation standards in Felix Valentin 

homicide investigation

Homicide cases and investigations in police agencies across the United States are given 

priority and resources not normally provided to other types of investigations. More experienced, 

trained and knowledgeable detectives are assigned. Their investigations result in detailed 

documentation, commonly referred to as “murder books” in some jurisdictions. These 

investigative records provide a step by step record of all evidence gathered, all witnesses 

interviewed, statements taken, leads followed (whether productive or not), medical records, 

autopsy photographs and reports, photographs of the crime scene, wound descriptions, weapon 

(gun, bullet, shell, knife, vehicle, objects, etc.) analysis, chain of custody and evidence logs, 

vehicle impounds, search warrant applications and returns. It is not uncommon for a typical 

murder investigation to contain hundreds (and often times thousands) of pages – even if there is 

thought to be a “known” suspect. There are well-established criteria and a broad range of 

literature for these practices. In fact, Det. Anthony Wronkowski (“Homicide Coordinator”) 

stated that there should be 22 specific parts of an on-going and completed Chicago Police 

Department homicide investigation book.

Experienced homicide detectives are familiar with the difficulties posed by relying 

entirely on a single “eyewitness” as a basis for police presenting a charge of homicide and they 

were aware of these difficulties in 1988. According to the American Judicature Society, 

misidentification by eyewitnesses was the leading cause of wrongful conviction in more than 75 

percent of the first 183 DNA exonerations in the United States. The presence of a weapon 

during an incident can draw visual attention away from other things, such as the perpetrator’s 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 16 of 433 PageID #:15437
14

face, and thus affect an eyewitness’s ability to identify the holder of the weapon. This is further 

aggravated when the lineup does not contain the offender. In that situation young children and 

the elderly commit mistaken identifications at a rate higher than young adults.

Professional investigation and documentation are critically important for a number of 

reasons, some of which include but are not limited to:

x Case integrity

x Continuity of investigation

x Supervisory oversight

x Facilitation of case management

x Inclusion of investigative notes and investigators actions

x Insuring thoroughness of the investigation

x Allowing other investigators to assist or replace initial investigators

x Providing a “paper trail” of what steps were taken (or not taken)

x Focusing on important aspects of the case

x Identifying what remains to be done and what has already been done and by whom

x Eliminating suspicion from some possible initial suspects

x Providing sufficient information to identify and arrest a suspect

x Providing insight for prosecutors considering charges

x Providing an objective basis for charging and trying the suspect

x Providing an objective basis for the court to determine challenges

x To have a single document for discovery and disclosure (Brady rule)

Individual, Supervisory & Institutional Failures in Felix Valentin Homicide Investigation

Officers’ liabilities in this investigation include, but are not limited to:

x Problematic reports

x Intentional and willful actions

x Intentional and willful omissions

x Fabrication of evidence

x Destruction, suppression, failure to preserve evidence and investigative materials

x Bogus documentation and failure to provide documentation

x Improper and manipulative juvenile procedures

x Improper lineup and photo array identification procedures

x Criminal conspiracy

This so-called “investigation” into the homicide of Felix Valentin by the Chicago Police 

Department, Reynaldo Guevara, and various police officers and supervisors employed by the 

City was 1) intentionally and blatantly calculated to wrongfully focus on, arrest, charge and 

convict Jacques Rivera; and/or 2) was conducted in a manner as to be considered so sloppy and 

unprofessional as to insure the same outcomes.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 17 of 433 PageID #:15438
15

Even by the most forgiving of standards, practice and criteria, the investigative 

documents of the Chicago Police Department in this matter were lacking any semblance of a 

professional and thorough investigation.

Before describing specific failures in the Valentin investigation, I must note that it is 

unusual that an investigating officer in a criminal investigation would refuse to answer questions 

about that investigation under oath. On the advice of his attorneys and apparently concerned 

about incriminating himself, Reynaldo Guevara refused in his deposition in this case to answer a 

single substantive question about the Valentin investigation or the prosecution of Mr. Rivera 

during his deposition in this case. This refusal extended to all aspects of the case, including the 

fabrication and suppression of evidence, manipulation of witnesses, including Orlando Lopez, 

physical and photo identification procedures used, exclusion of alternative perpetrators, 

testimony at Mr. Rivera’s criminal trial, related misconduct in other cases, etc. It is a duty of a 

police officer to testify truthfully about investigations in which he is and was involved and a 

refusal to adhere faithfully to that duty is a departure from accepted police practices. I infer from 

Guevara’s silence that there are no ready explanations for the serious holes in the Valentin 

homicide investigative, and that if Guevara were to testify, his statements would not exonerate 

him.

Some specific and important examples and issues of the failure to conduct a thorough and 

professional investigation to either bolster or eliminate suspects include, but are not limited to:

x Maintenance of parallel investigative files some of which are not provided to the 

criminal justice system. As explained in greater detail below, important investigative 

materials created during CPD investigation were not provided to Mr. Rivera, his criminal 

defense attorney, Judge Wadas, or the state prosecutors charged with approving charges 

and prosecuting the criminal case. Some of these investigative materials have gone 

missing or were destroyed. Other investigative materials were withheld and produced 

decades after Mr. Rivera’s conviction. Those investigative materials recently produced 

have strong investigative value and should have been provided to participants so that they 

could conduct additional investigation to demonstrate Mr. Rivera’s innocence, the 

unreliability of eyewitness Lopez, and to bring the perpetrator to justice. The multiple 

files in this case demonstrates a lack of file integrity and security, an insufficient or nonexistent chain of evidence and/or custody, and willful failure to disclose and produced 

(Brady rule) all records to prosecutors, defense attorneys, and the court, not only in the 

initial process and trial, but also later in appeals and civil litigation.

x Investigative “tunnel vision” by Reynaldo Guevara and the other defendants.

Responding officers investigating crimes have an obligation under accepted practices to 

follow all leads to bring the true perpetrator to justice. It is not an acceptable practice to 

focus on a suspect while developing evidence that implicates that suspect and excluding 

evidence that implicates other suspects (“tunnel vision” or confirmation bias). Tunnel 

vision is apparent in the investigative materials. The following four examples are the 

chief evidence of tunnel vision in the investigation of the Valentin homicide and the 

prosecution of Mr. Rivera for that crime:

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 18 of 433 PageID #:15439
16

o A rap sheet of in the investigative file, which was not given to Mr. Rivera or 

his attorney Judge Wadas, shows an issued on inquiry date stamp of 

8/27/1988. Based on my experience in other cases involving the Chicago Police 

Department, that date stamp was placed on the rap sheet when it was requested by 

investigators working the Valentin investigation and was issued by the records 

division. The date stamp of 8/27/1988 is the same day as the Valentin shooting 

and is a full two days before 8/29/1988, the date on which police report the first 

mention of Mr. Rivera being implicated as having anything to do with this crime. 

Selecting a suspect without evidence and then pursuing evidence to connect that 

suspect to the crime in question is in serious conflict with accepted police 

practices. If Mr. Rivera was a suspect before the only evidence tying him to the 

crime was developed—the eyewitness identification of Lopez—that represents a 

gross violation of accepted police practices and egregious misconduct.

o A physical lineup viewed by Lopez on 8/31/1988 or 9/1/1988 did not result in 

an identification of Mr. Rivera and was suppressed. Evidence discussed above 

supports the conclusion that an initial physical lineup procedure was performed 

on 8/31/1988 or 9/1/1988 that included Orlando Lopez as the witness and Mr. 

Rivera as a suspect, during which Mr. Rivera was not identified and after which 

Mr. Rivera was released from custody. Investigative materials concerning that 

physical lineup procedure were not provided in advance of Mr. Rivera’s criminal 

trial to Mr. Rivera or to his attorney as described in Section V.H below. A failure 

by the sole eyewitness Lopez to make an identification of Mr. Rivera is evidence 

that he did not commit the crime. In addition, it is evidence that critically 

undermines Lopez’s 9/15/1988 supposed identification of Mr. Rivera, and it is 

evidence that prosecutors and criminal defense attorneys would have used to 

evaluate the prosecution and defense of the case. Failure to document Lopez’s 

non-identification of Mr. Rivera during the 8/31/1988 or 9/1/1988 physical lineup 

is additional evidence of “tunnel vision” and another gross violation of accepted 

police practices. 

o Failure to pursue perpetrators Rodriguez and Nieves, identified by the 

victim, and failure to document investigation, exclusion, or alibis of 

alternative perpetrators. Shortly after the crime, the victim Felix Valentin stated 

to investigators that the person who had shot him was a member of the gang 

called the Imperial Gangsters, after which investigators provided a photo album of 

know Imperial Gangsters, from which Felix Valentin selected a photograph of 

Jose Rodriguez as the shooting perpetrator and Felipe Nieves as the driver of the 

getaway car. Rodriguez was arrested in close proximity to the crime scene, held, 

and participated in a physical lineup, as described above, but he was released 

according to reporting on or about 9/1/1988 with the only stated reason being that 

the victim had not identified him. Lopez testified that shortly after the first 

physical lineup he saw the perpetrator of the Valentin shooting on the street and 

recognized that the perpetrator was a member of the Imperial Gangsters street 

gang. The investigative files do not document any investigation of Rodriguez or 

Nieves other than the above, even though these individuals were identified by the 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 19 of 433 PageID #:15440
17

victim of the crime, who was the person in closest proximity to the shooter. The 

investigative files do not reflect or document an effort to determine whether 

Rodriguez or Nieves had an alibi for the date and time of the shooting of Felix 

Valentin, and they do not reflect or document the process by which Rodriguez or 

Nieves were excluded as suspects in this crime. The only exception is the report 

by Guevara and Gawrys described above, which states, contrary to Lopez’s 

testimony, that Lopez was shown photographs of Rodriguez and Nieves following 

his supposed identification of Mr. Rivera on 9/15/1988, at which point Lopez 

supposedly excluded Rodriguez and Nieves. Established police practices require 

investigation of perpetrators of crimes identified by the victims of those crimes, 

including careful documentation of the investigation of such individuals and the 

process by which such individuals are excluded as suspects.

o False reporting of an identification of Mr. Rivera by the victim Felix 

Valentin. Reporting detectives Guevara and Gawrys stated in a police report 

written on 9/16/1988, after Mr. Rivera’s arrest, that the victim Felix Valentin a 

week before on 9/10/1988 had identified Mr. Rivera as the perpetrator in a 

photograph. The failure to contemporaneously document this purported 

identification and the physical impossibility of such an identification being made 

by a victim who on 9/10/1988 was unresponsive, could not breath, had unreactive 

pupils, was paralyzed with medication, and who could not have made an 

identification according to the doctors treating him, demonstrates that the 

information about an identification of Mr. Rivera by Valentin is false. This false 

information is likely included in the police report produced after Mr. Rivera’s 

arrest by police officers suffering from “tunnel vision” in order to eliminate the 

significant obstacle to Mr. Rivera’s arrest and prosecution that is caused by the 

fact that shortly after the crime the victim Felix Valentin identified individuals as 

perpetrators who were not Mr. Rivera. Inserting false information into a police 

report is an additional gross deviation from acceptable police practices during a 

homicide investigation, as is attributing to the victim of a crime an identification

that did not occur.1

x Improper conduct of and failure to document physical and photographic lineup and 

showup procedures. In addition to the failure to document a filler identification and/or 

non-identification of Rivera taking place during an initial physical lineup on 8/31/1988 or 

 

1 Additional departures from accepted police practices concerning the supposed 9/10/1988 identification 

of Mr. Rivera by Felix Valentin include 1) the fact that information about the identification was first 

inserted into a report 6 days later on 9/16/1988, after Lopez had selected Mr. Rivera in a 9/15/1988 

physical lineup, leaving no contemporaneous documentation of the identification in the investigative 

record, 2) the lack of documentation regarding how the identification procedure was employed, including 

any deviations from standard practice, such as using signals rather than speech to indicate identification, 

or any modifications to allow Felix to view the photographs while his bed was in constant motion from 

side to side, 3) the lack of any audio recording, video recording, or other documentation of the 

identification procedure, 4) failure to preserve the photograph identified, 5) failure to document the 

physical and mental condition of the witness, given his serious injuries, during the identification 

procedure and interaction with the witness apart from the identification procedure.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 20 of 433 PageID #:15441
18

9/1/1988, discussed above, investigating defendants also departed from accepted police 

practices in their conduct and documentation of physical and photographic lineups 

conducted during the course of the Valentin investigation as follows:

o Failure to document the circumstances of Lopez’s purported identification of 

Mr. Rivera in a photo album. There are conflicting reports and testimony about 

where the identification occurred and who was present and procured said 

identification. There is no documentation of the number of photographs shown to 

Lopez, what photo albums were shown to Lopez, who was present (both civilian 

and police officers) what Lopez said/what was said to him before and after the 

identification procedure, Lopez’s reaction to various pictures as he reviewed the 

photo books, how long the procedure lasted, or the contents of Lopez’s statement 

when he supposedly picked Jacques Rivera’s photograph, including his level of 

certainty. The photograph and the photo book were not preserved or inventoried 

as evidence. In related fashion, there is an absence of explanation in the police 

documents as to why investigators provided Lopez solely with a Latin Kings 

photo album, rather than showing him multiple albums, such as the Imperial 

Gangster albums.

o Failure to document the circumstances of other identifications from photo 

albums. There are similarly no records documenting the identifications 

supposedly made by Felix Valentin from photo albums and those photographs and 

photo albums were not preserved or inventoried as evidence.

o Failure to use fillers independent of the investigation. Individuals present in a 

physical or photographic lineup procedures as fillers must not be known to 

witnesses viewing those procedures. For obvious reasons, use of a filler known to 

the witness increases the possibility of mistaken/improper identification because 

the person is known by the witness and thus is not a filler. George Ruiz (or a 

photo of him, if the defendants are believed) was used in a lineup procedure on or 

about 8/31/1988 or 9/1/1988. Ruiz was a friend of Felix Valentin’s and was 

known to him. He was likely known by Lopez (at least in appearance) as well. 

Using Ruiz and others known to witnesses undermines the reliability of those 

identification procedures.

o Failure to document use of photos. The investigative materials reflect photos, 

including photos of Mr. Rivera, without documentation of individuals to whom 

those photos were shown or even whether those photos were used during the 

investigation. 

o Failure to include Jose Rodriguez in 9/15/1988 lineup. Without any 

explanation in the police record, Jose Rodriguez was not presented in a physical 

lineup to Lopez on 9/15/1988. Rodriguez had been identified by the victim 

himself and was arrested in close proximity to the crime scene. Not permitting 

Lopez to observe the potential actual perpetrator dramatically increases the 

chance of a mistaken identification of an innocent person. Relatedly, the chance 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 21 of 433 PageID #:15442
19

of a mistaken identification is increased when two lineups are shown to a witness 

that only have a single suspect in common.

o Failure to accept and suppression of non-identification. According to Lopez, at 

the 9/15/1988 physical lineup, he (Lopez) stated that Mr. Rivera was not the 

person who committed the shooting. Rather than accepting his statement, 

defendants had Lopez proceed with the identification of Rivera and then 

suppressed the true circumstances of the identification. In addition, defendants 

improperly suggested to Lopez that he should continue with his identification of a 

particular participant (Mr. Rivera). This is an obvious and knowing suppression of 

highly exculpatory evidence, and it represents a blatant manipulation of a child 

witness (see below). In addition, it runs contrary to accepted police practices, 

established in 1988, which required investigators not to suggest to witnesses 

anything about who should or should not be selected during a lineup procedure.

o Improper photo lineup with unresponsive witness. As discussed elsewhere, 

Valentin was not in physical shape to participate in any lineup procedure or to 

respond to officers as of 9/10/1988, nonetheless Guevara/Gawrys presented him a 

lineup on that date. A lineup should not be shown to witnesses who are in a 

comatose state. The condition or a witness and any changes to a lineup procedure 

as a result of the witness’s condition must be carefully documented.

o Improper photo lineup with Orlando Lopez following live lineup and failure 

to document photo lineup. Though Lopez denies being shown photographs of 

Rodriguez and Nieves after his 9/15/1988 lineup with Mr. Rivera, even accepting 

Guevara/Gawrys’s account that he was shown such photographs, that was not the 

proper procedure. Rodriguez and/or Nieves should have been included in a live or 

photographic lineup, including fillers, if they were to be excluded. In addition, the 

photos shown to Lopez should have been preserved and inventoried as evidence, 

and the procedure used to show those photos to Lopez should have been 

documented.

The departures from standard police practices regarding lineup procedures 

discussed above were in part a result of the written policies of the Chicago Police 

Department governing lineups. Hickey testified that GO 83-5, effective at all dates in 

the Valentin investigation, did not require a photographic record to be made of a lineup in 

which a filler was selected (Hickey Dep., pp. 260-267). The written policies did not 

provide guidance on what had to be reported in the event of a lineup procedure in which a

filler was selected. In addition, police were permitted to confirm to a person viewing a 

lineup that they had picked the correct person during the lineup procedure. There appear 

to be no written policies in effect in 1988 that governed the conduct of photographic 

lineups. Photographic procedures appear in 2003 amendments to GO 88-18.

x Failure to document and transmit investigative information. The investigative file 

reflects a pronounced failure by defendants to document investigative information. Oral 

communication of information during a homicide investigation is insufficient. A written 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 22 of 433 PageID #:15443
20

record is necessary to communicate relevant information among investigating personnel 

in order to identify suspects and develop evidence leading to the apprehension of the true 

perpetrator of the crime. All potentially pertinent information must be recorded because 

the investigator will not know at the time information is received that it is or is not 

important to the ultimate case. Contemporaneous documentation is critical to ensure that 

information is accurately recorded and communicated. Finally, the requirement of 

disclosure of investigative materials to the criminal defendant and criminal defense 

attorney (Brady rule) requires documentation of investigative information. A lack of 

documentation suggests a departure from standard police practices, a failure to 

investigate, a suppression of evidence, or a combination of these things. The following 

were not produced in the investigative files I have reviewed:

o Withheld notes, GPRs, investigative reports and activity forms of Gang 

Crimes Officers involved in the investigation. As explained below, any 

investigative materials in the investigative file produced by the Gang Crimes 

Specialists involved in the Valentin investigation were never produced, with the 

exception of a couple of reports by Guevara. Investigative activities of gang 

crimes officers should have been reported to superiors and the criminal justice 

system.

o Withheld documentation of investigation between 9/2/1988 and 9/14/1988.

Virtually no chronological documentation of investigative steps taken between 

9/2/1988 and 9/14/1988 was produced as part of the investigative file. Based upon 

the material made available by the defendants, the investigation was “shut down” 

on or about 8/31/1988 when it appeared that Felix Valentin would survive. Only 

after his death on 9/14/1988 were events and documents generated to belatedly 

make it appear that officers had actually been conducting a real investigation. 

There is no documentation of investigative steps taken during the 2 weeks that the 

investigation was dormant. There is no explanation or justification for the lack of 

continuity in this homicide investigation. Detectives McLaughlin and Leonard 

began the investigation, but it was soon taken over by gang specialists who should 

have only been providing assistance regardless of whether Valentin survived.

There is no record of any meaningful supervisory oversight apparent from my 

review of the materials, other than signing documents.

o Withheld documentation of steps to locate Orlando Lopez. The defendants 

state in various police reports that they were having trouble locating Orlando 

Lopez, but no documents were produced to reflect investigative steps undertaken 

by defendant investigators to locate Lopez between 8/30/1988 and 9/15/1988. In 

an investigation such as this one, investigators would have been making efforts to 

contact Lopez, and the results of that search are relevant to the investigation as a 

whole (for example, if Lopez was actively evading contact with the police, his 

status as a reluctant witness may be pertinent to the prosecutor or criminal 

defendant).

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 23 of 433 PageID #:15444
21

o Withheld documentation of the reasons that Rodriguez and Nieves were 

excluded as suspects. As discussed, no investigative materials were produced 

that reflect any reason that Rodriguez and Nieves were excluded as suspects. 

There are similarly no materials in the investigative files showing that either 

individual’s alibi was checked or confirmed. There are no materials reflecting any 

interview or police interaction with Rodriguez or Nieves, with the exception of 

Rodriguez’s 8/31/1988 arrest. A decision to stop pursing a suspected perpetrator 

must be documented in the homicide file. In fact, there is very little 

documentation anywhere in the file about the apparent parallel investigation into 

Rodriguez and Nieves. Based on my experience, I would expect that investigators 

would have documented the reasons that Rodriguez and Nieves were excluded as 

suspects.

o Withheld documentation or recordings of interviews with or statements of 

witnesses and the victim. No documents or recordings of interviews or 

statements of individuals relevant to the investigation have been produced as part 

of the investigative file, including Mr. Rivera’s family, employer, and co-workers 

(regarding his alibi, work schedule, relationship with the victim and witnesses), 

individuals frequenting the Humboldt Park baseball fields, Marilyn Lopez (Israel 

Valentin’s girlfriend), Orlando Lopez’s friends, family, teachers, or others who 

might have shed light on his reliability as a child witness (see below), interviews 

with Israel Valentin or Felix Valentin after 9/1/1988 (with the exception of 

Guevara/Gawrys’s purported 9/10/1988 photo identification), the corner store

clerk to whom Lopez ran during the shooting, the driver who took Felix and Israel 

to the hospital, hospital staff, and family and friends of Felix Valentin. These 

interviews would be a starting point in a homicide investigation and I expect that 

they would have both occurred and been documented by the assigned personnel.

o Withheld reports of tips and leads. A typical homicide investigation will 

contain numerous tips that should be investigated. There are notably few tips 

documented in the investigative files in this case.

x Improper use, interaction, and influence of juvenile witness. The sole eyewitness and 

only evidence connecting Mr. Rivera to the murder of Felix Valentin was 12-13 year old 

Orlando Lopez. As discussed, relying on a single child eyewitness in support of a 

homicide charge, under the circumstances presented here, is unprofessional absent 

corroborating evidence. Established police practices dictate that juvenile witnesses should 

be treated with extreme care. There is no evidence that such steps were undertaken in the 

Valentin investigation regarding Lopez.

o Vulnerability/susceptibility of juvenile witness. Lopez was 12 years old at the 

time of the investigation and 13 years old at the time of trial, making him less 

reliable, and also susceptible to manipulation and suggestion. As discussed, 

mistaken identifications occur at a higher rate with juvenile witnesses. All 

interviews and identification procedures performed with juvenile witnesses must 

occur in a non-leading format with results carefully documented. As discussed, in 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 24 of 433 PageID #:15445
22

this case, Lopez testified that he stated to police at a physical lineup that Mr. 

Rivera was not the perpetrator after identifying Mr. Rivera in a photograph. That 

information should have been documented and Lopez should not have been 

compelled to make an identification following that statement.

o Presence of parent/guardian. There is no documentation of the presence or

absence of a parent at any of the police interactions with Lopez. Absent such 

documentation, we must assume that there was no parent present at any of his 

numerous interactions with police.

o Initial statement and subsequent statements of juvenile witness. Lopez’s 

statements and testimony about his observation of Felix Valentin’s shooting have 

changed over time. It is especially important in the case of a juvenile witness to 

document carefully, preferably by recording audio/visual, all statements of a 

juvenile witness about the nature of a crime, particularly the initial statement. For 

example, 11 shots were fired at Valentin in rapid succession, but Lopez has 

testified that he was able to observe the beginning and the end of the shooting, 

while running to a corner store to tell a clerk to call the police as the shooting was 

occurring. This is an unreliable account on its face. It also contradicts the police 

record described above. In a case where an eyewitness is the only evidence 

connecting a perpetrator to a crime, all descriptive statements given by that 

eyewitness of the perpetrator must be completely and accurately reported, 

particular in the case of a juvenile witness. Inconsistencies in child statements 

should not be ignored; rather, discrepancies must be explored with witnesses, and 

the results of that follow-up investigation carefully documented.

Additional examples and issues of the failure to conduct a thorough and professional 

investigation to either bolster or eliminate suspects include, but are not limited to:

x Street nomenclature (North vs. West)

x Family relationships (Israel referred to as father rather than brother at one point)

x Orlando Lopez identified at one point as Orlando Rivera

x Corruption of physical evidence (shell casings (5) co-mingled and placed in single 

bag, bullets recovered at autopsy co-mingled and placed in single bag)

x Ballistic analysis missing or not done (no comparison of ballistic evidence with 

known weapons, no comparison with open or closed Chicago cases, no comparison 

with regional, state, or federal data bases)

x Failure to process and document crime scene, vehicle, and clothing (no

documentation of Rivera’s, Rodriguez’s, or Nieves’s owned or accessible vehicles, 

although autopsy found 11 wounds, only 5 shells recovered from scene, failure to 

examine, document, and photograph “line of sight” positions and angles)

x No attempt to locate suspect vehicle (stolen/missing vehicles, impounded vehicles, 

similar vehicle description in other similar or nearby crimes, area accident reports, 

investigation of incorrect vehicle, failure to include traffic accident/collision report 

#K875-233)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 25 of 433 PageID #:15446
23

x No review or retention of incoming 911 call recording(s) or dispatch or responding 

unit call recordings

x Utilization of silencer suggested, but no follow-up

x Reason for Felix and Israel Valentin’s visit was supposed to be to pick up Israel’s 

girlfriend. Why didn’t she come downstairs with Israel since no shots were heard? If 

she did, what did she see?

x Missing and merging of investigative dialogue often precludes ability to actually 

know which officer (who) did what, when, where, how and why

x Partial documents (blank “Inventory of Things Seized in Search” (warrant return), no 

“Search Warrant” in files)

x No attempt to address the classic “motive-means-opportunity” criteria.

o Did the suspect have any animosity towards, or confrontational history (motive) 

with, Felix Valentin?

o Did the suspect own or have easy access (means) to the murder weapon, or own 

or have access to the type of vehicle used in the shooting?

o Did the suspect have a witness, or witnesses that would place him elsewhere (lack 

of opportunity) at the time of the shooting?

Nowhere in the investigation did officers inquire into, or establish and/or address any of these 

basic items.

The defendants in this lawsuit will undoubtedly claim that any “minor” oversights, 

inconsistencies, or mistakes were unimportant. The record does not support any of those 

conclusions and instead demonstrates ample departures from standard and accepted police 

practices. Any reviewing supervisor should have immediately noted the telltale signs of such.

As initially stated, there exists a broad range of literature, accepted policies and practices, 

and professional references that accentuate many of these shortcomings.

IV. Failures in CPD’s internal investigation and disciplinary processes allowed 

Defendant Reynaldo Guevara to engage in the sort of investigative misconduct 

alleged here

As described in detail below, Defendant Guevara’s misconduct in the Jacques Rivera 

case and all other cases is a direct result of the CPD’s failure to meaningfully investigate, 

supervise, or discipline him.

The community policing philosophy depends on the integrity of the police department. If 

the public lacks confidence in the agency’s ability and commitment to investigate and prosecute 

officer misconduct, there is little hope for successful partnerships and problem-solving.

Police departments must walk a delicate balance when supervising their officers. On the 

one hand, police officers must employ great authority and a fair amount of autonomy to 

effectively carry out their duties. On the other hand, every police department understands that 

autonomy plus authority, absent sufficient supervision, will generate abuse of that power, 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 26 of 433 PageID #:15447
24

ultimately leading to violations of civilians’ constitutional rights. This is a fundamental concept 

of policing – that a healthy police department will always deploy resources to supervising police 

officers to prevent abuse of police powers. 

That supervision can be carried out in a variety of ways, including an active and efficient 

internal affairs department, direct supervision by superiors, and reviews of both of these systems 

by the department and/or municipal authorities and/or agencies to ensure that the supervision is 

effective. A breakdown in the oversight by the department not only fails to deter the 

unsupervised officer from committing misconduct, it also sends a message to all other officers 

and detectives that they will be provided similarly lax oversight, emboldening those officers to 

believe if they abuse citizens they will not face meaningful discipline from the department. 

How police officers are disciplined for acts of misconduct affects the culture of policing 

within the police department and among police officers. An agency that implements or in 

practice demonstrates substandard mechanisms for police supervision and/or discipline invites a 

culture in the department where officers know that they cannot or will not be held to accepted 

standards in the event of oversights or misconduct in investigation and the performance of other 

job duties. That culture in turn may lead to circumstances where there is little incentive for sworn 

officers in the department to report or to attempt to address problems with police officers within 

the department. Once a culture of relative lawlessness or non-reporting is established and 

entrenched within a police department, a concerted effort will be necessary to reform that 

culture.

Moreover, how police officers are disciplined for acts of misconduct affects how the 

community views the police and how the police view their job. An agency or individual that 

routinely fails to take proper action when discovering that its officers have committed acts of 

misconduct will eventually lose its credibility in the community. Intuitively we can see why. If

officers feel that the discipline system gives them no reason to obey the rules, some of them will 

not obey the rules. The public may see the results in more acts of police misconduct. Likewise, if 

officers view the agency’s discipline as capricious or oppressive, they will often avoid the work 

that generates the most complaints: citizen contacts. (Community Policing Dispatch – August 

2008)

In the case of Detective Guevara, both the Department’s dedicated internal affairs system 

and his direct supervisors failed for decades to meaningfully investigate or discipline Guevara’s 

pattern of gross misconduct in violating numerous citizens’ constitutional rights, including 

Jacques Rivera’s. Any worthwhile investigation would have uncovered widespread abuses, 

particularly given that Detective Guevara is refusing to testify about any of the over one hundred 

documented allegations of misconduct, for fear that truthful responses would implicate him 

criminally. While invoking silence may not be admissible at a criminal proceeding (and I offer 

no opinion on that), silence certainly can be an indicator of wrongdoing during internal 

investigations. 

As far back as April 1986, Detective Guevara was accused of punching a civilian, 

threatening him, and using racial slurs in front of two witnesses. CR # C150473. After 

conducting an investigation, the complaint against Guevara was sustained, but inexplicably, the 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 27 of 433 PageID #:15448
25

Superintendent altered the result to “not sustained” for no apparent reason. If an investigation 

yields evidence that misconduct occurred, as in this case, discipline must be imposed. If new 

evidence comes to light that warrants reversing the initial decision to impose discipline, then the 

new evidence, or at least the reason for departing from the decision to impose discipline, must be 

documented. It almost goes without saying that when a police officer is caught committing 

misconduct but suffers no consequences, the effect on the officer is even worse than if the officer 

had not been apprehended in the first place – the officer learns that the internal affairs system has 

no teeth, and the system fails to serve as a deterrent regarding future misconduct. 

Again in 1986, Guevara arrested a man for narcotics possession, released him for some 

unknown reason, and was accused of striking him in the head several times. CR #C152902.

Guevara received a 2 day suspension for failing to fill out a battery report and releasing someone 

who had committed a crime. (These circumstances are similar to reports about Guevara in the 

FBI 302, discussed in detail below). Although this internal investigation occurred weeks after 

Guevara was accused of striking a different arrestee and of improper use of a weapon, very 

serious allegations themselves, and months after the April 1986 allegations, the internal 

investigation does not reference the repeated allegations against Guevara. CR #C152612. The 

failure to take into account prior similar incidents of misconduct when conducting an internal 

affairs investigation is a recipe for disaster. One of the initial steps any qualified detective takes 

when conducting a criminal investigation is to check the criminal history of a suspect, including 

not only convictions but also arrests as well, to determine whether a pattern of behavior is 

indicated. The same is true for any competent internal affairs investigation. But the CPD’s 

internal affairs department, as a matter of policy (Klimas Dep, pp. 90-91, 93), did not consider 

other complaints when determining if a particular citizen’s complaint of misconduct had merit. 

Also in the early 1980s, Annie and Bernard Turner alleged that Guevara used excessive 

force against them for smoking on a city bus (CR #124631). Although medical evidence 

supported the Turners’ allegations, the officers present denied misconduct, claiming that Annie 

Turner resisted arrest and was injured as a result. According to the records, however, Annie 

Turner was never charged with resisting arrest or anything other than smoking on a city bus. This 

discrepancy is not noted by the internal affairs investigators. Despite credible evidence

supporting the Turners’ claim, the complaint was not sustained.2 The message that is sent by not 

disciplining police officers caught violating citizens’ rights is that they are free to offend again 

without fear of reprisal.3

Similarly, in 1982, complainant Almarie Lloyd stated that Guevara and two other officers 

entered her home without a warrant (CR #125360). Although three witnesses apparently

corroborated this version of events, there is no record that I have been provided that Guevara 

received any discipline whatsoever for his conduct. 

 

2 Investigators treated allegations brought by a police officer against Guevara differently than complaints 

by civilians, so long as the complaint did not criticize Guevara’s on-duty actions. In CR # C251502, 

Guevara was suspended 20 days for threatening to harm a police sergeant who ticketed Guevara’s car. 

3 CPD’s internal affairs sustained rate of 2-3% is extremely low (Klimas Dep., p. 64), and supports the 

conclusion that Guevara was emboldened to commit misconduct by CPD’s refusal to provide supervision 

and discipline.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 28 of 433 PageID #:15449
26

Further, Guevara was the subject of two complaints of domestic violence, both in 1996 

and 1998. CR #C223928 and #C248946. The way the CPD handled these complaints is 

instructive. In both incidents, Guevara was accused of physically striking members of his 

household. One of the allegations was sustained, the other was not. These are criminal acts, and 

should have been referred to the prosecutor for potential prosecution. Instead, Guevara simply 

received a 3 day suspension. Favorable treatment by the CPD of criminal acts committed by 

Guevara furthers the impression that Guevara was led to believe that he could break the law and 

not face consequences for his actions. 

I find further support for the lack of investigation and/or supervision/discipline of 

Guevara in the FBI 302 report of Mohammed Omar produced by the FBI during the 

investigation of CPD Gang Crimes Specialist Joseph Miedzianowski (JR-L 44169-41183). In 

that report, witnessed by a member of the CPD’s internal affairs division, Omar reported that he 

knew Guevara, and that Guevara’s “policy” was to catch a person with drugs or guns, but let 

them buy their way out of trouble. Further, Omar reported that Guevara “accepted bribes to 

change positive or negative identifications during line-ups for murder cases.” Omar provided a 

specific example of two cases where Guevara was implicated in fixing the cases in conjunction 

with an attorney Boyke, whom Omar said was a friend of Guevara’s. Omar’s information about 

Boyke’s relationship to Guevara appears to be accurate, and his detailing of the criminal 

enterprise run by himself and Miedzianowski is supported by their federal convictions for the 

same (Beuke Dep., pp. 44, 66-67, 68-69, 69, 73-74) (Complaint, Maysonet v. Beuke, Bates No. 

JR-L 040987-040999, ¶ 3-4, 6, 28, 30, 46). Nonetheless, the record presented to me is devoid of 

any follow-up investigation of Omar’s report (Klimas Dep., pp. 6, 12-13). There is no indication 

that Guevara was questioned, that IAD tried to question Boyke or find the two people 

specifically mentioned as having cases that were fixed by Guevara. These are the most 

fundamental steps that must be taken in any internal investigation, let alone one where the 

accusations are so serious. If true, what Omar is alleging is not only a terminable offense, it is 

also criminal. Nevertheless, it is not acceptable for a department to abdicate investigative 

authority to a prosecuting agency. Prosecutors seeking criminal charges have an entirely 

different standard of proof and purpose than a police agency looking to ensure that its police 

officers are not victimizing its citizenry. Regarding the suggestion that no follow-up was 

conducted because Omar was deemed not credible (Klimas Dep, pp. 6, 12-13), I find that 

suggestion contraindicated by the 16-page detailed report created by the FBI as a result of the 

interview with Omar, in which Omar freely details his own criminal involvement as well as those 

of Miedzianowski, Guevara, other civilians and other Chicago police officers. To discount 

wholesale a witness’s account of such extreme police misconduct without conducting any 

follow-up investigation is wholly unacceptable by reference to accepted police practices and 

administration standards. Furthermore, if an investigation was not conducted because the 

complainant was not credible, that determination itself should be documented so that there is a 

record for any future inquiry as to why no investigation was undertaken. The lack of a 

documented explanation for why no investigation was conducted into these serious allegations 

suggests that no explanation exists to justify not investigating Omar’s allegations.

The CPD’s refusal to investigate, supervise, and/or investigate Guevara is apparent in 

relation to State Representative Delgado’s April 2001 formal complaint with CPD regarding 

seventeen cases in which Guevara was alleged to have provided false testimony in court (CR 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 29 of 433 PageID #:15450
27

#C270916). The CPD conducted no investigation. The CPD did not even bother to record the 

names or case numbers of the seventeen cases. CPD’s only response to Representative Delgado’s 

complaint was to wait for the State’s Attorney’s Office to conduct its own review of the 

seventeen cases. A single ASA claimed to have reviewed fourteen of the seventeen cases less 

than two months later and reported finding no improprieties. There is no record of what that 

assistant state’s attorney did to determine whether any improprieties occurred. Further, there is 

no record that the remaining three cases were ever reviewed; the only reference to those cases is 

that the assistant state’s attorney could not find the records for those cases. No record of the 

state’s attorney’s investigation was ever obtained by the CPD. Guevara was never questioned 

about the seventeen cases by the CPD, which is a departure from accepted practices. As stated 

above, it is wholly unacceptable to abdicate responsibility for investigating misconduct by a 

Chicago police officer to another agency.

The CPD’s lack of response to Representative Delgado’s complaint is troubling in a 

number of respects, not the least of which is that the complaint was pending at the very same 

time that Omar provided his similar allegations of gross misconduct by Guevara. The fact that 

CPD refused to even so much as begin an investigation into contemporaneous serious complaints 

against Guevara coming from such diverse sources as a State Representative and a cooperating 

federal informant, indicates that the CPD was actively avoiding any investigation that might 

reveal misconduct by Guevara. Coupled with the CPD’s refusal to investigate Hunt’s allegations 

(see below), Dorsch’s allegations (see below), and overturning a sustained finding against 

Guevara for no apparent reason, I find that the CPD evinced a long-standing refusal to

investigate or discipline Guevara in any meaningful respect, that began in the mid-1980s and 

continued until his retirement in 2005. 

The systemic lack of investigation and/or supervision/discipline is also present in the 

City’s failure to investigate Leshurn Hunt’s civil lawsuit against Guevara, filed in 1985. Hunt 

claimed he suffered excessive force and other civil rights violations committed by Guevara and 

other officers during his arrest and interrogation. Hunt sustained injuries and his confession was 

suppressed by the criminal court. In that lawsuit, according to the court, Hunt “identifies five 

recent occasions on which the police defendants in this case were accused of undertaking 

warrantless home searches, and nine recent occasions on which they were accused of using 

excessive force during arrests and interrogations.” Hunt v. Jaglowski, 85 C 1976, 665 F.Supp.

681 (July 21, 1987). I see no indication that the CPD conducted investigation of the allegations 

raised, despite a lawsuit being filed against Guevara and a number of court opinions regarding 

the case being published. This is unacceptable under any standard of internal affairs 

investigations. 

I find further support for the lack of investigation and/or supervision/discipline in both 

the sheer number of similar allegations lodged against Guevara as well as the confirmed acts of 

misconduct he committed. For a police detective to have one confirmed case of framing an 

innocent man is abhorrent; for it to occur repeatedly, it is evidence of a complete failure of 

supervision and that fellow officers turned a blind eye or condoned the misconduct. 

Specifically, in 1989, Guevara framed Juan and Henry Johnson for murder by inducing 

one man to get other men to falsely implicate the Johnson brothers in the murder. The circuit 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 30 of 433 PageID #:15451
28

court eventually overturned Juan Johnson’s conviction and he sued (Complaint, Johnson v. 

Guevara, case no. 05 C 1042). Guevara was found liable for framing Juan Johnson and ordered 

to pay $21,000,000 as compensation to Johnson. (Verdict Form, Johnson v. Guevara, case no. 05 

C 1042)

In or around 1988-1990, CPD detective William Dorsch alleges that he witnessed 

Guevara tell a juvenile witness whom to select from a photo array (Dorsch Dep., pp. 320-360). 

Recognizing the obvious impropriety in Guevara’s misconduct, Dorsch brought the incident to 

his supervisors’ attention. Instead of disciplining Guevara (intentionally interfering in an 

identification procedure in a murder case could justify termination), the supervisors covered up 

the wrongdoing by instructing Dorsch to classify the case as cleared/closed, so that no further 

investigation would be conducted. There is no record of any follow-up investigation conducted 

by any supervisor or member of the internal affairs division to determine if Guevara in fact 

interfered in an identification procedure conducted during a homicide investigation. 

The City of Chicago has also determined that, in 1993, Guevara was responsible for 

obtaining the convictions of Jose Montanez and Armando Serrano for murder, despite their 

innocence. According to the report issued by former Federal Prosecutor Scott Lassar of the law 

firm Sidley Austin, which was retained by the City of Chicago after the filing of this lawsuit to 

conduct an investigation of Guevara in order to examine its liability, among other things,4

Guevara induced a man facing several serious felony crimes to falsely implicate Montanez and 

Serrano, causing them to spend over twenty years incarcerated for crimes they did not commit 

(Lassar Report regarding Montanez and Serrano, Bates No. CCSAO 46099-46156).5

Subsequently, the appellate court reinstated Montanez and Serrano’s case, and then both 

Montanez and Serrano were granted certificates of innocence (People v. Montanez, Ill. App. 2d. 

(1st Dist. 2016); Orders Granting Certificates of Innocence, People v. Serrano and People v. 

Montanez). 

The City of Chicago has determined that in 1994 Guevara also caused Roberto 

Almodovar to be wrongfully convicted of murder as an innocent man. In the Almodovar case, 

Guevara was again accused of inducing witnesses to falsely implicate Almodovar and his codefendant, William Negron. Guevara’s explanation for how he came to suspect Almodovar– that 

Guevara thought Almodovar’s photograph appeared similar to a description of the shooter that 

was not provided until after Guevara made Almodovar a suspect defies common sense. I am not 

making a credibility determination here; rather, I note that a police officer cannot claim that a 

photograph matches a description that does not exist at the time the photograph was selected as 

the suspect. I further note that, when questioned about this case at his deposition, Guevara took 

the Fifth rather than respond to questions about his alleged misconduct, lending further support 

for the opinion that Guevara’s conduct in that investigation contradicted accepted police 

practices (Lassar Report on Almodovar, Bates No. CCSAO 43718-43732). 

 

4 The City’s efforts to investigate Guevara, through Scott Lassar, did not come until long after Guevara 

retired and had no effect on preventing Guevara from victimizing other people.

5 In a similarity to the Rivera case, detectives in the Montanez/Serrano case, investigated by Guevara, 

pulled the rap sheets for all three of the men eventually charged in the murder – Montanez, Serrano, and 

Pacheco – on May 25, 1993, although no one implicated them in the murder (or any other crime) until 

June 2, 1993. Like the Rivera case, this is shown by issued on inquiry date stamps on the rap sheets.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 31 of 433 PageID #:15452
29

The City of Chicago determined that in May 1993 Guevara caused Robert Bouto to be 

wrongfully convicted of murder. In that case, Guevara is alleged to have induced several 

witnesses to falsely identify Bouto as the shooter. Although Bouto’s alibi witnesses have 

consistently maintained that he was not present at the shooting, from the time of his trial to the

present, all of the witnesses selected Bouto at line-ups conducted by Guevara. Those witnesses 

maintain that Guevara allowed them to see Bouto at the police station before the line-up was 

conducted, negating the neutrality of the line-up (Lassar Report on Robert Bouto, Bates No. 

CCSAO 30301-30344). 

The City of Chicago also determined that in April 1998 Guevara used physical force to 

coerce Arturo Reyes and Gabriel Solache to involuntary confess to murder (Lassar Report on 

Reyes and Solache, Bates No. CCSAO 43655-43673).6 Based on evidence of Guevara’s 

misconduct, Solache and Reyes have been granted a new suppression hearing by the criminal 

court (Order in People v. Reyes dated June 29, 2016). 

In 1996, the appellate court overturned the conviction of Xavier Arcos in a published 

opinion. That opinion reported that, in 1991, a witness was induced to falsely implicate Arcos by 

Guevara, who was alleged to have fed him details about the crime in order to frame Arcos. 

People v. Arcos, 282 Ill. App. 3d 870, 873-74 (1st Dist. 1996). I see no record that Guevara was 

ever questioned or investigated despite the courts overturning a murder conviction on grounds 

that he fed false information to the witness, which is a grave departure from accepted practices.

The fact that Guevara committed so many repeated serious transgressions during 

homicide investigations, resulting in the wrongful prosecution and conviction of innocence 

individuals, indicates to me that his supervising and fellow officers turned a blind eye to his

misconduct. This evidence is consistent with the existence of a code of silence within the 

Chicago police department, dating back to the Jacques Rivera investigation in 1988, and 

continuing at least until 2007, when a federal jury determined that the CPD had a code of silence, 

wherein police officers would not report misconduct committed by fellow police officers. 

Obrycka v. City of Chicago, 913 F. Supp. 2d 598, 603-04 (N.D. Ill. 2012). In addition, these 

repeated serious transgressions – discovered apparently without much investigative effort during 

an investigation performed recently by Lassar at the City of Chicago’s request – demonstrate that 

the City of Chicago and the Chicago Police Department, including its IAD and other supervisory 

agencies, failed to adequately investigate, supervise, and/or discipline Guevara over the course of 

his career.

Conversely, I find no support for the proposition that Guevara was receiving appropriate 

supervision or discipline. The failure to even question Guevara about the allegations listed 

above, including allegations from Omar, Hunt, and Representative Delgado, but also the various 

other cases where citizens accused Guevara of misconduct, is even more pronounced given 

Guevara’s refusal to testify about these incidents on grounds that truthful responses might 

subject him to criminal liability (Guevara Dep.). When he was a police officer, the CPD could 

 

6 Lassar reached this conclusion despite drawing no inference from Guevara and another officer’s refusal 

to speak about their activities as Chicago police officers and their interrogations of Reyes and Solache 

(Lassar report on Reyes and Solache, footnote 1). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 32 of 433 PageID #:15453
30

have forced him to provide truthful responses under Garrity, and, given his invocation of the 

Fifth Amendment, it is likely those responses would have uncovered Guevara’s misconduct. But 

by not even questioning Guevara in so many of these cases, the CPD failed to even begin the 

process of ferreting out Guevara’s wrongdoing and, by extension, allowed it to perpetuate for 

decades. 

Supervision of Guevara was hampered by the CPD’s refusal to implement any type of 

early warning system (Klimas Dep., p. 76). The need for an early warning system to alert a 

police department to problem officers before they violate citizens’ rights was well-established in 

policing long before 1988. An effective early warning system would have tracked Guevara’s 

serious allegations of misconduct lodged against him prior to 1988, and would have required 

supervisors to consider the allegations against him in conjunction with each other, rather than as 

separate and discreet acts. An effective early warning system in place prior to 1988 would have 

communicated to Guevara, and all other police officers in Area 5, that transgressions would be 

exposed and responded to harshly, in effect deterring Guevara from committing the misconduct 

that marked his career from 1988 onward. Indeed, a federal jury found that the CPD had a 

widespread practice of not supervising or disciplining police officers as late as 2007. Obrycka v. 

City of Chicago, 913 F. Supp. 2d 598, 603-04 (N.D. Ill. 2012). The record before me is 

consistent with that verdict, and I have seen nothing to suggest that CPD maintained an effective 

disciplinary or supervisory system from 1982 onwards. 

V. The CPD’s policies and practices related to the creation, maintenance, storage, 

preservation, and disclosure of investigative material deviated substantially from 

generally accepted police practices

Police departments have long recognized the need to ensure that information and 

evidence collected during a criminal investigation is properly documented, stored, and ultimately 

disclosed for use in the criminal trials. The standard practice is relatively straightforward, and 

consists of a few key components: (a) requiring investigating officers to document the 

information they learn during the course of an investigation; (b) collecting, inventorying, and 

maintaining all of the investigative materials and information, in one central location; (c) 

applying policies or guidelines to ensure that the investigative material in the central file is 

disclosed to prosecutors and criminal defendants in response to formal requests for information; 

and (d) administering training and monitoring around all of these issues to ensure the policies are 

followed. 

CPD did not comply with these standards, instead allowing detectives and other 

investigating officers like gang crimes officers to utilize multiple, parallel files for each 

investigation. The use of parallel files itself creates a significant risk that important investigative 

materials will not be disclosed, but that risk was exacerbated by the CPD’s failure to provide any 

training or policies regarding proper response to subpoenas and discovery requests. The result is 

predictable: a routine failure to disclose all relevant investigative materials to criminal 

defendants. 

CPD’s problem of failing to turn over all relevant materials was brought to light by two 

federal cases in the early 1980s, but despite being acutely aware of the problem, CPD did little to 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 33 of 433 PageID #:15454
31

address the practice. The policies it issued were a superficial attempt to resolve the problem and 

were deficient on their face – as they still allowed, and even required, multiple, parallel files to 

be created for each investigation. Moreover, CPD took almost no steps to train, supervise, or 

implement those policies. Finally, the policies did nothing to ensure that there was a system in 

place to properly respond to subpoenas and discovery requests. 

I have reviewed numerous Chicago homicide files, including police investigative files 

and corresponding criminal defense files and permanent retention files. This includes such files 

produced in this case, as well as other cases against the City of Chicago (e.g., Fields v. City of 

Chicago, Kluppelberg v. City of Chicago).7 My review has confirmed that because of the 

deficient policies and widespread practices described above, criminal defendants were routinely 

denied substantive and relevant investigative materials related to their criminal cases, and that 

the written policies did little to alter the ingrained practice of keeping clandestine, parallel files. 

Finally, I reviewed the material that was withheld from Mr. Rivera during his criminal 

trial and concluded that the information was withheld as a result of the same set of practices and 

policies (or lack thereof), and contained relevant and important investigative materials that 

should have been disclosed under standard police procedures.

A. Standard police practices for maintaining and disclosing investigative files 

requires a single, comprehensive file 

Every police department in the country must address how to properly document their 

criminal investigations. All information and evidence from an investigation must be properly 

collected, documented and preserved so that it can be disclosed to prosecutors and criminal 

defendants for use in criminal trials. 

The standard police practice, across the country, is relatively straightforward: a lead 

detective is assigned to every major investigation, and that lead detective is in charge of 

compiling all investigative materials in a single centralized location. This includes investigative 

material generated by investigators in specialized units like gang crimes, bomb and arson and 

others. Although multiple detectives and specialized investigators may work on an investigation, 

all information must be centralized and organized. These standards are in place to help police 

officers effectively solve crimes: they ensure that, during the investigation, information is not 

lost because it is dispersed among various investigators and that the information is organized and 

stored so that a supervisor or other investigators can locate and understand the evidence collected 

by their colleagues. This standard police practice also ensures that once charges are filed, 

everything that does exist from the investigation is complete, identifiable, inventoried, and 

 

7 In both Fields and Kluppelberg, I examined investigative files maintained in the Chicago police 

department to evaluate the written policies and practices of the Chicago of Chicago, and in Fields I

compared those investigative files to criminal defense attorney files to evaluate what materials were 

disclosed by the Chicago Police Department in the course of criminal investigations and prosecutions. I 

rely on those file examinations and comparisons in this report, and I intend to opine in this case about my 

findings in both Fields and Kluppelberg. The expert reports submitted in both cases are included as 

Attachment H and I, along with their respective attachments setting out the results of my examination and 

comparison.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 34 of 433 PageID #:15455
32

maintained in its entirety in a central location. Whether it is referred to as an investigative file, a 

“murder book,” a completed investigation, an open investigation, or something else, everything 

should be in one package that can be located and produced – for whatever reason it is needed.

Standard police practices also require the disclosure of all investigative material in the 

police file, whether centralized (standard, and preferable) or not. There should not be picking and 

choosing. Performing these disclosure requirements is not an informal practice; it is done 

pursuant to written policies and procedures, in conjunction with training on those policies and 

procedures, to ensure compliance to this crucial step in ensuring fair trials. As a practical matter, 

this disclosure for use in a criminal case usually occurs in one of two ways: either the police 

fulfill their obligations by disclosing their entire investigative file to the prosecutor (rather than 

picking and choosing which parts of a file to disclose), who in turn disclose it to the criminal 

defense attorney; or, in some cases, independently and as a safeguard, the criminal defendant or 

his counsel will subpoena the police investigative materials directly. In response to the subpoena, 

all investigative materials should be disclosed.

It is also standard police practice to keep and catalogue every document or piece of 

information pertaining to an investigation. The police investigative role is to search for and 

document facts – all facts regardless of where those facts fit into some pre-conceived theory of 

the investigation. Not all facts, information, or individuals will necessarily enhance the 

prosecution of an identified suspect. Nonetheless, those facts have to be included in the 

investigation– to help prevent tendencies like tunnel vision, and also in fairness to the victims, 

the prosecutor, the defense, the court, and the jury. The judge will eventually rule on what is 

relevant and admissible. And investigators routinely offer explanatory information that puts that 

information in perspective, or explains why the detectives gave it little weight. But based on my 

experience, police officers are expected to, and are specifically trained on the importance of 

preserving all investigative materials and including those materials in a centralized location. 

Police departments typically emphasize this point because, in order to meet the needs of police 

agencies and the courts, case files must be maintained in a manner that make them secure but 

accessible, and the case contents should be arranged in an orderly and consistent manner. 

As a corollary, all of the information must be inventoried, indexed, or documented in 

such a manner as to be easily located and so that the content of the inventory is clearly 

understood. To that end, a copy of the investigative file inventory will typically be placed in an 

official police department file so that the department can maintain a single, accurate list of all 

available material, and that inventory is typically disclosed to prosecutors and criminal 

defendants so that they can ensure that they have everything. In this way, it serves not as a 

solution to the problem of ensuring that all investigative material is disclosed, but as a necessary 

backstop to try to prevent the possibility of non-disclosure despite the existence of other policies 

and procedures.

My knowledge of these standards is based on my extensive experience with police 

practices. This includes my own experience as a detective and supervisor in multiple police 

agencies; my familiarity with the policies used by police departments nationwide, developed in 

the course of my own efforts to improve policies in police agencies in which I worked, as well as 

in the course of my work as an independent consultant and auditor reviewing policies and 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 35 of 433 PageID #:15456
33

practices of police departments around the country; and my knowledge of industry standards 

established by organization like the International Association of Chiefs of Police. These 

standards have also been documented in homicide guides and reference materials for decades. In 

addition to my own extensive experience, for a summary of some relevant texts please see 

Attachment E.

B. Jones and Palmer litigation highlight Chicago’s “Street File” problem

In the early 1980s, two federal court cases highlighted the fact that the Chicago Police 

Department had no systems in place to ensure that investigative materials were collected 

centrally and disclosed during criminal cases, and in fact important materials were consistently 

withheld from criminal defendants. 

1. The George Jones Prosecution

In 1981, twelve-year-old Sheila Pointer was raped and bludgeoned to death; and her 10-

year-old brother Purvy was beaten unconscious in their home.8 George Jones – a senior at a 

nearby high school, who edited the school newspaper and was nicknamed “Bookworm” – was 

ultimately arrested and prosecuted for the crime. During the CPD investigation of the Pointer 

murder, detectives gathered evidence that undermined the witnesses who had implicated Jones, 

and which Jones could have used to help defend himself, but this information was placed “not in 

the police department's regular files but in its ‘street files.’ These were files that the police did 

not turn over to the state's attorney's office as they did with their regular investigative files.”9

After George Jones had been charged, a detective, Frank Laverty, who was investigating 

the case interviewed the victim’s brother, Purvy, who told Laverty that there were two assailants 

and both were wearing stocking masks. Laverty also documented other strong evidence that 

Jones was not the perpetrator. That information was also placed in the street file.10 Laverty was 

told that, in light of these facts, the prosecution of Jones had been abandoned. However, in the 

spring of 1992, Detective Laverty read in the newspaper that George Jones was on trial for the 

Pointer murder.11 Laverty went to his Commander to tell him that an innocent person was being 

prosecuted, but his Commander took no action. Laverty then went directly to Jones’ criminal 

defense attorney and told the attorney about the information in the street file. After the court 

declared a mistrial, the State’s Attorney dropped all charges against Jones.12

After the charges against him were dismissed, Jones filed a civil lawsuit. He was awarded 

a substantial amount in damages for the violation of his rights. Notably, among other things, the 

jury found that the City was liable to Jones for its custom of maintaining “street files” that were 

withheld from the State’s Attorney and therefore unavailable to Jones and the rest of the criminal 

justice system.13 The Seventh Circuit explained that the practice of “retaining records in 

 

8 Jones v. City of Chicago, 856 F.2d 985, 988 (7th Circuit 1988)

9 Ibid (at 988-991)

10 Ibid (at 990-91)

11 Ibid (at 991)

12 Ibid. (at 991)

13 Ibid. (at 995-96)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 36 of 433 PageID #:15457
34

clandestine files deliberately concealed from prosecutors and defense counsel cannot be 

tolerated.”14

2. The Palmer Litigation

On April 16, 1982, shortly after Jones’ prosecution, a class of plaintiffs filed a lawsuit in 

federal court to prevent the use of street files.15 The plaintiffs immediately moved for a 

temporary restraining order (TRO). A TRO issued on April 20, 1982, and amended on 

September 24, 1982, required the CPD to preserve all street files and documents formerly placed 

in street files.16 The TRO was amended because of allegations that detectives were continuing to 

keep investigative materials as their personal property and therefore not subject to CPD 

control.17

District Judge Milton Shadur oversaw the preliminary injunction hearing. Based on the 

evidence presented by the plaintiffs and by the City of Chicago, Judge Shadur found the 

following (among other things):

x The CPD does not provide its detectives or other personnel with guidelines as to the 

extent to which “official reports” (which Judge Shadur defined as case reports, 

supplementary reports, closing reports, etc.) have to embody information in 

“unofficial reports” (defined as notes, witness interviews, worksheets, memoranda, 

etc.) In particular, Judge Shadur found that “Official Reports have sometimes been 

prepared from the perspective of what fits the preparer’s concept of the crime, so they 

omit information that – though highly relevant and sometimes exculpatory of the 

defendant charged with the offense – the preparer does not deem ‘pertinent.’”18

x The existence and use of unofficial reports is well known throughout CPD. Parallel 

files containing these reports are referred to as “street files,” “running files,” “office 

files” or “working files.”

x Potentially relevant information contained among the CPD’s various investigative 

files and materials for a particular crime is not necessarily included in official reports. 

There has been and is no police rule, regulation, procedure, or practice that requires 

all relevant information to be placed in official reports or to be transmitted to the 

CPD’s Records Division for permanent retention.19

x the CPD responds to requests for documents as follows:

q In response to a subpoena, CPD produces only official reports maintained at 

Records Division along with photographs and lab reports. CPD does not 

produce unofficial reports maintained at the Area or unofficial reports in the 

possession of individual detectives.20

q In response to a defendant’s discovery motion, Assistant State’s Attorneys 

 

14 Ibid. (at 995).

15 Palmer v. City of Chicago, No. 82 C 2349 

16 Ibid (at NF-L 005606-07)

17 Ibid (NF-L 005607)

18 Ibid (NF-L 005609-10)

19 Ibid (NF-L 005612)

20 Ibid (NF-L 005614)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 37 of 433 PageID #:15458
35

(ASAs) order official reports by phone. CPD Records Division employees 

respond to these requests by producing official reports and do not contact 

individual Areas or other units or divisions of the CPD for unofficial 

documents.21

Judge Shadur found that the exclusion of relevant information from official reports “was 

not random or infrequent.”22 In fact, by the City’s admission, there were hundreds street files in 

active use during the Palmer litigation itself. In granting the injunction, Judge Shadur found that 

the use of street files created a “grave risk” of non-disclosure of exculpatory information, 

including information that could be used to impeach witnesses.

On appeal, the Seventh Circuit reversed Judge Shadur in part, although it did order the 

CPD to preserve and produce street files for those plaintiffs who had been convicted of 

felonies.23 It vacated the preliminary injunction in all other respects because the court found that 

the plaintiffs either lacked standing or should have asked for relief in the state courts. It did not 

revisit the factual findings that Judge Shadur made.

3. The 1988 Jones Appeal

After the Palmer litigation concluded, the Seventh Circuit issued an opinion in 1988, 

Jones v. City of Chicago, 856 F. 2d 985 (7th Cir. 1988), in which Judge Posner affirmed liability 

against Chicago police officers for the withholding of evidence from Mr. Jones and affirmed 

liability against the City of Chicago for maintaining a street files practice. 

Among other things, the appellate decision noted as follows: (a) the case disclosed 

“frightening abuse of power by members of the Chicago police force and unlawful conduct by 

the City itself”; (b) Laverty was charged with a disciplinary infraction, “transferred out of the 

detective division, ostracized by his fellow officers, and assigned to a series of menial tasks 

culminating in the monitoring of police recruits giving urine samples” while “none of the 

defendants has been disciplined for misconduct”; (c) there was “enough evidence to enable the 

jury to infer that [a Chicago Police Department Commander, Lieutenant and Sergeant] had 

known . . . [and] had approved every false step”; and (d) there was sufficient evidence against the 

City that the street files practice existed, caused Jones injuries, and was “consciously approved at 

the highest policy-making level.”24

The Seventh Circuit’s decision also specifically highlighted the failure of CPD’s 

leadership, which allowed Detective Laverty to be punished for coming forward while allowing 

those who actively attempted to thwart Laverty’s efforts to reveal the truth to go without 

discipline or reprimand. Indeed, the United States Court of Appeals for the Seventh Circuit 

described the CPD’s reaction to these events as follows: 

Laverty should have been commended for his adherence to the principles of 

 

21 Ibid (NF-L 005614)

22 Ibid (NF-L 005615)

23 Palmer v. City of Chicago, 755 F.2d 560 (7th Cir. 1985); CPD Special Order 83-2A.

24 Id. at 988, 991-92, 993, 995-996.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 38 of 433 PageID #:15459
36

honesty, decency, and justice, instead the police department charged him with a 

disciplinary infraction for having failed to advise the state’s attorney that he 

planned to testify for the defense in George Jones’s criminal trial should that 

become necessary. He was also transferred out of the detective division, 

ostracized by his fellow officers, and assigned to a series of menial tasks 

culminating in the monitoring of police recruits giving urine samples. None of 

the defendants has been disciplined for misconduct in the arrest and prosecution 

of George Jones.25

These actions in effect condoned the misconduct, and sent an unmistakable message to 

CPD personnel that the priority was not solving the street file problem, but instead was 

dissuading whistleblowers from coming forward. 

Based on my experience, strong and unequivocal management commitment is needed to 

successfully achieve the sort of shift in culture that was necessary in the wake of the Jones and 

Palmer revelations; CPD leadership’s response was the opposite. I would expect, therefore, that 

the improper street files practice would continue. As discussed below, my review of hundreds of 

homicide files in this case and others (e.g., Fields and Kluppelberg) confirms exactly that: the 

street files practice continued unabated.

C. CPD personnel consistently use multiple files during a criminal investigation, 

and fail to disclose all relevant materials to criminal defendants.

As the Jones and Palmer cases highlighted, the CPD has a long history of using multiple, 

parallel files during the course of a criminal investigation, which are frequently withheld from 

criminal defendants. 

1. Multiple files are created for a single investigation, creating a serious risk 

that investigative materials are not disclosed. 

From at the latest in 197726 until at least 2009,27 the Chicago Police Department has 

maintained multiple, parallel files relating to a single investigation and has had no system in 

place to ensure that all important investigative materials from these multiple files are collected 

and provided to the prosecutors and criminal defendants. 

The only “centralized” repository of investigative information maintained by CPD is the 

“permanent retention file” maintained by the Records Division. But the CPD policy and practice 

 

25 Jones, at 991-92.

26 The City’s designated witness, in this and other cases involving the City’s practice regarding 

maintenance and production of investigative files, James K. Hickey, testified that the practice of using 

street files started at least as early as 1977, when he arrived at Area 1 homicide. Similarly, during 

hearings on the use of street files in Palmer v. City of Chicago, John Stibich, a former commanding 

officer in Area 4 homicide, testified that during his time there, from December 1974 to December 1977, 

Area 4 homicide had a practice of using street files. Following Hickey’s sampling of the various violent 

crimes units in 1982, Hickey determined that each of the Areas used street files.

27 See Attachment H, Expert Report in Fields v. City of Chicago

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 39 of 433 PageID #:15460
37

is to only include the official reports in the permanent retention file.28 This practice of having an 

“official” file that does not include all of the investigative notes, documents, and materials 

deviates from standard police practice, which would have one single repository with all the 

information. 

Instead of utilizing the permanent retention file as the central repository of information, 

CPD practice is to use multiple, parallel files while an investigation is ongoing. These multiple, 

parallel files have been variously referred to at different times as “street files” “working files,” 

“running files,” “unit files,” “Area files,” or “investigative files,” among other terms. These files 

are used by detectives and other investigating officers, while an investigation was ongoing to 

gather relevant investigative materials; to communicate steps taken and steps to be taken in an 

investigation; and to record the personal opinions of the officers investigating a crime. The files 

contained notes (sometimes handwritten on scraps of paper), memos, reports, photographs, and 

various other forms of information about the case that were developed as the investigation 

unfolded. Among other things, information in these various, parallel files included details about 

the crime and the physical evidence, information about the observations or statements of 

witnesses, identification of potential leads and suspects, and items obtained from victims or 

witnesses (e.g., a victim’s telephone book or a witness’s telephone messages). The files also 

contained other criminal history information and police reports pertaining to other cases, which 

were utilized in suspect identification and elimination.

Detectives working a case necessarily take notes during witness interviews and must 

communicate that information to other detectives. That is an inevitable and important part of an 

investigation.29 The problem with the Chicago Police Department’s practice is that these notes 

are stored across multiple files—both during and after an investigation—and are never 

consolidated into the official file which is permanently maintained by the CPD. Thus, even after 

an investigation concludes, there are still multiple files containing different sets of investigative 

materials scattered in various locations, and which are regularly withheld from criminal 

defendants. 

There are a variety of reasons that multiple, parallel files are created within the CPD 

environment:

x Multiple detectives working on the same case, each take notes, resulting in multiple 

sets of investigative materials, but there is no formal place for detectives to keep these 

notes, and as a result they are kept on tables, coat racks, in cars, in filing cabinets, or 

desk drawers in the Areas and are not collected in a central repository.30

x In 1980, the CPD was re-organized, and the Detective Division was split into six 

geographical areas (Areas One through Six) and two subject matters (Violent Crimes 

 

28 Hickey Kluppelberg Deposition [2015] 22-23, 95-96

29 Hickey himself confirms this. Hickey April 2014 Fields Trial Testimony, at 2060:16-21 (“It is just 

common sense that you do write things down because you can’t remember, you know, who said what, 

who said what when.”) Hickey November 2016 Fields Trial Testimony, at 11/23/16 PM, at 14-15

(“Taking notes is terribly important.”)

30 Palmer v. City of Chicago, 562 F. Supp. 1067, 1071 (N.D. Ill. 1983). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 40 of 433 PageID #:15461
38

and Property Crimes).31 Detectives from different divisions or units of CPD often 

investigate a case together, but report to different supervisors, and work out of 

different units or Areas, resulting in multiple files kept at the different geographical 

locations throughout the City. 

x In addition to detectives, there are many others involved in investigating major crimes 

such as homicides, including patrol officers as well as specialized unit officers like 

Gang Crimes and Bomb & Arson. Indeed, Gang Crimes Officers were heavily 

involved in the investigation in this case. Yet, no set of policies or practices governed 

the investigative practices of these additional investigators or required them to 

coordinate with the Detective Division. As a result, those investigators had their own 

sets of notes and yet more files, unknown to and uncoordinated by CPD.

x There is no centralized log of the various parallel files created for each investigation, 

and thus no way to know how many files exist or where they are located.

x Files that are kept in an Area may be moved during CPD re-organization or are 

relocated to a storage warehouse. If multiple files for the same homicide are stored at 

an Area, they are not necessarily stored or moved together, and there is no system in 

place, or documentation, for tracking the movement of these files.32

x The documents in the files at the Area are never consolidated into the permanent, 

official files stored in CPD’s centralized Records Division.

x Detectives also do not routinely transcribe all information obtained during an 

investigation into an official report, resulting in different information maintained in 

the official and unofficial documents. 

x The permanent file, kept in the Records Division, therefore, does not contain all the 

relevant and important investigative materials. 

This practice of using of multiple, parallel files creates an unacceptable risk that information will 

not be discoverable in response to a subpoena and will, therefore, be withheld from prosecutors 

and defendants. Where detectives keep their own files, or files are kept at multiple areas or units 

throughout the City, there is no way for any detective or supervisor to know how many parallel 

files have been created for a particular case, or whether they have all been collected. This is why 

standard police practice around the country is to have a lead investigator responsible for keeping 

a single, known repository of information.

2. The CPD’s ad hoc response to subpoenas exacerbates the problem

In Chicago, the risks created by using multiple files are exacerbated by the fact that the 

CPD Subpoena Service Unit, which is responsible for responding to requests for records, is 

untrained and lacks any policies governing how it responds to subpoenas and requests for files. 

According to Hickey, when a request for investigative documents is made to the Chicago 

Police Department, that request goes to the Records Division, Subpoena Service Unit.33 A

sergeant was in charge of the Subpoena Service Unit, and that sergeant reported to the assistant 

 

31 James K. Hickey Deposition in Kluppelberg v. Burge at 64 (NF-L 001004).

32 Loughran Deposition 43-44. 

33 Hickey Kluppelberg Dep 358(NF-L 001299)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 41 of 433 PageID #:15462
39

director and director of the Records Division.34 It was the Record Division director’s 

responsibility to set policy at the Subpoena Service Unit.35

The Chicago Police Department had no written policy that Hickey was aware of dictating 

how the Subpoena Service Unit should search for documents responsive to a subpoena or request 

for records.36 In addition, there were no directives addressing “policies, safe checks, [or] 

procedures . . . to ensure that when a request came in either by a subpoena or by an informal 

request from and Assistant State’s Attorney . . . that all of the necessary information including 

exculpatory information was provided by the subpoena services unit in response to that 

request.”37

The subpoena service unit was staffed by non-sworn personnel with the title “clerk.”38

There was no formal training of personnel assigned to respond to subpoenas,39 and there is no 

rule, policy, procedure, directive or any other document that guides the clerks in the subpoena 

unit to ensure that all documents are retrieved from all possible locations and disclosed, or any 

training to that effect.40 Whether all of the different units that worked on a given investigation 

were searched for documents responsive to a subpoena depended in large part on the discretion 

and experience of the personnel searching for the documents, such that a subpoena for all 

documents under a certain records number41 would not necessarily result in the production of all 

documents corresponding to that particular investigation.42 Hickey described the Subpoena 

Service Unit’s effort to respond to document requests as an “art.”43 He acknowledged that it is 

possible in a case with multiple units working on the same investigation that the subpoena could 

only go to one of those units.44

All of this was true as well with respect to requests for documents made by the Cook 

County State’s Attorney’s Office to the Chicago Police Department.45 This system was in place 

before Mr. Rivera’s conviction and well into the 2000s.46 In fact, the City’s expert on the CPD’s 

policies in 2009 explained that, even if a subpoena is forwarded to an Area or unit, there is no 

system or procedure to follow up if the Area or unit fails to respond.47

 

34 Hickey, Rivera v. Guevara, et al., No. 12 C 4428, pages 146-47 (NF-L 000312-13)

35 Ibid, pages 159-60 (NF-L 000316)

36 Ibid, pages 36-37 (NF-L 000273-74); City of Chicago’s Amended Response to Plaintiff’s Seventeenth 

Set of Requests to Produce Documents to the City of Chicago, p.2-3

37 Ibid, page160 (NF-L 000316)

38 Ibid, pages 147-48 (NF-L 000313)

39 Ibid, page 39 (NF-L 000274)

40 Hickey Rivera Deposition 36, 185-87; City of Chicago’s Amended Response to Plaintiff’s Seventeenth 

Set of Requests to Produce Documents to the City of Chicago, p.2-3.

41 A Records Division number is a unique identifier assigned to a particular criminal investigation. The 

letters represent the year that the investigation began and investigations are assigned the numbers 

sequentially as they had. 

42 Ibid, pages 43-46 (NF-L 000275-76)

43 Ibid, page 162 (NF-L 000316); Hickey Kluppelberg Deposition 362-63(NF-L 001303-04)

44 Hickey Kluppelberg Deposition 362-63 (NF-L 001303-04)

45 Hickey, Rivera, page 125(NF-L 000296); Loughran Deposition, page 50.

46 Ibid, pages 151-53 (NF-L 000314); Loughran Deposition 14. 

47 Loughran Deposition 15. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 42 of 433 PageID #:15463
40

This system, or lack thereof,48 for responding to requests for documents and producing 

investigative materials, including important investigative information, is deficient. Because there 

are multiple files in multiple locations pursuant to the special orders and CPD’s design, there is 

an acute need for policies, practices and training to ensure that all relevant information was 

produced to prosecutors and criminal defendants. The lack of such safeguards represents a 

significant departure from accepted police practices.

D. Criminal defense files show that important investigative materials are regularly 

withheld from criminal defendants

From a police practices perspective, criminal defense attorney files contain all of the 

documents disclosed and made available to the attorneys that provided counsel to defendant(s) in 

the homicide cases that I reviewed. By standard police policy and practice, criminal defendants 

should get everything that was available from the police investigation to aid the defendant in 

presenting his or her defense at trial. It would be a dangerous departure from standard police 

policies to permit a practice of picking through police files to select which investigative materials 

to turn over.

As a practical matter, this disclosure of information usually occurs in one of two ways: 

either the police fulfill their obligations by disclosing their entire investigative file to the 

prosecutor (rather than picking and choosing which parts of a file to disclose), who in turn 

disclose it to the criminal defense attorney; or, in some cases, independently and as a safeguard, 

the criminal defendant or his counsel will subpoena the police investigative materials directly, 

rather than relying exclusively on what was provided by the prosecutor. In response to the 

subpoena, all investigative materials should be disclosed.

The basic principle is that a criminal defendant is not supposed to be tried in the dark. He 

is entitled to understand the full breadth of the evidence against him; and he is entitled to any

evidence that may help him prove his innocence. As a matter of police practices, a well-trained 

detective would understand that information should be disclosed even if it is only supportive –

but not conclusive – proof of innocence. As long as information known to the police or 

prosecution might contribute to doubt about the defendant’s guilt, it is relevant and must be 

disclosed.

Based on the criminal defense files reviewed in this case, and others, as explained below, it is 

clear that these standard police practices are not followed in the Chicago Police Department, and 

as a result investigative materials that should be disclosed under normal police procedures are 

routinely withheld from criminal defendants. Moreover, these documents were withheld even 

where defendants issued subpoenas specifically requesting those documents. And finally, the 

material withheld was often relevant, exculpatory investigative information that should have 

been disclosed under generally accepted police practices. I discuss each conclusion in turn 

below.

 

48 Hickey, Rivera, pages 36-37 (NF-L 000273-74); City of Chicago’s Amended Response to Plaintiff’s 

Seventeenth Set of Requests to Produce Documents to the City of Chicago, p.2-3.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 43 of 433 PageID #:15464
41

1. Background on the Area North investigative files and my file review

For purposes of my analysis of Area North files, I reviewed investigative files for the 

period from 1985-1991 (the three years around the 1988 homicide investigation), collected from 

two locations. 

1. In 2011, during post-conviction proceedings in Mr. Rivera’s criminal case and decades 

after Mr. Rivera’s criminal trial, the City of Chicago located an investigative file related to Mr. 

Rivera’s case. Portions of that file appear to have been provided to the CCSAO during Mr. 

Rivera’s post-conviction proceedings. That complete file was not turned over to Plaintiff when 

this civil lawsuit was filed in 2012, and instead documents Bates-stamped CPD 1-55 were 

produced and identified as the “Area File.” In April 2014, during the deposition of Anthony 

Wronkowski, the City produced for the first time a copy of the so-called Investigative File for 

the Valentin homicide, Bates-stamped as Wron 1-69. As discussed below, in Section V.H, that 

file contained numerous pages of documents related to the police investigation into the Valentin 

homicide that had not been previously produced and were relevant evidence.

Based on further investigation, it was learned that the investigative file had been stored at 

some point in time in the 45 file cabinets at Area North, containing primarily open investigative 

files from 1961 to the present. Based on Court rulings, Plaintiff was then given limited access to 

a sample of two file cabinet drawers from the period of 1985-1991, and all investigative files in 

those two drawers were copied and produced. That set of 52 files, classified as the Area North 

Inspection Files, forms one of the two sets of investigative files I reviewed.

2. Pursuant to CPD policy, closed homicide investigative files are supposed to be sent to 

the CPD records warehouse for storage. For purposes of another aspect of Plaintiff’s case, the 

parties reviewed 435 investigative files stored at the records warehouse that were represented to 

comprise all Area Five homicide investigations from 1985-1991. By agreement of the parties 

those files are a representative sample for purposes of assessing CPD’s policies and practices. 

The parties then identified and copied 138 of the 435 files that contained any evidence of a 

lineup having been conducted, and that set of 138 homicide files was used for purposes of my 

analysis. 

Mr. Rivera’s attorneys provided me with a spreadsheet that served as an index of the 190 

police investigative files pertaining to the two sets of investigative files for the time period from 

1985-1991, as described above.49 I reviewed and double-checked the spreadsheet extensively. 

That spreadsheet is attached to this report as Attachment G.50

Attachment G also contains additional information reflecting my comparison of the 

investigative files to criminal defense files and permanent retention files (discussed further 

 

49 The spreadsheet contains 194 rows, rather than 190, because there were several cases in which there 

were multiple criminal defendants, and so multiple criminal defense files corresponding to a single 

investigative file. Each criminal defense files is given its own row, but for purposes of calculating 

statistics related to the investigative files, the rows are considered as one file.

50 I intend to rely on the spreadsheet included as Attachment G at trial to help explain the differences 

between the particular files to the jury.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 44 of 433 PageID #:15465
42

below). For all of the investigative files found at the CPD warehouse, Plaintiff’s counsel issued 

subpoenas for any corresponding criminal defense files, and was able to obtain 48 criminal 

defense files corresponding to 44 investigative files (there were several cases with multiple 

defendants, so multiple criminal defense files for a single investigative file). Plaintiff also 

obtained 132 permanent retention files, which included files for 43 of those 44 investigative files. 

In some cases, the City of Chicago redacted substantial information from the criminal defense 

files and the permanent retention files in a way that made it impossible to conduct a comparison, 

as noted in Attachment G.

Finally, I gave the City the benefit of the doubt for purposes of my analysis of criminal 

defense files as compared to investigative files. To that end, I excluded from my analysis 

criminal defense files in which it appears that the case was transferred to private counsel, and so 

the criminal defense file may or may not be complete (10 criminal defense files). Those files 

contain a strikethrough in Attachment G. I also gave the City the benefit of the doubt in my 

comparison to criminal defense files by assuming that all material in the criminal defense file 

had been there at the time of the original criminal trial (even if it might have been added 

subsequently, for example, as part of appeals or post-conviction proceedings).

2. Criminal defense files are missing pages from the police investigative files

I also had access to criminal defense attorney files that corresponded to certain of these 

investigative files. Mr. Rivera’s attorneys attempted to locate defense attorney files for as many 

of these homicide investigations as possible. As discussed above, through their efforts they 

located 48 criminal defense files for 44 different homicide investigations. Each CPD homicide 

investigation is assigned a “Records Division” (RD) number that is used to identify materials 

corresponding to a particular investigation. I reviewed all of the criminal defense attorney files 

counsel was able to obtain; none were withheld from me. 

I conducted a case-by-case analysis of what documents are included in the police 

investigative files but are missing from criminal defense files. I did not make any inferences 

about what documents were turned over to criminal defendants – my comparison exercise was 

objective in nature rather than subjective. I then analyzed the types of documents withheld across 

the files, focusing in particular on whether there were the types of documents withheld that could 

and would be important to disclose to prosecutors and criminal defendants. My observations and 

conclusions flow from this analysis, which is contained in Attachments F and G.

Of course, not all of the material withheld is of equal importance. Some of the documents 

not turned over to criminal defendants were administrative in nature and not crucial evidence 

(although I note that administrative records like inventories can be important evidence to 

disclose); while other records were highly relevant investigative material. But any withheld 

pages, regardless of their importance, are evidence that there was not a policy of copying all 

police files in their entirety. Moreover, the inconsistent nature of what was withheld or disclosed 

is concerning, (i.e. the same category of document is sometimes disclosed and sometimes 

withheld). That variation suggests that individual officers are making ad hoc decisions about 

what to disclose from each file. Picking and choosing what materials to produce, or failing to 

have a procedure to ensure complete production of all material in all police investigation files, 

are both egregious departures from generally accepted police practices. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 45 of 433 PageID #:15466
43

My comparison of the investigative files to corresponding defense attorney files revealed 

that well over 90 percent (37 of 38 criminal defense files51) of defense attorney files are missing 

documents that were contained in the corresponding police investigative files.

The documents missing from the defense attorney files are important investigative 

materials. For example, the following significant discoverable items were routinely absent, and 

are precisely the kinds of documents that should be routinely disclosed to a criminal defendant 

under normal police practices. 

Handwritten Notes and General Progress Reports: More than 20 out of 27 of the 

criminal defense files (or approximately 74%) reviewed above were missing unofficial 

handwritten notes that were present in the investigative files (see Row L of Attachment 

G). Another 10% of criminal defense files were missing GPRs that were present in the 

investigative files. The handwritten notes are often found on plain sheets of paper, on the 

margins of official forms, and on scraps of paper, none of which were the official GPRs 

on which such information was supposed to documented. There were hundreds of 

handwritten notes contained in the police files reviewed that were not in criminal defense 

files. They are often not inventoried, or the inventory lacks any type of specificity to 

assist in investigation and discovery. They are documents recording the type of 

information– from alternative suspects, to witnesses, to vehicle information, to alternative 

theories of the crime – that should be disclosed to defendants under normal police 

practices. 

To-From Memos: Approximately 17% of the criminal defense files were missing tofrom memos that were present in the investigative files: (see Row N of Attachment G) 

Handwritten and typed to-from memos, not on GPRs, are another classic type of document 

typically contained in “street files” that were supposed to be prohibited during the relevant time period 

from 1985-1991. Like handwritten notes, they contain a wide range of information – from alternative 

suspects, to witnesses, to vehicles, to alternative theories of the crime.52

Investigative File inventories: Only 3 of the criminal defense files that I reviewed had 

an inventory to serve as an index of documents in the police investigative files. 

As discussed above, normal police practices and procedures require the creation and 

dissemination of an inventory that serves the purpose of providing a compilation of all of 

the investigative materials related to a criminal investigation. The inventory sheet was 

apparently designed to be used as an index of documents in an Investigative File. Even 

when an inventory sheet is available, they were often incomplete (i.e., missing entries 

that were listed on the investigative file inventory or not listing handwritten notes or other 

 

51 Again, 10 of the 48 were excluded to give CPD the benefit of the doubt.

52 Notably, in only six of the more than 40 cases in which I conducted a comparison of criminal defense 

files to investigative files were there even to-from memos. This strongly suggests that there are additional 

investigative files in addition to the ones the City produced, as set forth in Section VII, below. Defendants 

in this case testified that they routinely used memos to communicate between shifts, which is consistent 

with my findings in reviewing investigative files in Fields and Kluppelberg.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 46 of 433 PageID #:15467
44

documents) or were so generic as to be worthless (e.g., including overly generic entries, 

such as “GPR,” with no date, number of pages, or author). 

Other types of important investigative material often missing from the criminal defense 

files included photographs, lab reports, evidence reports, hold requests and release of person in 

custody reports, and arrest reports. See Attachment F. 

As discussed below in Sections V.G and V.H, these same problems infected the Rivera 

files as well.

3. Issuing a subpoena does little to ensure disclosure of all relevant materials

Even in cases where a criminal defense attorney went out of his or her way to send a 

subpoena requesting the “investigative” or “street files,” my analysis reveals that there was no 

guarantee that a defense attorney would receive all the relevant investigative materials beyond 

the official reports in the permanent retention file. In many instances, the defense attorney issued 

a subpoena specifically for “street files,” and that subpoena appears in the investigative file, but 

not all the documents in the investigative file were disclosed in response to a subpoena. For 

example, subpoenas specifically for “street files” were issued by defense counsel in the 

following cases, but as described in Attachment F, not all the documents were turned over in 

response: G235351 (subpoena at RFC 2922); J052070 (subpoenas at RFC 5250-52); J080925 

(subpoena at RFC 5987); J209456 (subpoenas at RFC 6333, 6335-36); J215119 (subpoena at 

6498); K417078 (subpoena at RFC 8181-82); K455932 (subpoena at RFC 8393); K530917 

(subpoena at RFC 8783-85); M184949 (subpoena at RFC 9653); M287641 (subpoena at RFC 

10192); M579697 (subpoena at RFC 10784); N028256 (subpoena at RFC 11332); N262285 

(subpoenas at RFC 12628-29, 12702-03); N475910 (subpoena at RFC 13121-22); N581836 

(subpoena at RFC 13575-76); P049272 (subpoena at RFC 13944-45); P060434 (subpoena at 

RFC 14475-76); P128067 (subpoenas at RFC 14647-49); P526822 (subpoena at RFC 16315-16).

These problems with CPD’s responses to subpoenas and file requests persisted regardless 

of who sent the request. In fact in one case that I reviewed, an Assistant State’s Attorney 

described the difficulties obtaining the complete set of investigative materials from CPD. In 

1987, Sherman Addison was and convicted of the 1985 murder of Helen Smith. The case was 

sent back for a retrial, and in 1994, during a court hearing about discovery an Assistant State’s 

Attorney explained that “usually there is an investigative file. We never had that, never had it for 

the first trial.” JR-L 214518. He also reported to the Court that even though the prosecutor met 

with Detective Jedlowski, the lead detective in the case, before the first trial:

[a]ll he had was the typed police report which is the normal police report that is 

always issued in cases, the non-investigative type police report. No notes, no 

GPRs, and that is what she [the prosecutor] was shown by him. She noted that he 

didn’t have a copy of the street file or the investigator file so that is why she then 

subpoenaed the investigative file but she was not tendered anything by Detective 

Jedlowski and, in fact, Detective Jedlowski happened to be in the building 

yesterday so I spoke with him also and he verified the fact that all he had was just 

the typed police reports, supplementary reports

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 47 of 433 PageID #:15468
45

JR-L 214520-21. In fact, the lead detective made multiple representations to the prosecutors that 

he had provided the “complete set” of police files. 

These subpoena responses suggest deficiencies with regard to the two most basic 

requirements of a process to ensure complete disclosures to defendants: (1) the City did not 

know what files it had and where (not centrally located or indexed); and (2) it did not have 

policies or procedures to ensure that whatever investigative material was found was turned over 

in its entirety. The latter finding is particularly troubling: it suggests that CPD personnel were 

picking and choosing which investigative materials in the files to turn over.

4. The missing pages contain important and relevant information that should 

have been disclosed to criminal defendants

Finally, entirely consistent with the findings above, in the majority of cases I reviewed 

there were significant amounts of relevant information that would have aided the defendant and 

therefore should have been disclosed under standard police procedures. In my experience, given 

the volume of investigative material that was not disclosed, it was inevitable that relevant 

information helpful to a criminal defendant would be withheld. That is exactly what I found.

Below are some examples from the comparison of the defense attorney files and the 

corresponding police investigative files that demonstrate this problem: 

J209456 – David Quinones, Bruce Andras, Marc Johnson

Quinones, Andras and Johnson were charged with the May 19, 1987 murder of Eddie 

Mercado, and attempted murder of Nicky Lanzarin and Luis Rodriguez. Andras reportedly told 

police that he was shot at the week prior by members of a rival gang, and the drive-by shooting 

in this case was allegedly planned in retaliation.

Among the documents missing from the criminal defense files are a request for 

identification photos (RFC 6443) of three men: (a) criminal defendant Bruce Andras, (b) 

Santiago Chacon, and (c) a man named Mickey Harris, whose name does not appear elsewhere 

in the investigative materials and whose connection is otherwise unexplained. The fact that 

police were interested in obtaining identification photos for Mickey Harris suggests he may have 

been an alternate suspect, and information that led police to pursue this lead should have been 

disclosed. Moreover, the fact that there is no information on who Mickey Harris is, or how police 

obtained this name, or why detectives thought his photos would be relevant to the investigation, 

suggests that additional investigative materials created during this investigation, are missing 

from this file. 

Handwritten notes elsewhere in the investigative files were also withheld. A handwritten 

note at RFC 6334 lists a criminal case number (94CR0105701), the significance of which is not 

explained. This page is missing from both Quinones and Johnson’s defense attorneys’ files. The 

number 87117788701 is likewise handwritten on a blank page at RFC 6332, and is not included 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 48 of 433 PageID #:15469
46

or otherwise explained in any official reports. RFC 6332 is missing from both Andras and 

Johnsons’ defense attorneys’ files.53

P526822 - Miguel Borrotto

Miguel Borrotto was charged with first degree murder and aggravated battery with a 

firearm after he allegedly shot Fulgencio Torres and Angel Sotos in a bar fight on October 26, 

1991.

A supplementary report at RFC 16300 notes that an Illinois vehicle registration card was 

found in the pocket of the shooter’s jacket, which he took off and left behind after fleeing the 

bar. The card from the shooter’s jacket was for a Nissan with the license plate ZZ1384. 

However, two documents which are missing from the defense attorney’s file (a vehicle search 

printout at RFC 16394 and a receipt for the purchase of the vehicle at RFC 16401) show that the 

defendant owned a Nissan with a license plate number YVK670, not ZZ1384. 

Also missing from the defense attorney’s file is a page of handwritten notes (RFC 16397) 

on which the names Eduardo Castro and Karl Lugo are written. These names are not included in 

supplementary reports or mentioned elsewhere in the investigative file. The presence of 

unexplained names in the file suggests that there are other investigative materials for this case 

(for instance, that explain the source of the names and their relevance) that are now missing from 

this particular file. 

J080925 – Samuel Slack

Samuel Slack was charged in July 1987 with the February 1987 armed robbery and 

murder of Estella Winburn. 

Two fingerprint comparison reports are missing from the defense attorney’s file. The 

report at RFC 5984 notes that the victim’s prints were compared for elimination purposes. The 

report at RFC 5982 requested that the defendant’s prints be compared to “all unidentified latent 

prints,” but no results are listed in the report. 

Five photographs at RFC 6074-79 were also withheld from the defendant. These photos 

are labeled with the names Jeffery Johnson, Christopher Morrow, Fines Gerard Savage, Clarence 

Parker, and Carl Harrington. A supplementary report at RFC 6007 notes that five photographs 

were shown to eyewitness Alvin Robles, and Robles “tentatively identified” the photo of 

defendant Slack. In fact, Robles first identified Johnson as the shooter in a photo lineup in 

February 1987 (RFC 6017-19), but Johnson was released when Robles failed to identify him in a 

live lineup (RFC 6014). Slack was not identified in a live lineup by Robles until five months 

later, in July 1987 (supp report at RFC 6005-06). The arrest reports for two of the men in these 

photos, Savage and Johnson, were also withheld from the defense attorney (RFC 6042, 6056). 

 

53 An additional file for this case was found in the two drawers that Plaintiff was given access to from 

Area North, and that file contains information pointing to an alternate suspect that also was not produced 

to the criminal defendant. The existence of a separate file, with different documents and information, 

stored in another location, demonstrates the risks of maintaining a parallel file system. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 49 of 433 PageID #:15470
47

Given the fact that the same eyewitness who implicated Slack in the shooting previously 

identified another suspect, exactly which photos were used in the lineup could have been an 

important part of Slack’s defense.

N028256 – Jesse Swanigan

Defendant Jesse Swanigan was charged with the January 1990 murder of Roy Stolle. 

Swanigan was ultimately found not guilty of the murder charge but was sentenced to 7 years on 

the theft and possession of a stolen motor vehicle. Swanigan claimed to have run across the real 

perpetrator of the burglary, saw him loading two TVs into his car, yelled “police” to scare him 

off, and drove off in the car. The TVs were later determined to have been stolen from the 

victim’s home during the burglary and murder. Swanigan denied any involvement in the burglary 

and admitted only to stealing the car with the TVs inside, and to later attempting to sell the TVs 

to a friend named Benny Buford.

Several mug shot photographs from the investigative file (RFC 11300-09) were withheld. 

The men’s names are written on the back of most of the photos along with the note “filler” on 

several. Two of the photos, however, also have a note stating, “unidentified...misidentified as 

Swanigan, Jessie.” No names are listed on these two photos.

A handwritten phone message (RFC 11324) was also withheld from the criminal 

defendant. The phone message appears to be from a John Reed, and on the back are details 

regarding Reed’s contact information and place of employment. Reed’s name does not appear 

anywhere else in the file and there is no indication whether detectives ever followed up with 

Reed or what information he may have provided.

M258570 – Curtis Kirkland

Curtis Kirkland was charged with first-degree murder in January 1991. Victim Stanley 

Moody was chased and beaten by several men in June 1989 and eventually died from his 

injuries. Kirkland and another man, Michael Sargent, were both charged with murder after 

eyewitnesses identified them in lineups. Sargent was found not guilty (RFC 9920), but Kirkland 

was convicted and sentenced to 38 years in prison (RFC 9919). 

Several pages of handwritten notes (RFC 9984, 9987, 9989-90) contain names not 

included in supplementary reports – Carmen Tate, Eddie Richardson, Ernest Roberts, Carl 

Evans. These names are mentioned in the investigative file only in a GPR at 10081. A 

handwritten note at RFC 9989 contains potentially important information tying Ernest Roberts 

and Carmen Tate to the crime, apparently provided by an anonymous source: “Ernest ...V with 

Joe...Michael has baseball bat...Carmen had rock[?]...all people in liquor store saw it...would 

you like to remain anonymous??...YES.”

A memo in the defense attorney’s file (JR-L 223955) indicates that a witness named 

Avory Moore volunteered these names to Kirkland’s defense attorney nearly two years after the 

crime and several months after Kirkland was charged. Police interviewed a possibly related 

witness named Courtney Moore (see canvass report at RFC 9959), who owned a nearby 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 50 of 433 PageID #:15471
48

laundromat, but supposedly saw nothing and could provide no information. Avory Moore’s 

memo reads “I was working at the Laundromat...across the street from where this guy was beat 

up and killed...Curtis was not 1 of the 8 guys that was involved in this incident. I know they (sic) 

guy who had the stone was called Carmen, and the man who had the 2x4 was called Ernest.” 

This highly exculpatory information was clearly known to detectives early on in the 

investigation, based on the notes at RFC 9989, but was only uncovered independently by the 

defense attorney, and then only partially – it is not clear that the defense attorney uncovered the 

names or significance of Eddie Richardson, or Carl Evans. 

N162782 – Tomas Nieves

Tomas Nieves was charged with the April 11, 1990 murder of Benedicta Gonzalez, who 

fell or was pushed out the window of an apartment building during an argument and died of her 

injuries.

The investigating detectives appear to have considered several male acquaintances of 

Gonzalez as potential suspects before eventually arresting and charging Nieves. Gonzalez was a 

known drug dealer, and had related dealings with these various men. Gonzalez’s daughters told 

police that a man they knew as “Mike” was with their mother that day, and initially identified a 

John Lowden in a photo array (see supplementary report at 11924), but one of the girls later 

changed her identification (RFC 11932). Other witnesses identified Mike as Mike Amidei. 

Amidei had an alibi for his whereabouts that day, but cooperated with police and identified Jose 

Montero in a live lineup in May 1990 (RFC 11945). Amidei told police that he had seen Montero 

at Gonzalez’s apartment when he himself went there to buy drugs on April 11, 1990.

It is not clear from the investigative file how police identified Nieves as a suspect. A 

supplementary report dated October 28, 1990 (RFC 11949), six months after the murder, notes 

that “the reporting detectives developed information that a male white Hispanic known as Tomas 

Nieves was involved with the deceased in a failed relationship.” After Nieves was brought in for 

questioning, detectives had Mike Amidei (who previously gave a definitive identification of Jose 

Montero) view another lineup (see RFC 11943). Amidei changed his story and identified Nieves 

as the man he saw at Gonzalez’s apartment the day of her murder.

A number of photos relevant to the investigation were withheld from Nieves’s defense 

attorney, including polaroid photos (RFC 11956-66) of the various men who were considered as 

alternate suspects, and polaroid photos taken at the crime scene (RFC 11955). These crime scene 

photos included a photo of a pair of glasses found at the scene, which police used to track down 

Nieves and tie him to the crime. Moreover, the fact that there is no information about how 

Nieves was identified as a suspect suggests that there is additional investigative material that 

once existed but is no longer included in this file. 

P272087 – Demetrius Johnson

In connection with this investigation, Demetrius Johnson was charged with the murder of 

Fred Erwin and was convicted on June 12, 1991. The investigative file contains documentation 

of an in-person lineup, in which a witness positively identified an alternative suspect named 

Bryan Johns. See Bates No. RFC 15470-71. The report of this lineup and all references to this 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 51 of 433 PageID #:15472
49

lineup occurring are omitted from the permanent retention file and were not provided to Erwin or 

his criminal defense attorneys and are also missing from the CCSAO file. Instead, typed police 

reports included in the permanent retention file state that Bryan Johns appeared in a lineup that 

resulted in no positive identification (see supplementary report at RFC 15480).54 I note, in 

relation to my other opinions in this case, that this is an investigation in which Defendant 

Guevara was actively involved.

***

I received copies of the Cook County State’s Attorney’s Office files for each of the 

examples above, and in each case the material identified as withheld from the criminal defendant 

was also withheld from the State’s Attorney’s Office. 

In several of these cases, and many others identified in Attachment F and G, there are 

handwritten notes, or GPRs that list names and contact information of individuals without 

additional context or explanation of their relationship to the investigation. In my experience, it is 

likely that these were individuals whose names came up during the investigation as possible 

suspects or witnesses that a detective would want to remember and follow up on. That is exactly 

what I found in my review of the undisclosed street file in Fields; it contained handwritten notes 

listing names without any explanation, which were in fact referring to important alternate 

suspects.55 These examples emphasize how important it is to disclose all investigative materials, 

because the importance or relevance of certain pieces is not always apparent looking at a 

document in isolation.

Moreover, the fact that the relationship of various names is not explained elsewhere in 

the investigative files produced in this case is indicative of the practice of using multiple, parallel 

files for an investigation: there is no evidence that explains where the names came from, or 

evidence of any follow up to investigate those names. That suggests that detectives continued to 

store that information in separate files, that were not ultimately stored with the investigative files 

produced in this case. One example of this are the photos, from what appear to be an August 31, 

1988 lineup, that were produced from ERPS for the first time in this civil case in 2013 (see 

Section V.H, below).

E. CPD’s policies after Jones and Palmer don’t ensure disclosure of all relevant 

investigative materials

All police officials are aware of the challenges of ensuring that, over the course of an 

evolving criminal investigation involving multiple investigators developing evidence at different 

locations and times, that investigating officers document their findings and that such 

investigative material is collected, preserved, compiled and disclosed. In the CPD’s case, it was 

acutely aware of these challenges since 1982, at the time of the Jones case, and the problems 

created by using multiple, parallel files. Yet, it has made only superficial attempts to resolve its 

 

54 The withheld lineup information is also missing from the CCSAO file for this case. While there is some 

possibility that this criminal defense file was transferred and could be incomplete, that is unlikely to 

explain the omission since the information is also missing from the CCSAO file.

55 See CITY-NF-001062; CITY-NF-001076; CITY-NF-001085, which list names of alternate suspects 

without any additional information.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 52 of 433 PageID #:15473
50

“street files” problem. It issued written directives, but they were incomplete and insufficient in 

their scope, and beyond that they were not supplemented with the training, auditing and 

monitoring necessary to ensure that the necessary changes in practice occurred. Unsurprisingly, 

then, the street files problem continued. 

1. A department-wide teletype issued during the Palmer litigation;

2. Detective Division Notice 82-2 (Detective Division Notice - File Control);

3. Special Order 83-1 (Detective Division Special Order – File Control);

4. Special Order 83-2 (Detective Division Special Order – Investigative Files);

5. Special Order 86-3 (Detective Division Special Order – Investigative Files); and

6. Standard Operating Procedures (SOP) 1988

Instead of using the Jones and Palmer litigation as an opportunity to reform its practices 

and implement standard police procedure of creating one single, centralized file for each 

investigations, those directives actually instructed detectives to create multiple, parallel files, 

each with different information and did nothing to address the fundamental problems regarding: 

(1) allowing officers discretion about what to document in the official reports; and (2) the

absence of any system or training for responding to subpoenas and ensuring complete disclosures 

of investigative material. Moreover, the CPD provided only minimal training on these orders, 

and failed to conduct any audit, supervision, or oversight to ensure that detectives were following 

these new directives.56

1. The policies are insufficient to remedy the “street files” problem

a. The Teletype and Detective Division Notice 82-2

In April 1982, after a Temporary Restraining Order was issued in the Palmer litigation, 

CPD issued two documents: (1) Detective Division Notice 82-257 and (2) a 1-paragraph teletype 

to commanding officers alerting them to the TRO.58 As Hickey explained, Notice 82-2 was “a 

quick and dirty document” designed to implement the TRO but was “not very workable.”59

Notice 82-2 and the corresponding teletype were concerned only with preservation and 

were silent about procedures to collect or inventory their notes, memos, or other documents. 

Although it coined the term “Unit Investigative File,” it did not require detectives to put notes or 

memos into Unit Investigative Files; and it did not specify whether detectives had to preserve 

notes or memos that were not in the file.60

Even with Notice 82-2’s limited requirements and scope, the CPD showed little 

commitment to implementing that Notice. There is no evidence of training to implement the 

Notice, and six months after its implementation, Commander Stibich testified that it was still the 

 

56 Hickey Fields Dep. at 10, 43.

57 NF-L 008751

58 NF-L 008754; Hickey, Kluppelberg Deposition 201 (NF-L 001141)

59 Hickey Kluppelberg Deposition 221-22, 224; (NF-L 001161-62, NF-L 001164); Brzezcek Test. NF-L

007517

60 NF-L 008751-53; Hickey Kluppelberg Deposition 212-13 (NF-L 001152-53)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 53 of 433 PageID #:15474
51

prevailing view that if a detective kept his own personal notes or memos – or considered those to 

be his personal property – then Notice 82-2 did not require the detective to put those notes or 

memos in the file and detectives felt they could do whatever they wanted with those notes or 

memos, including destroying them.61

Based on this and other testimony, Judge Shadur found that Notice 82-2 responded to the 

TRO in “an improperly restrictive and grudging manner, under which detectives could consider 

their investigative writings as their personal property (and thus not ‘under Detective Division 

control’) and therefore outside the preservation requirements of Notice 82-2.”62 The comments 

of Commander Stibich and the findings of Judge Shadur make clear to me that the practice of 

keeping information in parallel files that were not shared with prosecutors or criminal defendants 

was an ingrained problem within the police department, and one that would require the sort of 

dramatic change in attitude and culture that could only be achieved through extensive training, 

monitoring, and discipline.

b. Special Order 83-1

On January 3, 1983, Detective Division Notice 82-2 was replaced by Special Order 83-1.

Special Order 83-1 applied only to the field investigations of detectives assigned to Violent 

Crimes.63 Special Order 83-1 defined certain terms and created procedures for documenting and 

preserving investigative documents. Special Order 83-1 defined the term “Investigative File” and 

created something called an Investigative File Case Folder to secure documents relating to a 

criminal investigation. According to the terms of Special Order 83-1, an Investigative File Case 

Folder was to be created either when certain categories of violent crimes occurred64 or when a 

violent crime investigation resulted in an arrest and approval of felony charges.65 Special Order 

83-1 also created an “Investigative File inventory sheet,” which was supposed to identify each 

document placed in the Investigative File.66 The inventory sheet was to be forwarded to the 

Records Division anytime felony charges were lodged.67 Finally, Special Order 83-1 created 

General Progress Reports (“GPRs”).68 The GPR forms were to be used by detectives whenever 

they were taking handwritten notes or writing memoranda to other detectives.

Unlike Notice 82-2, Special Order 83-1 created an affirmative obligation for detectives to 

submit handwritten GPRs or investigative materials for review and inclusion in the investigative 

file. It also mandated that detectives transcribe relevant information previously recorded on a 

 

61 Stibich Test. (NF-L 007468-70)

62 NF-L 005615-16

63 NF-L 007223-27

64 Those categories of violent crimes were identified in Special Order 83-1, V(A)(1): Homicides/Medical 

Examiner Cases; Police-related shooting incidents; Batteries likely to result in death; Rapes and Deviate 

Sexual Assaults, and Any other major violent crime field investigation that the unit supervisor deems 

appropriate.

65 Special Order 83-1, V(A)(1) & (2) 

66 Special Order 83-1 IV(D) 

67 Special Order 83-1, IV(D) 

68 Special Order IV(E); Hickey Kluppelberg Deposition 170 (NF-L 001110)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 54 of 433 PageID #:15475
52

GPR or other miscellaneous documents on an official CPD case report form (general offense 

case reports, supplementary reports, etc.).69

In reviewing Special Order 83-1, Judge Shadur identified several deficiencies, including: 

• Unless the crime being investigated fit one of the specified of violent crimes, 

there was no obligation to create an Investigative Case File Folder unless and until the 

offender was arrested and felony charges were approved. According to Judge Shadur, 

and in line with standard police practices, this continued to pose the same type of risk 

that information would not be retained and disclosed because there was nothing to 

prevent against selective retention while the case is investigated;70

• It only required detectives to include “relevant” information in the official reports 

and offered no guidance about what information a detective should deem “relevant,” 

leaving discretion for detectives to withhold information based on their assessment 

that it was not relevant.71

• It did not include information to ensure that any detective who has or receives 

information relating to a violent crime field investigation not assigned to him will 

forward the information to the assigned detective for investigation and inclusion in 

the Investigative File Case Folder;72 and 

• It omits any provision defining how the CPD responds to a criminal subpoena or 

request by the State’s Attorney to produce information relating to a criminal 

proceeding.73

Moreover, the training on 83-1 was inadequate. Hickey testified that he provided a onetime training to about 1,000 detectives.74 He said each training session was done in groups of 

30-40 people, and lasted approximately 3 hours.75 During that three-hour training session, he went over 

Special Order 83- 1. One training session was wholly insufficient to try to change a decades-long practice, especially 

one so ingrained in the culture of the police department. 

c. Special Order 83-2

On May 2, 1983, Special Order 83-2 was issued. Three of the changes in Special Order

83-2 were (1) a requirement that detectives create records reflecting all relevant information, 

V(B)(1); (2) a requirement that where a detective receives information about another crime, he or 

she pass that information along to the detective investigating that other crime, V(B)(6); and (3) 

 

69 Special Order 83-1 V(B)(1) & (2), NF-L 008772-73

70 NF-L 005620

71 Special Order 83-1 V(B) (NF-L 005620); Hickey Kluppelberg Deposition 238; (NF-L 001178); Hickey 

Kluppelberg Deposition [2015] 20. 

72 NF-L 005621

73 NF-L 005621

74 Hickey Kluppelberg Deposition 308-309 (NF-L 001249-50); NF-L 008808

75 Hickey Kluppelberg Deposition 309 (NF-L 001250); NF-L 008808

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 55 of 433 PageID #:15476
53

that a copy of the Investigative File Inventory Sheet will be transmitted to either the Office of 

Legal Affairs (in case of a subpoena from a criminal defendant) or the State’s Attorney’s Office 

(in case of a discovery motion) so that the inventory sheet is disclosed to defense counsel in a 

criminal case, V(B)(6).76 Hickey also testified that Special Order 83-2 also created the 

Investigative File Control Card, IV(F).77 This Control Card was supposed to act like a library 

card so that the Investigative File could be accounted for. 

Despite these new requirements in 83-2, there is no evidence that CPD provided any 

additional training to update detectives on the differences between 83-1 and 83-2.

Moreover, even if detectives had been adequately trained on Special Order 83-2, it was 

still deficient. Here are some of the deficiencies that should have been apparent to CPD 

policymakers.

x Special Order 83-2 still did not comply with standard police practice to require a 

single repository for all investigative information maintained by a lead 

investigator.

x Special Order 83-2 applied only to detectives, and it explicitly excluded from its 

directives all other officers involved in investigating major crimes, such as gang 

crimes officers, officers from bomb and arson, and officers from patrol, among 

others. The failure to include gang crimes officers is particularly egregious: it was 

well understood within CPD leadership that gang crimes officers participated in 

homicide investigations,78 and the Valentin investigation at issue in this case is an 

obvious example of the intimate involvement of gang crimes officers in homicide 

investigations. Yet, there was no training or other effort to ensure that gang crimes 

officers were preserving their notes in the wake of Jones or otherwise.79

x Special Order 83-2 provided no guidance about what information a detective 

was required to include in a supplementary report beyond information deemed 

“relevant.”80 Relevance is of course subjective and, as Commander Stibich testified, 

what is relevant to one detective may not be relevant to another.81 In fact, Hickey 

testified that a detective would only have to put information in a supplemental report 

if the detective deemed it pertinent at the time that the detective wrote the 

supplemental report, regardless of whether the detective considered the information 

relevant when he or she received it.82 For example, Hickey testified that CPD policy 

did not require suspects who had been eliminated through investigative activity to be 

documented in any way.83 Based on my experience, this is inconsistent with standard 

 

76 NF-L 008746-50

77 Hickey Kluppelberg Deposition 228-29 (NF-L 001168-69)

78 Hickey Rivera Deposition 229-32.

79 Hickey Rivera Deposition 55, 87-88.

80 Hickey Kluppelberg Deposition 238; (NF-L 001178); Hickey Kluppelberg Deposition [2015] 20 

81 Stibich Test. NF-L 007474 

82 Hickey Kluppelberg Deposition [2015] 24-25, 33 

83 Hickey Kluppelberg Deposition 237-38 (NF-L 001177-78)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 56 of 433 PageID #:15477
54

police practices. Alternate suspect information, for example, is highly relevant 

information and its documentation and disclosure to criminal defendants is critical.84

x Special Order 83-2 provided no guidance about how information should be 

communicated or documented among detectives, for example when one detective 

learned something about a crime being investigated by another detective; or when one 

unit learned something about a crime that is also being investigated by another unit.

While section V(B)(6) of Special Order 83-2 codifies the obligation to “forward” 

information about a crime to the assigned detective, it does not require either 

detective – the detective passing along information or the receiving detective – to 

document that information.85 Similarly, even where the detective passing along the 

information may have created a document memorializing that information – e.g., a 

memorandum or GPR – there is no requirement in Special Order 83-2 that the 

resulting memorandum or GPR be distributed to other detectives or units 

investigating that crime.86

x Nowhere does Special Order 83-2 state that the entire investigative file should 

must be disclosed in response to a discovery motion or subpoena, or provide 

procedures for doing so. Despite the underlying circumstances of Jones and Judge 

Shadur’s admonishment about the failure to “defin[e] the CPD’s duty or procedure in 

responding to a criminal subpoena or request by the State’s Attorney to produce 

information relating to a criminal proceeding,” Special Order 83-2 included 

absolutely no policy directive or procedure to ensure production of investigative files. 

Although the City claims in this litigation that its practice was to disclose the entire 

investigative file, such a directive is conspicuously absent from the Special Orders. 

Instead, the Special Order contains an instruction to forward a copy of the inventory 

to the Records division to be forwarded to the defense attorney. This might imply that 

in fact the policy was not to copy and disclose the entire investigative file, but just the 

inventory. In addition, there is no rule, policy, procedure, directive or any other 

document that guides the clerks in the subpoena unit to ensure that all documents are 

retrieved from all possible locations and disclosed, or any training to that effect.87

The CPD’s lack of clear policy guidance, as well as the lack of any guidelines or 

instructions to ensure retrieval and disclosure of all investigative material, are each 

egregious violations of generally accepted police practices. Indeed, these are both 

straightforward requirements of any policy regarding maintenance and disclosure of 

investigative materials, and, as explained above, standard practice is to keep a single 

investigative file and to have a clear policy requiring that the single investigative file 

be copied in its entirety and disclosed to the prosecutor or directly to the defense 

attorney. The result within CPD was entirely predictable: confusion among detectives 

 

84 This does not prevent an investigating officer from also documenting information explaining why the 

suspect was eliminated.

85 Hickey 236-37 Kluppelberg Deposition (NF-L 001176-77)

86 Hickey Kluppelberg Deposition [2015] 39, 43, 46 

87 Hickey Rivera Deposition 36, 185-87; City of Chicago’s Amended Response to Plaintiff’s Seventeenth 

Set of Requests to Produce Documents to the City of Chicago, p.2-3 (no guidelines or instructions and no 

training).

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 57 of 433 PageID #:15478
55

and subpoena personnel about their disclosure obligations, as acknowledged by 

Hickey.88

x Inventory sheets are an inadequate mechanism for ensuring disclosure of 

documents generated during the police investigation. While the investigative file 

inventory sheet is designed to be used as an index of documents in the file, there is no 

guidance about what level of detail is needed in the inventory sheet to ensure that it 

serves its purpose. Indeed, my review of the records demonstrates that the inventories 

are largely useless because the entries are too general, often missing dates, 

descriptions and numbers of pages, such that one cannot tell whether they have the 

document referenced. In addition, that sheet is only distributed beyond the Area or 

investigating unit if felony charges are placed IV(D); V(B)(6).

x Finally, there is no provision in Special Order 83-2 requiring an audit or 

oversight to ensure compliance with the special orders. 

d. Special Order 86-3

On May 29, 1986, the CPD issued Special Order 86-3. Special Order 86-3 largely 

replicates its predecessor with some minor adjustments, most of which actually limited, rather 

than expanded, to policies governing disclosure of investigative materials to prosecutors and 

defense attorneys. For example, Special Order 86-3 more explicitly limits the creation of 

Investigative File Case Folders to homicides or felony investigations where charges have been 

approved, or an arrest warrant issued; it eliminates the requirement that the inventory sheet be 

forwarded when a criminal subpoena or discovery motion is received; it eliminates the 

requirement that handwritten notes or other investigative materials be submitted “promptly 

(normally at the end of each tour of duty)” and instead only states that such notes must be 

“submitted.”

In these ways, Special Order 86-3 actually deviated further from standard police practices 

than the special orders that came before it: 

x It still did not comply with standard police practice to require a single repository 

for all investigative information maintained by a lead investigator.

x It permitted detectives to maintain their handwritten notes as personal files for 

longer periods of time, by removing the requirement that they turn in the notes and 

investigative materials “promptly (normally at the end of each tour of duty).” Thus, 

even if detectives retained their handwritten notes on their person, or in their locker 

for extended periods of time, it would not clearly violate the Order. In my 

experience, that level of discretion is a gross deviation from standard police practices, 

especially in light of the ingrained problem in CPD. 

 

88 Hickey Rivera Deposition at 253-54. He testified to remembering conversations when he was in charge 

of records division in which there were questions from subpoena clerks and detectives about what they 

were required to produce in response to subpoenas, including whether the entire investigative files had to 

be turned over.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 58 of 433 PageID #:15479
56

x It still provided no guidance about what information a detective was required to 

include in a supplementary report beyond information deemed “relevant.” 

x Finally, it removed even the inadequate stop-gap measure of providing the 

inventory sheet to defense attorneys, leaving defense attorneys with no mechanism 

to determine whether they had received all the relevant investigative materials. 

Special Order 86-3 included a section VI, titled “Inspection.” That section requires 

“[e]xempt members of the Detective Division” to “conduct periodic, unscheduled inspections of 

the subject files to ensure compliance.” According to Stibich, however, he had no idea if, when, 

how often, or in what manner such inspections were conducted.89 Hickey, too, does not know of 

any such auditing ever occurring.90 Nor is there any evidence that detectives were trained on this 

new policy. 

e. Standard Operating Procedures (SOP) 1988 

In 1988, Chief of Detectives John Townsend wrote standard operating procedures to 

govern the work of detectives. Chapter 18 deals with investigative files. Chapter 18 contains “no 

substantive changes of any kind” from Special Order 86-3.91

f. Summary

The policies implemented by the CPD were inadequate to remedy the “street files 

problem” and deviated from standard police practices regarding documenting and disclosing 

investigative materials. 

Continued use of parallel files. None of the policies required a single repository for all 

investigative information maintained by a lead detectives. In fact, in reviewing the materials 

provided, I identified at least three different files that would be created relating to any criminal 

investigation pursuant to the special orders. First, there would be a permanent retention file in the 

Records Division, containing only supplementary reports, general offense case reports and the 

arrest report filed under the accompanying RD number.92 Second, there would be a unit RD file: 

Hickey testified that this was a slim file kept in the homicide drawer at the Area to identify that 

there is a case open.93 Like the permanent retention file, it would contain all the known official 

police reports: original case offense report, supplementary reports, lab reports and other 

documents sent to the investigative unit from support units.94 Third, there would be the 

investigative file maintained by the detective area.95 This file would contain documents that 

 

90 Hickey Rivera Deposition 244, 249.

91 Hickey Rivera Deposition pages 250-51.

92 Hickey Kluppelberg Deposition 22-23, 95-96.

93 Hickey Kluppelberg Deposition 115-16, 299-300.

94 Hickey Kluppelberg Deposition 115-16, 299-300; S.O. 86-3

95 Hickey Kluppelberg Deposition 297-300 (NF-L 001238-41)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 59 of 433 PageID #:15480
57

individual detectives assigned to investigate the case have determined should be in there.96 As 

noted above, none of the files had to have the same documents in them: In fact, by design, they 

did not.97 Likewise, Hickey admitted that the files did not even necessarily have the same 

information in them.98

But in addition to these files, investigative material could also be kept in the Evidence 

and Recovered Property Section (like the photos produced in this case in 2013), arrest reports 

could be kept at the Identification section, and individual detectives could each keep their own 

running/working files during an investigation.99 Defendant detectives in this case have also 

admitted to documenting investigative information in unofficial documents, like Serafini 

Reports, that never become part of the official file.100

Moreover, additional files were also created by other units of the Chicago Police 

Department, because the policies only applied to the Detective Division. So, in addition to the 

multiple files above, gang crimes officers, other special unit investigators, and patrol officers, 

could each have additional sets of files related to a homicide investigation, and the special orders 

are silent as to those additional files, if and how they are to be preserved and maintained, and 

whether they are to be disclosed to prosecutors and criminal defendants. This case is an example 

of the problem: despite intimate involvement of gang crimes officers in the homicide 

investigation, no gang crimes notes, memos or daily activity summaries have ever been 

produced. Yet, like any investigators, gang crimes officers would have had a need to take notes, 

and indeed many of them in this case admitted that they kept such notes and documentation.101

This was an obvious omission. In fact, Hickey testified that he raised the fact that Special 

Order 83-1 was only addressed to the Detective Division and that the Department might want to 

look beyond the detective division to see if the problem extended to other units.102 And at some 

point, Hickey suggested that perhaps Research and Development and Auditing Internal Controls 

Division should get involved because there may be department-wide implications to the use of 

street files.103 But there was no response from the chain of command to Hickey’s concerns and 

CPD never looked to see if the problem of street files went beyond the Detective Division. This 

failure to look beyond the detectives – notwithstanding the fact that they worked closely with 

other units in investigating crimes – was deficient and allowed yet more parallel files to be 

created in other parts of the Department. 

 

96 Hickey Kluppelberg Deposition 297-300 (NF-L 001238-41)

97 See for examples Hickey Kluppelberg Deposition [2015] describing documents that would go in the 

investigative file but not in the permanent retention file at 71-72, 81, 91, 94, 100, 103, 105, 108-110

98 Hickey Kluppelberg Deposition at 100.

99 Hickey Kluppelberg Deposition at 295-96; Hickey Fields April 2014 Trial Testimony at 2069.

100 Rinaldi Deposition at 28, 34 (detectives prepared what he called “Serafini reports” for open cases, 

which comprised leads and investigative results that were passed from one shift of detectives to the next 

to update the investigation’s progress; but these Serafini reports were never made part of the official file).

101 Hickey April 2014 Fields Trial Testimony, at 2060:16-21); Hickey November 2016 Fields Trial 

Testimony, at 11/23/16 PM, at 14-15; Zacharias Deposition at 183-84, 193-96, 200, 203-06; Fallon 

Deposition at 60-62, 145; Gawrys Deposition at 187-88, 218.

102 Hickey Kluppelberg Deposition 207-208 (NF-L 001147-48)

103 Hickey Kluppelberg Deposition 208 (NF-L 001148)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 60 of 433 PageID #:15481
58

The problems created by such an unwieldy system are obvious: It creates the potential for 

information and documents to go missing because they are not centrally controlled. Moreover, 

because the files are designed to be different and to be retained in different locations, there is no 

way to ensure that the complete investigative file is produced during any criminal prosecution.

Discretion to determine what is relevant and needs to be documented and disclosed.

Second, the policies also left detectives with far too much discretion about what information to 

document in official reports and when to turn in investigative materials. This is particularly true 

because the status quo had previously been not to record or document information – at least not 

on official documents that would be maintained by CPD and disclosed to the prosecution and 

defense. As a result, to overcome this culture – and this citywide practice – CPD had to be 

explicit in its requirements and provide direct guidance about what did or did not have to be 

documented; it is not enough to leave it up to the individual officer. 

An egregious example of the problems of officer discretion relate to the lack of a 

requirement to document elimination of suspect. Indeed, Hickey testified that it was not the 

policy of the CPD to require detectives to document suspects who were eliminated.104 To the 

contrary, it was permissible and consistent with the special orders not to document the identity or 

investigative steps taken to eliminate a suspect if a detective did not think that information was 

relevant or if the detective discounted it for some reason.105 This is a significant departure from 

standard police practice, which calls for officers to err on the side of documentation and 

disclosure of such information, which is often crucial to other investigators on a case and highly 

likely to contain exculpatory information.

2. The City failed to provide proper training and oversight to ensure 

compliance with the special orders

On a department-wide scale, there was no action taken whatsoever to ensure that the 

special orders were being followed. The only training provided was one three-hour session after 

83-1 was issued. But some of the Defendant detectives in this case deny receiving any such 

training; Defendant Rinaldi, for example, testified that in the period around Plaintiff’s 

prosecution in 1988 and 1989, Area 5 detectives had been given no instructions about whether 

they could keep their own files, or given requirements for doing so; and accordingly there was no 

effort to ensure that all exculpatory information in investigative notes were preserved or tendered 

for inclusion in the official file. In other words, training or no training, he was oblivious to the 

requirements of the special orders.106

This is because, even if it did occur, one three-hour training session on just the first 

iteration of the policy change was wholly insufficient to try to change a decades-long practice. In 

fact, Hickey testified that the years after Special Order 83-1, he learned that unit detectives were 

reverting back to carrying their own files on the street separate and apart from the file maintained 

by CPD.107 Nothing, however, was done about this. 

 

104 Hickey Kluppelberg Deposition 237-38 (NF-L 001177-78)

105 Hickey Kluppelberg Deposition 339 (NF-L 001280); Hickey Kluppelberg Deposition [2015] at 66-67.

106 Rinaldi Deposition at 50-54.

107 Hickey Kluppelberg Deposition 321, 327 (NF-L 001262, NF-L 001268)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 61 of 433 PageID #:15482
59

Hickey also explained that although he did a sampling prior to the special orders being 

issued, he did not do one at any time after Notice 82-2 and was not aware of anyone else 

conducting such an audit.108 Hickey testified that members of the police department were 

supposed to conduct inspections pursuant to Special Order 83-2 and 86-3 but Hickey could not 

identify any instances of audits or investigations.109 Likewise, the City has produced no 

documentation that any such inspections were ever conducted. Hickey also testified that 

detectives were not disciplined for failure to comply with the Special Orders.110 Similarly, 

Commander Stibich testified that supervisors were supposed to review files but he had no idea 

how often, when or the manner in which that review was conducted.111 Put simply, policymakers 

failed to train, review, or supervise subordinates to ensure that the Special Orders were followed. 

In fact, it appears that there was no oversight to ensure that the special orders were being 

enforced and that the street files practice was eliminated. This is particularly troubling given the 

importance and scope of the problem and is certainly deficient. You cannot expect a departmentwide, decades-long practice to be eliminated by simply issuing an order that was read at roll call 

a few times. Based on my experience, this requires extensive and ongoing training (not a onetime session of a couple of hours), careful auditing and monitoring, and meaningful discipline 

when the new special orders were not followed. Based on my review of the record, almost none 

of this occurred. Accordingly, CPD leadership either knew or was deliberately ignorant of the 

fact that the street files problem continued unabated after issuance of the special orders

F. The police investigative files show that the directives were not properly 

implemented

1. The police files from the 1985 to 1989 time period show that CPD’s policies 

were not followed 

I reviewed 180 of the 190 total investigative files from 1985-1991,112 excluding those 

that appeared to be incomplete. I reviewed them to evaluate whether the files, standing on their 

own (i.e. without comparing to a permanent retention file or defense file) demonstrated 

compliance with the 1982, 1983, and 1986 special orders, or if the practices that led to the 

wrongful prosecution of George Jones continued, like the use of informal street files and the 

failure to tell the complete story of the investigation in official reports (and instead typing up 

official reports for only the part of the investigation that led to the person charged). The files 

show that the special orders were not followed in a number of ways (which would have been 

obvious in any reasonable file audit):

 

108 Hickey Kluppelberg Deposition 160-61, 166, 167 (NF-L 001100-01, NF-L 001106-07)

109 Hickey Kluppelberg Deposition 375-76; Hickey Rivera Deposition 244, 249.

110 Hickey Fields Dep. at 10, 43. Hickey Kluppelberg Deposition 213. 

111 Stibich Testimony NF-L 007461-62

112 As set forth earlier in my report, these 180 investigative files take up 184 rows, because several 

contain multiple criminal defense files. The multiple rows for a single investigative file are italicized, and 

counted only once toward the statistics below.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 62 of 433 PageID #:15483
60

a. Handwritten notes, not on general progress reports, are still routinely 

used

As discussed above, the special orders directed officers to use GPRs to take notes, and 

were intended to eliminate the use of handwritten notes on loose sheets of paper without any 

context of who wrote the note and when. I found that detectives consistently used handwritten 

notes despite the direction in the special orders. 110 of the 180 files I reviewed, or approximately 

61%, contained handwritten notes not on GPRs.

b. To-from memos are still being used

As discussed above, the special orders also directed officers to stop using to-from memos 

to communicate investigative information, and to instead include that information in GPRs and 

Supplemental Reports. However, I found that detectives continued using to-from memos: 36 of 

the files, or approximately 20%, contained to-from memos not on official police forms. 

c. Review of permanent retention files: all relevant information in unofficial 

documents is not transcribed in official reports 

The special orders state that all relevant information must be transcribed into an official 

report, in an effort to ensure that the permanent retention file, which contains only official 

reports, provides a complete picture of the investigation. The special orders also require that 

inventories be sent to the permanent retention file for distribution to prosecutors and criminal 

defendants (as discussed above, an indication that CPD contemplated that it would only initially 

produce permanent retention files). These requirements were routinely flouted.

I was provided with copies of 138 permanent retention files, 43 of which corresponded to 

investigative files from the time period 1985 – 1991 (for one of the 44 investigative files, the 

permanent retention file was not located), and intend to rely on them to demonstrate the City’s 

failure to train, follow, or implement its special orders. See Attachments F and G.

First, I examined the permanent retention files, standing alone, to assess whether they 

communicated a complete picture of the investigation. My finding is that the permanent retention 

files in CPD are different in kind from those I’ve seen in other police departments around the 

country. Usually, an official file reads like a novel: it tells a story, with twists and turns in the 

plot and characters whose importance waxes and wanes. CPD’s permanent retention files 

routinely lack this texture; they read like a single (often final) chapter of the novel – the one that 

explains the information that led to charges against the person ultimately charged. Put another 

way, in most departments, in addition to the various strands of the investigation, there is a 

charging memo in the official file that explains the basis for charges; CPD’s entire official file is 

a charging document (or file).113

Second, I compared and contrasted the 43 permanent retention files with their 

corresponding investigative files. See Attachments F and G.

 

113 In my review of permanent retention files in Fields, which I also rely on here, I made the same 

observation and reached the same conclusion.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 63 of 433 PageID #:15484
61

The case files I reviewed are replete with examples where information on handwritten 

pages (whether on scraps of paper or GPRs) and informal memos between investigators, is not 

transferred into official reports. In many cases, the information is potentially exculpatory. By not 

transcribing the information into an official report, it is less likely to get into the permanent 

retention file, and as observed above, to criminal defendants. I have provided a number of such 

examples in Section V.D.4. Other examples include RFC 4873-75,114 RFC 11711-17,115 RFC 

10701,116 RFC 6379, RFC 16395, RFC 8213, RFC 8388, RFC 8438, RFC 11324, RFC 14712, 

and RFC 14761.

In numerous cases, including some of the example pages cited in the paragraph above, I 

found handwritten notes containing cryptic notations on a page, without context: a name, a phone 

number, an address, a license plate number, etc. By not transcribing information into official 

reports, all of the context related to a given note is lost, both to other investigators on the case 

and to prosecutors and defense attorneys. Who said it? When? Why did the detective consider 

the particular notation important enough to jot down? Because the information is not typed into 

an official report, these questions cannot be answered. In my experience, it is typical to see notes 

like this in a file, and often it is critical information (a new witness previously unknown, contact 

information for someone who couldn’t be located, a piece of information that credits or 

discredits a witness or suspect, etc.). An investigator cannot write down everything a witness is 

telling them, and so they jot down the key information so that they can remember it and 

accurately convey it later in an official report, with the full context of its relevance to the 

investigation. But in my review of hundreds of CPD files in this case (as well as Fields and 

Kluppelberg), this final step is too often not done. The result is a violation of the Special Orders, 

which require relevant information to be written down and transferred into official reports, as 

well as a failure to disclose important information to prosecutors and criminal defendants. 

Finally, many of the investigative files produced in this case are lacking inventories 

(itself a violation of policy). In addition, more than 50% of the permanent retention files do not 

contain a copy of the inventory, also a violation of the special orders. And for the cases where 

inventory sheets were included in the permanent retention files, they were often incomplete or 

the description of the documents were so generic or general so as to be unusable

d. Inventories are missing or incomplete

I also noted that documents were often added to the inventory sheet long after they were 

initially created. In some instances, some inventory sheet entries were not created until after an 

offender had been charged. In other files, the dates are either illegible, or do not appear at all. In 

other instances, there are stamped dates, but nothing shown as entered. In other instances, an 

item is shown as entered, but not date or individual entering. In other instances, a large quantity 

 

114 An anonymous note in the investigative file provides the name and description of a single offender 

who allegedly committed the crime along with information about where he could be found.

115 Notation that Arron Thomas was a purported eyewitness to the crime and that, on the day after the 

crime, Thomas was arrested in connection with an armed robbery and participated in a lineup.

116 A GPR instructing someone to bring a blue knit hat for the lineup. The offender had worn a similar 

hat, and the defendant reports that he was made to wear this hat at the lineup, years after the crime.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 64 of 433 PageID #:15485
62

of GPRs and supplemental reports were entered all on the same date. Some limited examples:

J-409858

M-079435

M-127008

The delay in creating an inventory sheet reveals three problems. One, it again 

demonstrates the amount of discretion that officers could exercise when deciding what to put into 

an Investigative File: if an inventory sheet is only created after an individual is charged, 

detectives can exercise discretion over what they deem relevant at the end of an investigation. 

Second, if the documents are not logged on the inventory sheet until after the charges are 

brought, that indicates that documents are being stored in other, undisclosed locations during the 

course of the investigations, which was precisely the problem the special orders should have 

addressed. Finally, if detectives obtain additional information after charges are brought, there is 

no mechanism in place to update the inventory sheet in the Records Division, or in the inventory 

sheet disclosed (albeit rarely) to criminal defendants.

2. The investigative files confirm that there was no training, auditing, or 

oversight to ensure compliance with the policies

These consistent failures to follow the requirements of the special orders reveal that 

detectives were not properly trained on the special orders and that there was no proper 

supervision or oversight to ensure that these special orders were followed. 

Had there been any systematic audit or review of these files, these trends would be 

immediately apparent. But my review of the files shows no signs of an audit or review. Though 

the CPD had forms designed to facilitate oversight and supervision, those forms were routinely 

missing or blank in the files I examined. This includes the following:

Homicide File (Chain of Command) Review: This form is designed to document that 

the chain of command responsible for overseeing the investigation and compliance with 

relevant departmental policies and procedures has actually done so. Many of the files that 

I reviewed either were missing the form, had only a single signature, or had no signatures 

as all. That is, there is essentially no documentation of supervisory review in the 

investigative files. This demonstrates a willful disregard among supervisors for ensuring 

that detectives were following the policies.

Investigative Case File Control: Many of these are missing. This form is designed to 

maintain case integrity and chain of custody of investigative files. It is common during an 

investigation for a file to be routinely removed for a multitude of legitimate reasons 

(crime lab, consultation with other units, review by prosecutor, court appearances, etc.) 

The case file control form documents the file’s movements so that it is clear whether and 

when information may have been copied or removed. In most of the cases that I reviewed 

they are either missing, have so few entries as to be unbelievable, or have not entries at 

all – an impossibility. This is another important form for discovery purposes because it 

should reveal all the individuals that may have contributed to the file, including from 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 65 of 433 PageID #:15486
63

other divisions or units. The failure to systematically utilize them properly, and the 

concurrent institutional failure to enforce compliance, indicates a pattern and practice of 

indifference to the policies for maintaining investigative files.

Detective Division Personnel Form: This sheet is designed to quickly track and identify 

detective division employees, where they are assigned, working hours, and equipment. It 

does not necessarily account for officers from other units. Regardless, in the majority of 

the cases reviewed, this form is missing altogether. 

Case Assignment Slip: The Case Assignment Slip is designed to document initial 

detective(s) assigned and conclusion status. These are key individuals to seek out in 

discovery for documents, depositions or testimony. Again, enough of these forms are 

missing to demonstrate a clear pattern and practice of disregard for the policy.

As discussed above, without ongoing monitoring through audits and other means to 

ensure that the new special orders were being followed and that prosecutors and criminal 

defendants were receiving complete disclosures, it was almost certain that the ingrained practice 

of using street files would continue. 

My review of records in this case and others shows that the continuation of the street files 

practice, including the failure to follow the special orders, was so rampant that it would have 

been confirmed through even a cursory auditing of files. As discussed above, 100% of the 

Investigative Files I reviewed contained evidence that the special orders were not being followed 

– they were either lacking inventories, had incomplete inventories, had handwritten notes not on 

GPRs, or had to-from memos not on GPRs; and most often, some combination of these things –

and more than 90% of defense attorney files were missing information from the Investigative 

File; even superficial audits of small samples of records would have revealed these problems.

The failure to audit or discipline for non-compliance with the policies (see Sections IV, 

V.E.2) signals that the old ways – the ways of “street files” that the CPD should have been trying 

to correct – are acceptable. It is not only that best practices require enforcement of special orders 

to give them teeth, but also, in my experience with Internal Affairs, given the circumstances here 

strict adherence was necessary to create a new culture and practice so that detectives would not 

continue with the ingrained practice of keeping undisclosed parallel files

G. There is strong evidence in the police investigative files, the Valentin 

investigation itself, and other CPD street file cases that there are yet other 

investigative files and documents that are unaccounted for by CPD and 

inaccessible to the prosecutors and criminal defendants

1. My analysis of hundreds of files indicates that investigative information is 

being kept in other repositories or being destroyed

The files I reviewed demonstrate that the investigative files were not the central 

repository for information. My review of the files revealed cases where information that should 

be included was absent from the investigative file, as well as instances when the investigative 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 66 of 433 PageID #:15487
64

files specifically reference a piece of information, but the corresponding information is not 

documented in the file. This suggests that the missing information was stored in separate files, or 

otherwise destroyed. Examples of such missing information include:

x No explanation on photographs, such as when or where the photo was taken, who/what 

is depicted in the photograph or why the detectives believe it is relevant to the 

investigation. The missing information suggests that the paperwork, notes, or other 

investigative materials that led to the photograph were maintained separately from the 

investigative files produced in this case.

x Missing forms, such as missing inventories, inventory control cards, property 

inventories, Major Crime Worksheets, Gang Crimes Daily Activity Summaries, etc.

x Other missing forms or documents including missing medical records, missing property 

inventory forms, or missing search warrant affidavits, and missing search warrant 

returns.

x No live lineup photos, where there are lineup reports. 

x Reference to other units or outside agencies processing evidence, but no documentation 

in official reports, no results, and no chain of custody. 

x Cryptic handwritten notes with no explanations as to source, relevance, or why included. 

x Numerous Xeroxed handwritten spacer/filler pages with A/4-VC; A/1-VC; A/3-VC 

which would indicate other sources for relevant documents that may, or may not, have 

been. Other examples include listing detective’s names and unit numbers on Plain pages 

– or officers from other agencies - suggesting that information is coming from other, 

unidentified sources.

Using the example of missing inventories above, they are missing in approximately 37% 

of the investigative files the City disclosed. Likewise, I identified ten investigative files produced 

by the City that contain no GPRs or handwritten notes at all.117 In my career, I am aware of no 

other instance in which a homicide investigation was conducted in which no notes were taken at 

all, and a number of the defendants in this case admit that they took notes as part of their 

investigative practices. The most likely explanation for each of the findings above is that there 

are yet other files for each of these ten homicides that contain additional investigative material 

and inventories.118 Indeed, among the files I reviewed, there are nine cases in which two 

 

117 G-063126, G-129819 , G-256674, H-167635, J-423347, K-575912, M-020288, M-381429, M538914, N-133637.

118 This is true regardless of what terminology is used to describe the files: If the City contends that the 

files produced in this case are supposed to be Investigative Files as defined under the special orders, then, 

the files demonstrate that other, parallel files were maintained containing additional investigative 

material. If the City contends they are not Investigative Files as defined under the special orders, then the 

files produced are themselves examples showing that the parallel file system continued unabated after 

issuance of the special orders.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 67 of 433 PageID #:15488
65

investigative files were produced – one that was found in the warehouse (where investigative 

files for closed cases and open cases older than ten years are supposed to go, pursuant to the 

special orders), and one that was found in the two drawers of file cabinets to which Plaintiff’s 

counsel in this case was given access.119 These cases, which suggest that there are many other 

examples among the other 45 file cabinets of drawers, are strong evidence of a continued street 

files practice in which multiple repositories are kept, each with different information; and in 

which some or all of these repositories exist outside of official channels, and are therefore 

unknown or unaccounted for by the subpoena service unit and unavailable to prosecutors and 

criminal defendants.

2. The documents and testimony from this case provide further evidence of the 

existence of additional files and the failure to preserve investigative 

information. 

In addition to the evidence above, the evidence in this case provides strong evidence that 

additional repositories of investigative information exist in unofficial and undisclosed forms. 

Detectives routinely prepared an investigative document called a Serafini report. 

Detectives prepared “Serafini reports” for open cases, which comprised leads and investigative 

developments that were passed from one shift of detectives to the next to update the 

investigation’s progress.120 The Serafini reports were not unique to Area 5; their use actually 

began in Area 4.121 Hickey, the City’s own designee, acknowledged the use of Serafini 

Reports.122 However, these Serafini reports – full of highly relevant and potentially exculpatory 

information - were never made part of the official file.

123 Indeed, there are no Serafini reports in 

any of the Valentin homicide files produced in Mr. Rivera’s criminal case or this civil case; and I 

did not see a single such document in the hundreds of investigative files I reviewed in this case, 

or other CPD cases like Fields and Kluppelberg.

Gang crimes investigators, too, had special investigative documents they created that 

were never made part of the official files, called daily activity reports or “humper” reports.124

Defendant Fallon, a gang crimes investigator assigned to the Valentin homicide investigation, 

testified that gang crimes specialists filled out a daily activity report at the end of every shift. 

These daily reports listed investigative actions taken during the shift and leads that required 

follow-up by the next shift; this included highly relevant information like details of witness 

identifications of suspects from gangbooks, witness names and contact information, and so on.125

The specialists paired each activity with a Record Division number, thus permitting the activity 

to be linked to a particular investigation.126 The daily activity reports were stored at the gang 

 

119 G-235351, J-209456, J-215119, K-530917, K-466033, N-475910, M-541953, M-556260, P-129569.

120 Rinaldi Deposition at 28-29, 34, 100-101.

121 Rinaldi Deposition at 100-101.

122 Hickey Rivera Deposition at 291-93.

123 Rinaldi Deposition at 34. “[W]hen I’d read the official file, I wouldn’t see those notes and stuff in 

there.”

124 Hickey Rivera Deposition at 134-35,138-39; Fallon Deposition at 50, 73-74.

125 Fallon Deposition at 50, 73-74, 145.

126 Fallon Deposition at 50-51.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 68 of 433 PageID #:15489
66

crimes office.127 Yet, no such documents were produced in any of the Valentin homicide files 

produced in Mr. Rivera’s criminal case or this civil case; and I did not see a single such 

document in the hundreds of investigative files I reviewed in this case, or other CPD cases like 

Fields and Kluppelberg.

Also missing from the files produced before Mr. Rivera’s criminal case, and the files 

produced more recently, are any gang crimes notes, either on official forms like GPRs or in 

unofficial forms. The files are completely devoid of such notes, despite the involvement of eight 

gang crimes investigators in the Valentin homicide investigation (Guevara, Gawrys, Noon, 

Guzman, Sparks, Zacharias, Fallon, and Sparks). And again, there is a dearth of such notes in the 

hundreds of other investigative files I also reviewed. 

This is entirely consistent with the testimony of the Defendant gang crimes investigators 

in this case, who testified in effect that gang crimes officers operated entirely outside the system.

As discussed at length above, they were not subject to the Special Orders, or any other set of 

requirements to ensure that they preserved and disclosed investigative material.128 Accordingly, 

gang crimes specialists admitted that the gang crimes officers maintained their own parallel file, 

kept by individually and in the gang crimes offices.129 Indeed, it was well known that gang 

crimes officers participated in homicide investigations, and like any other investigators created 

notes.130 Yet, those documents were not subject to preservation and disclosure requirements.131

Defendant Zacharias, for example, testified that he never recalled giving his notes to a detective 

for inclusion in an official file, or recalled seeing any of his fellow gang crimes officers do so; he 

does not know of any gang crimes officer that would produce street files in discovery; and prior 

to 1993, he cannot remember ever seeing an official file that contained gang crimes specialists’ 

notes.132 Defendant Gawrys, another gang crimes specialist, admitted that gang crimes notes and 

humper reports created to alert other detectives about what investigation needed to be completed 

were removed from the official file before the file was readied to go to storage.133 At least some 

gang crimes officers destroyed those notes as a matter of practice, with the blessing of their 

supervisors.134

Notably, it appears that gang crimes files all went missing at some point after the gang 

crimes specialists were consolidated at offices on Maxwell street. File cabinets with their case 

files were moved from the various gang crimes offices to the consolidated office on Maxwell 

Street in 1993, but it is unknown where those files are currently.135 The lack of tracking and 

 

127 Fallon Deposition at 68.

128 Hickey Rivera Deposition at 87-88, 231-33; Fallon Deposition at 60-66; Gawrys Deposition at 37-38,

188, 190.

129 Zacharias Deposition at 183-84; Fallon Deposition at 67-71; Gawrys Deposition at 37-38, 188; Spratte 

Deposition at 379. 

130 Hickey Rivera Deposition at 229, 275-76; Gawrys Deposition at 187-88, 190, 218; Fallon Deposition 

at 60-66.

131 Spratte Deposition at 264-65, 379

132 Zacharias Deposition at 193, 195-96, 200, 203-04, 206.

133 Gawrys Deposition at 213-14.

134 Fallon Deposition at 60-62, 63-66; Gawrys Deposition at 37-38, 188, 190, 209-210; Spratte 

Deposition at 379.

135 Spratte Deposition at 37, 97-99, 339, 378.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 69 of 433 PageID #:15490
67

accountability for large numbers of investigative files is an egregious departure from police 

standards.

As discussed above, the failure to put in place policies that covered gang crimes was an 

egregious omission, and one that was obvious and predictable. Indeed, as set forth in Section

V.E.1 above (pp. 53, 56-58), the need for department-wide changes was raised with CPD top 

brass (rather than just detective division), but rejected.

In sum, the investigative files contain only a portion of the investigative materials that, 

based on my experience would typically be included in a comprehensive homicide investigation 

file.136 This indicates that other parallel repositories of investigative information exist or that 

information that is supposed to be preserved is being destroyed

3. Kluppelberg and Fields are additional examples of cases in which previously 

missing street files containing highly exculpatory information were 

discovered in civil litigation decades after the original criminal trials

This case has remarkable similarities to the facts and circumstances of other CPD cases 

that I’ve examined extensively. In particular, both Fields v. City of Chicago and Kluppelberg v. 

City of Chicago, two other wrongful conviction cases from the 1980s, present additional 

examples of what the City had already learned in Jones and Palmer: that the failure to effectively 

and properly maintain, track and disclose investigative material, there is a grave risk of 

withholding exculpatory information, and in turn, of wrongful prosecutions and convictions. 

After Jones and Palmer, Fields and Kluppelberg are additional examples of cases in which 

clearly exculpatory information was buried in a street file that was not disclosed until civil 

discovery in their civil rights lawsuits, decades too late. A brief summary of each of those cases 

is provided below, and further information is contained in Attachments H and I.

a. Fields v. City of Chicago

Nathson Fields was convicted in 1986 of the 1984double murder of Jerome Smith and 

Talman Hickman. Fields’ conviction was thrown out after a court granted his petition for postconviction relief, but he was re-tried in 2009 and acquitted. He then filed a civil rights lawsuit 

against the City of Chicago in 2010, and during discovery for the civil lawsuit, a street file of 

over a hundred pages of police reports and notes concerning the Smith/Hickman murders were 

located in a file cabinet at Area Central, along with files relating to other murders. The City 

admitted that the file had not been previously disclosed to Mr. Fields or to prosecutors.

The documents newly produced in the street file, which were not contained in any of the 

earlier files, include handwritten notes, memos, and other documents identifying multiple 

alternate suspects and potential leads demonstrating that Nathson Fields was not involved in the 

Hickman and Smith homicides. Notably, it also included a previously undisclosed rap sheet for 

an alternate suspect with an issued on inquiry date stamp that undermined the prosecution’s 

theory of the case. Nathson Fields name, meanwhile, was never mentioned as a possible suspect 

 

136 Attachment E provides background materials regarding what kinds of investigative documents should 

appear in a homicide investigation, including examples of checklists used during criminal investigations. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 70 of 433 PageID #:15491
68

in any of these documents.

In December 2016, a jury found that the failure to disclose the street file to Mr. Fields 

was the result of a pattern and practice of CPD, and awarded Mr. Fields compensatory damages 

of $22 million.

b. Kluppelberg v. City of Chicago

James Kluppelberg was convicted for a 1984 fire that killed six people. In 1984 the fire 

was investigated by CPD's Bomb and Arson division and Area Three Violent Crimes. Bomb and 

Arson investigators could not determine the origin of the fire and Area Three detectives closed 

the case as accidental. But the case was re-opened in 1988. During the 1988 investigation, Area 

Three detectives found new fire investigators to rule the case an arson, and James Kluppelberg 

was coerced into confessing to the crime. At his 1988 criminal trial, Kluppelberg only had the 

documents from the 1988 Area Three investigation. The 1984 Area 3 and Bomb and Arson files 

were withheld. 

Following his exoneration, Kluppelberg filed a civil case. In 2014, during the civil case, a 

new file was discovered that had never been disclosed in the criminal proceedings. That file 

contained investigative materials from the 1984 Area Three investigation, and included critical 

exculpatory information. Specifically, it included handwritten notes that a neighbor had reported 

there was loose and dangerous wiring in the basement that got wet sometimes -- undermining the 

arson determination and supporting the evidence that the fire was accidental. It contained 

numerous references to individuals who had had arguments or fights with the victims. And the 

file also contained a memo between detectives that recounted a statement from an alternate 

suspect named Isabel Ramos who had started another porch fire in a building nearby and just 

hours before the fire for which Kluppelberg was convicted. Moreover, Ramos reported that she 

had been intoxicated at the time, could not remember what she had done, but thought she perhaps 

set other fires. 

The file was found on a pallet among other Area 3 files at the records warehouse, and it 

appears it was packed up in 1991 when Area 3 was relocated. Neither of the Bomb and Arson 

files (from 1984 or the reinvestigation in 1988) has been located, much like the gang crimes 

documents in this case.

In both of these cases, the undisclosed documents should have been produced to Mr. 

Fields and Mr. Kluppelberg before their original criminal trials in 1986 and 1988 (and at 

numerous points after that). These documents should have been produced under generally 

accepted police practices related to creating, retaining, and disclosing investigative materials.

H. The failure to turn over crucial documents in Jacques Rivera’s criminal case was 

a direct result of these practices and inadequate policies

I have familiarized myself with the underlying facts in Mr. Rivera’s case, including those 

facts set out above in Section II above, and have reviewed the various sets of police files 

produced to Mr. Rivera at the time of his criminal trial, at later dates during his criminal case, 

and during this civil litigation, including (a) the permanent retention file (Hickey 1-33); (b) the 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 71 of 433 PageID #:15492
69

investigative file produced to Mr. Rivera in April 2014 during this litigation (Wron 1-69); (c) the 

file produced by Mr. Rivera’s criminal defense attorney, Judge Wadas (RFC 469-810); (d) a set 

of photos produced to Mr. Rivera in March 2013 during this litigation from the Evidence and 

Recovered Property Section (the “ERPS file”); (e) the file produced by the Cook County State’s 

Attorney’s Office (“CCSAO file”) (SAO 1-820).

What is clear from my review is that the file Judge Wadas (Mr. Rivera’s criminal 

attorney during his original criminal trial in 1990) received was nothing more than official police 

reports later designated as the permanent retention file. When official reports are received by the 

records division as an investigation is ongoing, those reports are stamped with a date and time of 

receipt.137 A comparison of the Valentin permanent retention file and the police reports present 

in Judge Wadas’s file reveal that both sets of pages have the exact same date and time stamps, in 

the exact same location on the page, each of which were placed on the police reports when they 

were received by the records division. In other words, the police reports in Judge Wadas’s file 

came from the permanent retention file at records division.138 It is also notable that, much like 

the permanent retention file, Judge Wadas’s file contains no GPRs or handwritten notes of any 

kind. In addition, Judge Wadas testified that the file he produced in this case contained 

everything he ever received.139

The investigative file (Wron 1-69) was not produced to Judge Wadas before the criminal 

trial. It contains approximately 30 pages of investigative material that were not disclosed until 

decades later. At earliest, these pages of investigative materials we disclosed during Mr. Rivera’s 

post-conviction proceedings, close in time to CCSAO ASA Darren O’Brien beginning to work 

on the case. For years, that file was unaccounted for: the City’s employee responsible for 

investigative files at Area North, Mr. Wronkowski, has testified that he did not know where the 

investigative file had been between the time of Mr. Rivera’s criminal trial in 1990 and Mr. 

Wronkowski’s search in 2011.140 There is no investigative file control card documenting chain of 

custody for the file.

It is also apparent that the investigative file (Wron 1-69) was not produced to the CCSAO 

at the time of Mr. Rivera’s criminal trial. The CCSAO file from the time of trial is gone. The 

State’s Attorney working on Mr. Rivera’s post-conviction case, ASA O’Brien, sought to 

reconstruct the file when he started work on the post-conviction case. O'Brien had the CPD 

provide him missing police reports. The CCSAO file contains an inter-office mail from Gillian 

 

137 Later, after it is determined whether the particular investigation is one that must be permanently 

retained in the records division, the records division adds a second, “PERMANENT RETENTION” 

stamp.

138 There are a few police reports in Judge Wadas's files that don't have the time and date stamps from the 

records division. The first report is the original case incident report (RFC 532-535), and it doesn't have 

time and date stamps in the permanent retention file either (HICKEY 3-6). The second is page 3 of a 27 

August 1988 supp report (RFC 509), which like the original case report isn't stamped in the permanent 

retention file either (HICKEY 9). That leaves a single police report that is included in Judge Wadas's files 

without a time and date stamp: the September 15, 1988 Arrest Report for Jacques Rivera. That report is 

not in the permanent retention file at all.

139 Wadas Deposition at 51.

140 Wronkowski Deposition 86, 65-66.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 72 of 433 PageID #:15493
70

McLaughlin to O’Brien’s investigator McGreal; that inter-office mail envelope is in the CCSAO 

file right before the police reports produced from Area Five. In other words, it is likely that part 

of the investigative file (Wron 1-69) were produced to the CCSAO after ASA O’Brien began to 

work on the post-conviction proceedings in 2009 or later. Still later, the whole file was produced 

in the midst of this civil litigation. Further supporting this conclusion, Judge Wadas testified that 

he had everything in his file that the prosecutors had because they showed him their file at the 

time of Mr. Rivera’s criminal trial.141

The documents newly produced in the investigative file include handwritten notes and 

other investigative material that undermine the prosecution’s theory of the case, contain potential 

investigative leads, suggest investigative misconduct and demonstrate Mr. Rivera’s innocence. 

For example, the investigative file contains the rap sheet for Mr. Rivera, discussed above, that 

shows an issued on inquiry date stamp of 8/27/1988. Based on my experience in other cases 

involving the Chicago Police Department, that date stamp was placed on the rap sheet when it 

was requested by investigators working the Valentin investigation and was issued by the records 

division. The date stamp of 8/27/1988 is the same day as the Valentin shooting and is a full two 

days before 8/29/1988, the date on which police report that Orlando Lopez identified Mr. Rivera 

in a photo album. This document is contained only the investigative file – it is excluded from the 

permanent retention file, the CCSAO file, and Judge Wadas’s file. It is highly exculpatory 

because it establishes that the defendants deemed Mr. Rivera a suspect before the sole

eyewitness supposedly identified him. This fact could have been used to impeach all of the 

State’s witnesses at trial.

Other documents in the investigative file containing relevant investigative material not 

produced to Judge Wadas are WRON 0001-0008, 0011-0014, 0018-0021, 0037-0038, 0042, 

0045-0048, 0052-0069. They include:

x As a general matter, all GPRs created and preserved in connection with the Valentin 

investigation are excluded from Judge Wadas’s file. In addition:

x WRON 0002-0003: the investigative file inventory, which is supposed to list all of the 

investigative materials created during the course of the investigation. Without the 

investigative file inventory, it is impossible to know what documents should be contained 

in a police investigative file and when they were placed in that file.

x WRON 0012: a handwritten report documents that Felix Valentin died on September 14, 

1988, after contracting a bacterial infection earlier in his hospital treatment. 

x WRON 0037: a photograph of Jacques Rivera taken either after or before the second 

lineup.

x WRON 0045: an evidence report on the photographs taken of the second lineup.

x WRON 0047-0048: the criminal complaint.

x WRON 0056: an arrest report, showing that Mr. Rivera was arrested on 8/30/1988 at 11 

p.m. in connection with the Valentin shooting and relating that hold papers were 

submitted “due to the fact that the witness is not available to view a physical lineup 

which will be held on August 31, 1988,” which is evidence that Mr. Rivera was placed in 

 

141 Wadas Deposition at 86-87.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 73 of 433 PageID #:15494
71

a physical lineup in this case prior to 9/15/1988.

x WRON 0057: a hold form, showing that Mr. Rivera needs to be held at the department 

because “the witness to this case [Lopez] will not be available until tomorrow’s date,” 

further evidence of a first physical lineup. The hold sheet notes that there is an 

expectation that Jacques will be charged with the Valentin shooting at 7 p.m. on 

8/31/1988. 

x WRON 0058: an arrest report, showing that Jose Rodriguez is arrested on 8/31/1988 at 1 

a.m. for the Valentin shooting. The report states that Rodriguez was identified by the 

victim.

x WRON 0059: a hold form for Mr. Rodriguez, dated 8/31/1988, stating that “a lineup 

must be viewed by the witness in this case” and noting that there is an expectation that 

Rodriguez will be charged with the Valentin shooting at 1 a.m. on September 2, 1988. 

Again, this is further evidence of an earlier physical lineup.

x WRON 0064: a GPR listing the six participants in the earlier physical lineup, with their 

biographical information and addresses.

x WRON 0062: an evidence form, dated 8/31/1988, documenting the placement into 

evidence of 6 photographs corresponding to the six individuals participating in the 

8/31/1988 or 9/1/1988 physical lineup. This is further evidence of a first physical lineup. 

The submission of this evidence form and accompanying photos late on the evening of 

8/31/1988 contradicts the official police account that the photos were used in a photo 

array procedure with the victim Felix Valentin on 9/1/1988.

x WRON 0052: a form to release Mr. Rivera from custody after the first lineup. 

x WRON 0063: the form to release Mr. Rodriguez from custody after the first lineup.

x WRON 0060-61, 0065: reports about the 5 cartridge cases recovered at the scene. 

x WRON 0055, 0067: rap sheets for Mr. Rivera. Neither of the rap sheets in Judge Wadas’s 

files matches these rap sheets in the investigative file.

x WRON 0053: McLaughlin GPR dated 8/27/1988, 8/28/1988, or 8/29/1988, containing 

the original description purportedly given by Orlando Lopez.

x WRON 0054: Leonard GPR containing the canvass of nearby buildings.

x WRON 0069: McLaughlin GPR dated 8/27/1988, the date of the shooting, reflecting the 

hospital interview of Israel Lopez. After Israel’s description of what he saw and did, it 

states, “Girlfriend’s brother – [Orlando] Macho Lopez – 13 yo saw incident – has not 

been interviewed – Kings.”

In addition to all of this, the ERPS file, which was not produced to Mr. Rivera until 2013 

during this lawsuit, contains six photographs that appear to be of individuals participating in the 

first physical lineup. Those photos also would have shown that Mr. Rivera was placed in an 

initial lineup on 8/31/1988 or 9/1/1988. 

All evidence regarding the earlier physical lineup not produced to the CCSAO, to Mr. 

Wadas, or to Mr. Rivera would have permitted attorneys in the criminal justice system to 

conduct a contemporaneous investigation to determine if Mr. Rivera had stood in a physical 

lineup before the 9/15/1988 in which he was supposedly identified, who had viewed the lineup, 

and who had been selected in the lineup. There is no documentation of a first physical lineup in 

the police file. According to Lopez, he viewed such a lineup and picked Mr. Rivera. According 

to Mr. Rivera and others, they stood in such a lineup. Mr. Rivera was released following that 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 74 of 433 PageID #:15495
72

lineup, suggesting strongly that he was not identified and instead Lopez identified another 

participant in that lineup. The defendants’ entire case against Mr. Rivera rested on Lopez, the 

sole eyewitness, and if he had failed to pick Mr. Rivera in an initial lineup, that would have been 

highly exculpatory evidence.

The investigative files in Valentin investigation suffer from the same systemic problems 

observed in the investigative files I reviewed as a whole, from this case and others such as Fields 

and Kluppelberg. In sum, the documents in the investigative files are highly relevant to the 

investigation, and should have been produced to Mr. Rivera before his original criminal trial in 

1990 (and at every other point at which he engaged with the criminal justice system after that). 

These documents would have been produced under generally accepted police practices related to 

creating, retaining, and disclosing investigative materials.

CONCLUDING STATEMENT

I have provided my opinions based upon my training, experience, and after a careful 

evaluation of the totality of the materials and circumstances in this matter. I utilized all of the 

facts and data known to me, and applied generally accepted police management principles and 

methods. I hold the opinions set forth above to a reasonable degree of professional certainty in 

the law enforcement community, and based on longstanding and well-accepted law enforcement 

practices. 

I reserve the right to supplement or modify this report and my opinions expressed in the 

report to the extent that additional information is presented to me and to the extent permitted by 

rules.

Pursuant to 28 U.S.C Section 1746, I declare under penalty of perjury that the 

foregoing is true and correct.

Michael D. Brasfield

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 75 of 433 PageID #:15496
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT A 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 76 of 433 PageID #:15497
Michael Brasfield and Associates, Inc.

641 Olele Point Road Phone: 360-301-4465

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com

Compliance with Federal Rule of Procedure 26 (a) (2) (B)

Testimony at Trial or Deposition for Preceding Four Years

I have either testified at trial or deposition as a witness in Federal, State, and Local Courts 

throughout my law enforcement career. These appearances have been in both civil and criminal 

matters. I have appeared in Federal District Courts in Fort Lauderdale, Miami, Seattle, and 

Tacoma. Civil litigation involving all types of police procedures and practices have included the 

use of force; police pursuits; deadly force; negligent selection, training, and retention; as well as 

class action and Federal Section 1983 civil rights cases. Specifically, testimony and/or 

deposition over the last four years are as follows:

x In the United States District Court (Eastern District of Washington) – Creach v. Spokane 

County, et al. – Cause No. 2:2011cv00432 – For Defendant (Deposition & Trial) –

42:1983 Civil Rights Act. - Fatal shooting by police officer.

x In the Superior Court of the State of Washington (Spokane County) – Glidden v. City of 

Spokane Valley, et al. – Cause No. 11-2-04437-2 – For Defendant (Deposition & Trial) –

Police Shooting - Negligent training, supervision, retention.

x In the United States District Court (Northern District of Illinois, Eastern Division) – April 

Ortiz – Cause No. 04-CV-7423 – For Plaintiff (Deposition, Rebuttal, Trial) – 42 USC, 

1983 - Denial of Medical Care.

x In the United States District Court (Eastern District of Washington) – Duncan v. Liberty 

Lake – Cause No. 2:2012cv00219 – For Defendant (Deposition & Trial) – Violation of 

Civil Rights.

x In the United States District Court (Eastern District of Washington) - Thoma v. City of 

Spokane – Cause No. CV-12-156-EFS – For Defendant (Deposition) – 42 U.S.C. Sec. 

1983

x In the United States District Court (Western District of Washington) – Theoharis v. 

Rongen – Cause No. 2:13-cv-01345-RAJ – For Plaintiff (Deposition) – 42 U.S.C Sec. 

1983 – Excessive and Unreasonable Force and Unreasonable Search and Seizure.

x In the Court of Common Pleas of Allegheny County, Pennsylvania – Commonwealth of 

Pennsylvania v. Leon Ford (Trial) – Cause No. CC201303273 – For Defendant -

Criminal charges.

x In the Superior Court for the State of Alaska (Anchorage) – Boshears v. State of Alaska –

Cause No. 3AN-13-07970CI – For Plaintiff (Deposition) – Negligence of Duty.

x In the United States District Court (Northern District of Illinois, Eastern Division) –

Percy Coleman v. City of Chicago – Cause No. 12C-10061 – For Plaintiff (Deposition) –

42 USC, 1983 – Wrongful Death.

x In the United States District Court (Northern District of Illinois, Eastern Division) – Deon 

Patrick v. City of Chicago – Cause No. 14C-3658 – For Plaintiff (Deposition) – 42 USC, 

1983 – Wrongful Conviction.

x In the United States District Court (Northern District of Illinois, Eastern Division) –

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 77 of 433 PageID #:15498
James Kluppelberg v. City of Chicago – Cause No. 1:13-cv-03963 – For Plaintiff

(Deposition & Rebuttal Deposition) – 42 USC, 1983 – Wrongful Conviction.

x In the United States District Court (Eastern District of Washington) - Rosen v. Pend 

Oreille County – Cause No. CV-15-00153-RMP – For Defendant (Deposition) – 42 

U.S.C. Sec. 1983 – Employment.

x In the United States District Court (Northern District of Illinois, Eastern Division) –

Nathson Fields v. City of Chicago – Cause No. 1:10-cv-1168 – For Plaintiff (Deposition

& Trial) – 42 USC, 1983 – Wrongful Conviction / Monell Issues.

x In the Superior Court of the State of Washington (Pierce County) – Johnson v. City of 

Steilacoom, et al. – Cause No. 14-2-13145-9 – For Defendant (Trial) – Discrimination -

Negligent training, supervision, retention.

In addition, I have provided my expert opinion, reviewed, consulted, and/or been retained in civil 

litigation related matters for plaintiffs and defense attorneys or governmental entities over 50 

times in the last 10 years in Riverside County (CA), Trinity County (CA), Prescott County (AZ), 

Chicago (IL), Garland (TX), Bradley County (TN), Hazard (KY), Clallam County (WA), 

Franklin County (WA), Reno (NV), Unalakleet (AK), Whatcom County (WA), Albany (OR), 

Jackson (MS), Seattle (WA), Columbia (SC), and Sweetwater County (WY).

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 78 of 433 PageID #:15499
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT B 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 79 of 433 PageID #:15500
Attachment B - Report of Material Reviewed

Plaintiff's Expert – Michael D. Brasfield

Jacques Rivera v. Guevara, et al.

No. 12 CV 4428

I have been provided and have reviewed the following documents and materials concerning this 

case:

x Pleading – Rivera v. Guevara Complaint

x Transcript – Jacques Rivera Criminal Case Transcripts

x Transcript – Jacques Rivera Criminal Sentencing Transcripts

x Transcript – Jacques Rivera Post-Conviction Transcripts (Part 1)

x Transcript – Jacques Rivera Post-Conviction Transcripts (Part 2)

x Transcript – Jacques Rivera Post-Conviction Transcripts (Part 3)

x Court Order – Granting Certificate of Innocence

x Court Order – Granting New Trial

x Pleading – Motion to Compel Street Files Discovery & Exhibits

x Pleading – Supplement to Motion to Compel Street Files Discovery & Exhibits

x Case File – Permanent Retention File (Hickey 1-33)

x Case File – Detective Street File for K 371 955 (Wron 1-69)

x Case File – Criminal Defense Attorney, Judge Wadas File (RFC 469-810)

x Case File – State’s Attorney’s Office File (SAO 1-820)

x Case File – Original Production in Civil Case (1-114)

x Line Up – Photos of First Lineup

x Line Up – Photos of Second Lineup

x Jacques Rivera FOIA Requests (JR-L 10492-10503)

x Individual Defendants’ Joint Answer to Plaintiff’s Complaint and Affirmative 

Defenses

x Defendant City of Chicago’s Answer, Affirmative Defenses, and Jury Demand to 

Plaintiff’s Complaint

x City of Chicago’s Amended Response to Plaintiff’s Seventeenth Set of Requests to 

Produce Documents to the City of Chicago, p.2-3

x City of Chicago’s Response to Plaintiff’s Second Set of Interrogatories

x City of Chicago’s Response to Plaintiff’s Fifth Set of Interrogatories

x Plaintiff’s Response and Supplemental Response to City’s Fourth Interrogatories

x Plaintiff’s Response and Second Amended Response to City’s Fifth Interrogatories

x February 18, 2016 Letter from S. Grusin to E. Rosen

x Chicago Police Department Special Orders Regarding Investigative Files

o Chicago Police Department Teletype

o Detective Division Notice 82-2

o Special Order 83-1

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 80 of 433 PageID #:15501
o Special Order 83-2

o Special Order 86-3

o Standard Operating Procedure 1988

x Chicago Police Department General Orders Regarding Lineups (83-5, 88-18, 06-02, 

as well as amendments)

x June 11, 2015 Stipulation Between the Parties

x Court rulings in Jones v. City of Chicago

x Court rulings in Palmer v. City of Chicago

x Obrycka v. City of Chicago, 913 F.Supp.2d 598 (2012)

x Fields Street File (from Area Central basement)

x Kluppelberg Street File (from pallettes found at CPD warehouse)

x Fields Verdict Form and Verdict Orders, Jury Instructions, Judgment, and Third 

Amended Complaint

x Gang Crimes Activity Summary (RFC 20172-73)

x Photos of Reynaldo Guevara (RFC 19393, 19519, JR-L 63213)

x FBI 302 regarding interview with Mohamed Omar (6/23/2001)

x Complaint from Juan Johnson vs. Reynaldo Guevara, 5 C 1042

x Complaint from Jose Maysonet v. Richard Beuke and Steven Rueckert

x Verdict form from Juan Johnson vs. Reynaldo Guevara, 5 C 1042

x Opinion in Obrycka v. City of Chicago, 7 C 2372 (12/20/2012)

x Opinion in Hunt v. Jaglowski, 85 C 1976 (7/21/1987)

x Opinion in People of Illinois v. Jose Montanez, 1-13-3726 (6/7/2016)

x Certificate of Innocence order from People of Illinois vs. Jose Montanez, 1993 CR 

1817303 (11/2/2016)

x Certificate of Innocence order from People of Illinois vs. Armando Serrano, 1993 CR

1817301 (11/2/2016)

x Opinion granting suppression hearing from People of Illinois v. Arturo Reyes and Gabriel 

Solache, 1998 CR 1244002-03 (6/29/2016)

x Sidley Austin, Memorandum, Guevara Investigation – Armando Serrano and Jose 

Montanez, 3/3/2015

x Sidley Austin, Memorandum, Guevara Investigation – Robert Bouto, 3/3/2015

x Sidley Austin, Memorandum, Guevara Investigation – Roberto Almodovar, 2/9/2015

x Sidley Austin, Memorandum, Guevara Investigation – Gabriel Solache and Arturo Reyes, 

12/12/2014

x Jacques Rivera Deposition (11/11/2014, 7/26/2016)

x Reynaldo Guevara Deposition (12/23/2013)

x Orlando Lopez Deposition (5/29/2013)

x Edward Mingey Deposition (4/4/2014)

x Daniel Noon Deposition (2/13/2014)

x Joseph Sparks Testimony (12/11/2013)

x Russell Weingart Deposition (6/17/2014)

x Paul Zacharias Deposition (1/17/2014)

x Gillian McLaughlin Deposition (5/24/2013)

x Stephen Gawrys Deposition (1/21/2014)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 81 of 433 PageID #:15502
x Joseph Fallon Testimony (2/20/2014)

x John Guzman Deposition (11/24/2013)

x John Leonard Deposition (5/17/2013)

x James Spratte Deposition (6/23/2016)

x James Hickey Deposition, Rivera v. Guevara (5/6/14)

x James Hickey Deposition, Rivera v. Guevara (6/10/14)

x James Hickey Deposition, Kluppelberg – Part 1 (7/29/14)

x James Hickey Deposition, Kluppelberg – Part 2 (7/31/14)

x James Hickey Deposition, Kluppelberg (6/9/2015) 

x James Hickey Trial Testimony, Fields (April 2014)

x James Hickey Trial Testimony, Fields (November 2016) 

x Brasfield Trial Testimony, Fields (November 2016)

x Anthony Wronkowski Deposition (4/9/14)

x Judge Wadas Deposition (1/28/2014, 2/5/14)

x William Dorsch Deposition (4/14/15)

x Dr. Arthur Sharkey Deposition (1/15/16)

x Ramon Lopez Deposition (5/6/13)

x George Ruiz Deposition (5/6/13)

x Carlos Oliviero Deposition (5/18/13)

x Angel Villafane Deposition (5/18/13)

x Richard Beuke Deposition (7/2/15)

x Robert Klimas Deposition (5/19/16)

x Kathleen Loughran Deposition, Fields

x All of the materials reviewed in connection with my work on the case Fields v City of 

Chicago, which are set out in attachment/exhibit H to this report.

x All of the materials reviewed in connection with my work on the case Kluppelberg v City 

of Chicago, which are set out in attachment/exhibit I to this report.

x ADD

I also reviewed numerous investigative files, criminal defense files, and permanent retention 

files, as well as a spreadsheet of information from plaintiff’s attorneys related to these files.

x CPD Public Defender Files

o G063126 Sherman Addison [JR-L 212772-215312].pdf

o G129819 Joaquin Gonzales [JR-L 202873-203213].pdf

o G235351 Jesus Hernandez [JR-L 203214-203395].pdf

o G235351 Torres Hipolito [JR-L 203396-203556].pdf

o G256674 Richard Gonzalez [JR-L 203557-203855].pdf

o G321911 Roberto Moreno [JR-L 203856-203878].pdf

o H167635 Cynthia Lee [JR-L 203879-204073].pdf

o H375595 Jose Delvalle [JR-L 204074-204939].pdf

o H422157 Michael Boyd [JR-L 204940-205068].pdf

o J052070 Michael Green [JR-L 215313-217081].pdf

o J080925 Samuel Slack [JR-L 217082-217479].pdf

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 82 of 433 PageID #:15503
o J209456 Bruce Andras [JR-L 205069-206061].pdf

o J209456 David Quinones [JR-L 217480-220059].pdf

o J209456 Marc Johnson [JR-L 206062-206321].pdf

o J215119 Jerry Buckner [JR-L 220060-221685].pdf

o J353821 Orlando Cintron [JR-L 206322-206366].pdf

o J409858 Richard Sanchez [JR-L 206367-206459].pdf

o J423347 Elmer Madrid [JR-L 221686-221866].pdf

o K292921 LaTonya Pitchfork [JR-L 206460-206763].pdf

o K417078 Orval Fain [JR-L 206764-206822].pdf

o K455932 Felipe Rodriguez [JR-L 206823-207000].pdf

o K530917 Amos Walker [JR-L 207001-207472].pdf

o K575912 Michael Armstead [JR-L 227867-223599].pdf

o M020288 Warren Robinson [JR-L 207473-207563].pdf

o M184949 Francisco Benitez [JR-L 207564-207966].pdf

o M258570 Curtis Kirkland [JR-L 223600-224210].pdf

o M287641 Clarence Roberts [JR-L 224211-225194].pdf

o M381429 Warren Murdock [JR-L 225195-226908].pdf

o M538914 Henry Robinson [JR-L 226909-227343].pdf

o M579697 Ras Green [JR-L 227344-227918].pdf

o N028256 Jessie Swanigan [JR-L 207967-208332].pdf

o N053000 Pierre Mahone [JR-L 208333-208519].pdf

o N133637 Allen Whittington [JR-L 208520-209645].pdf

o N162782 Tomas Nieves [JR-L 227919-228812].pdf

o N176796 Tyrece Williams [JR-L 209646-209725].pdf

o N203334 David Delgado [JR-L 209726-209738].pdf

o N262285 Jose Baez [JR-L 209739-210229].pdf

o N267450 Timothy Lee [JR-L 228813-229198].pdf

o N475910 Ricardo Miranda [JR-L 210230-210456].pdf

o N517875 Calvin McLemore [JR-L 212758-212771].pdf

o N517875 Rolando Serrano [JR-L 210457-210744].pdf

o N581836 Samuel Robinson [JR-L 210745-211080].pdf

o N592324 Glen Miller [JR-L 211081-211830].pdf

o P048272 Richard Conner [JR-L 229199-230507].pdf

o P060434 Demetrius Thomas [JR-L 211831-212422].pdf

o P128067 Robert Machine [JR-L 230508-231556].pdf

o P272087 Demetrius Johnson [JR-L 212423-212489].pdf

o P526822 Miguel Borrotto [JR-L 212490-212757].pdf

x CPD Investigative Files

o G063126 (RFC02417 - RFC02485).pdf

o G129819 (RFC02678 - RFC02729).pdf

o G235351 (RFC02919 - RFC02981).pdf

o G256674 (RFC02982 - RFC03028).pdf

o G321911 (RFC03322 - RFC03422).pdf

o H167635 (RFC04135 - RFC04168).pdf

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 83 of 433 PageID #:15504
o H375595 (RFC04585 - RFC04614).pdf

o H422157 (RFC04653 - RFC05112).pdf

o J052070 (RFC05471-05464).pdf

o J080925 (RFC05978 - RFC06127).pdf

o J209456 (RFC06322 - RFC06444).pdf

o J215119 (RFC06445 - RFC06592).pdf

o J353821 (RFC06630 - RFC06662).pdf

o J409858 (RFC07033 - RFC07146).pdf

o J423347 (RFC07147 - RFC07200).pdf

o K292921 (RFC07896 - RFC08058).pdf

o K417078 (RFC08152 - RFC08224).pdf

o K455932 (RFC08329 - RFC08465).pdf

o K530917 (RFC08733 - RFC08842).pdf

o K575912 (RFC08843 - RFC08894).pdf

o M020288 (RFC08895 - RFC08937).pdf

o M184949 (RFC0968 - RFC09720).pdf

o M258570 (RFC09904 - RFC10101).pdf

o M287641 (RFC10157 - RFC10242).pdf

o M381429 (RFC10243 - RFC10288).pdf

o M538914 (RFC10321 - RFC10345).pdf

o M579697 (RFC10727 - RFC10861).pdf

o N028256 (RFC11204 - RFC11503).pdf

o N053000 (RFC11504 - RFC11567).pdf

o N133637 (RFC11865 - RFC11905).pdf

o N162782 (RFC11906 - RFC12064).pdf

o N176796 (RFC12065 - RFC12161).pdf

o N203334 (RFC12328 - RFC12436).pdf

o N262285 (RFC12572 - RFC12735).pdf

o N267450 (RFC12736 - RFC12831).pdf

o N475910 (RFC13109 - RFC13182).pdf

o N517875 (RFC13249 - RFC13500).pdf

o N581836 (RFC13501 - RFC13671).pdf

o N592324 (RFC13672 - RFC13742).pdf

o P049272 (RFC13890 - RFC14195).pdf

o P060434 (RFC14415 - RFC14565).pdf

o P128067 (RFC14566 - RFC14774).pdf

o P272087 (RFC15446 - RFC15481) (Investigative File).pdf

o P526822 (RFC16275 - RFC16401).pdf

o RFC 20380 - 20420 Area North Inspection

o RFC 20421 - 20445 Area North Inspection

o RFC 20446 - 20471 Area North Inspection

o RFC 20472 - 20539 Area North Inspection

o RFC 20540 - 20590 Area North Inspection

o RFC 20591 - 20612 Area North Inspection

o RFC 20613 - 20632 Area North Inspection

o RFC 20633 - 20656 Area North Inspection

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 84 of 433 PageID #:15505
o RFC 20657 - 20675 Area North Inspection

o RFC 20676 - 20760 Area North Inspection

o RFC 20761 - 20823 Area North Inspection

o RFC 20824 - 20868 Area North Inspection

o RFC 20869 - 20896 Area North Inspection

o RFC 20897 - 21030 Area North Inspection

o RFC 21031 - 21083 Area North Inspection

o RFC 21084 - 21103 Area North Inspection

o RFC 21104 - 21383 Area North Inspection

o RFC 21394 - 21494 Area North Inspection

o RFC 21495 - 21649 Area North Inspection

o RFC 21650 - 21820 Area North Inspection

o RFC 21821 - 21833 Area North Inspection

o RFC 21834 - 21852 Area North Inspection

o RFC 21853 - 21889 Area North Inspection

o RFC 21890 - 21962 Area North Inspection

o RFC 21963 - 22028 Area North Inspection

o RFC 22029 - 22076 Area North Inspection

o RFC 22077 - 22188 Area North Inspection

o RFC 22189 - 22327 Area North Inspection

o RFC 22328 - 22361 Area North Inspection

o RFC 22362 - 22452 Area North Inspection

o RFC 22453 - 22487 Area North Inspection

o RFC 22488 - 22557 Area North Inspection

o RFC 22558 - 22593 Area North Inspection

o RFC 22594 - 22653 Area North Inspection

o RFC 22654 - 22843 Area North Inspection

o RFC 22844 - 22970 Area North Inspection

o RFC 22971 - 23025 Area North Inspection

o RFC 23026 - 23138 Area North Inspection

o RFC 23139 - 23240 Area North Inspection

o RFC 23241 - 23467 Area North Inspection

o RFC 23468 - 23566 Area North Inspection

o RFC 23567 - 23709 Area North Inspection

o RFC 23710 - 23799 Area North Inspection

o RFC 23800 - 23962 Area North Inspection

o RFC 23963 - 24136 Area North Inspection

o RFC 24137 - 24377 Area North Inspection

o RFC 24378 - 24505 Area North Inspection

o RFC 24506 - 24561 Area North Inspection

o RFC 24562 - 24595 Area North Inspection

o RFC 24596 - 24671 Area North Inspection

o RFC 24672 - 24915 Area North Inspection

o RFC 24916 - 25721 Area North Inspection

x Permanent Retention Files

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 85 of 433 PageID #:15506
o G025122 (RFC158644 - RFC158716).pdf

o G028593 (RFC159390 - RFC159448).pdf

o G063126 (RFC158717 - RFC158782).pdf

o G067109 (RFC158783 - RFC158837).pdf

o G069345 (RFC158838 - RFC158865).pdf

o G077193 (RFC158866 - RFC158921).pdf

o G129819 (RFC158925 - RFC158969).pdf

o G159909 (RFC158970 - RFC159066).pdf

o G235351 (RFC160869 - RFC160892).pdf

o G256674 (RFC159067 - RFC159131).pdf

o G303248 (RFC159133 - RFC159158).pdf

o G317267 (RFC159159 - RFC159192).pdf

o G317507 (RFC159193 - RFC159217).pdf

o G321911 (RFC159219 - RFC159242).pdf

o G382131 (RFC159243 - RFC159275).pdf

o G418721 (RFC159276 - RFC159329).pdf

o G451229 (RFC159330 - RFC159351).pdf

o G471800 (RFC159352 - RFC159389).pdf

o H064504 (RFC159449 - RFC159502).pdf

o H091575 (RFC159503 - RFC159522).pdf

o H094573 (RFC159523 - RFC159557).pdf

o H095844 (RFC159558 - RFC159592).pdf

o H100760 (RFC159593 - RFC159639).pdf

o H105557 (RFC159640 - RFC159685).pdf

o H126865 (RFC159686 - RFC159729).pdf

o H167635 (RFC159730 - RFC159762).pdf

o H172729 (RFC159763 - RFC159797).pdf

o H174403 (RFC159798 - RFC159844).pdf

o H193697 (RFC159845 - RFC159903).pdf

o H208106 (RFC159904 - RFC159951).pdf

o H265414 (RFC159952 - RFC159971).pdf

o H279780 (RFC159972 - RFC160001).pdf

o H316198 (RFC160894 - RFC160923).pdf

o H323287 (RFC160003 - RFC160030).pdf

o H375595 (RFC160031 - RFC160068).pdf

o H376814 (RFC160069 - RFC160107).pdf

o H422157 (RFC160108 - RFC160175).pdf

o H487637 (RFC160176 - RFC160203).pdf

o J052070 (RFC160204 - RFC160282).pdf

o J053513 (RFC160283 - RFC160366).pdf

o J075073 (RFC160367 - RFC160397).pdf

o J080925 (RFC160398 - RFC160439).pdf

o J117497 (RFC160440 - RFC160474).pdf

o J139200 (RFC160475 - RFC160509).pdf

o J209456 (RFC160510 - RFC160549).pdf

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 86 of 433 PageID #:15507
o J215119 (RFC160550 - RFC160580).pdf

o J252204 (RFC160581 - RFC160616).pdf

o J353821 (RFC160617 - RFC160636).pdf

o J355220 (RFC160637 - RFC160687).pdf

o J369257 (RFC160688 - RFC160715).pdf

o J388481 (RFC160716 - RFC160763).pdf

o J409858 (RFC160764 - RFC160790).pdf

o J423347 (RFC160791 - RFC160843).pdf

o J478062 (RFC160844 - RFC160868).pdf

o K103034 (RFC160924 - RFC160955).pdf

o K176170 (RFC160956 - RFC160979).pdf

o K197321 (RFC160980 - RFC161015).pdf

o K205158 (RFC161016 - RFC161041).pdf

o K227675 (RFC161042 - RFC161075).pdf

o K285989 (RFC161076 - RFC161122).pdf

o K292921 (RFC161123 - RFC161171).pdf

o K417078 (RFC161172 - RFC161201).pdf

o K419172 (RFC161202 - RFC161235).pdf

o K455932 (RFC161236 - RFC161271).pdf

o K466033 (RFC161272 - RFC161330).pdf

o K468422 (RFC161331 - RFC161367).pdf

o K502173 (RFC161368 - RFC161391).pdf

o K530917 (RFC161392 - RFC161417).pdf

o K575912 (RFC161418 - RFC161453).pdf

o M020288 (RFC161454 - RFC161490).pdf

o M027036 (RFC161491 - RFC161533).pdf

o M079435 (RFC161534 - RFC161630).pdf

o M127008 (RFC161631 - RFC161645).pdf

o M165445 (RFC161646 - RFC161700).pdf

o M184949 (RFC161702 - RFC161735).pdf

o M245807 (RFC161736 - RFC161783).pdf

o M258570 (RFC161784 - RFC161828).pdf

o M264219 (RFC161829 - RFC161888).pdf

o M287641 (RFC161889 - RFC161918).pdf

o M381429 (RFC161919 - RFC161962).pdf

o M400227 (RFC161963 - RFC161996).pdf

o M538914 (RFC161997 - RFC162017).pdf

o M541953 (RFC162018 - RFC162053).pdf

o M546558 (RFC162054 - RFC162076).pdf

o M551461 (RFC162077 - RFC162115).pdf

o M556260 (RFC162116 - RFC162156).pdf

o M558552 (RFC162157 - RFC162190).pdf

o M579697 (RFC162191 - RFC162219).pdf

o M599001 (RFC162220 - RFC162254).pdf

o N016505 (RFC162255 - RFC162282).pdf

o N018105 (RFC162283 - RFC162326).pdf

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 87 of 433 PageID #:15508
o N028256 (RFC162327 - RFC162389).pdf

o N050133 (RFC162390 - RFC162428).pdf

o N053000 (RFC162429 - RFC162448).pdf

o N114280 (RFC162449 - RFC162492).pdf

o N133637 (RFC162493 - RFC162530).pdf

o N162782 (RFC162531 - RFC162577).pdf

o N176796 (RFC162578 - RFC162612).pdf

o N192214 (RFC192613 - RFC162641).pdf

o N201263 (RFC162642 - RFC162682).pdf

o N203334 (RFC162683 - RFC162708).pdf

o N237529 (RFC162709 - RFC162759).pdf

o N262285 (RFC162760 - RFC162808).pdf

o N267450 (RFC162809 – RFC 162836).pdf

o N363181 (RFC162837 - RFC162866).pdf

o N413068 (RFC163754 - RFC163781).pdf

o N414150 (RFC162867 - RFC162896).pdf

o N475910 (RFC162897 - RFC162924).pdf

o N513129 (RFC162925 - RFC162967).pdf

o N517875 (RFC162968 - RFC163014).pdf

o N581836 (RFC163015 - RFC163056).pdf

o N592324 (RFC163057 - RFC163066).pdf

o P025950 (RFC163067 - RFC163097).pdf

o P049272 (RFC163098 - RFC163137).pdf

o P051734 (RFC163138 - RFC163157).pdf

o P054399 (RFC163158 - RFC163220).pdf

o P128067 (RFC163221 - RFC163269).pdf

o P129569 (RFC163270 - RFC163315).pdf

o P141860 (RFC163782 - RFC163816).pdf

o P175665 (RFC163316 - RFC163341).pdf

o P190627 (RFC163342 - RFC163383).pdf

o P218019 (RFC163384 - RFC163412).pdf

o P251800 (RFC163413 - RFC163444).pdf

o P272087 (RFC163445 - RFC163473).pdf

o P310965 (RFC163474 - RFC163510).pdf

o P317758 (RFC163511 - RFC163537).pdf

o P342256 (RFC163538 - RFC163561).pdf

o P348565 (RFC163562 - RFC163580).pdf

o P372509 (RFC163581 - RFC163621).pdf

o P402641 (RFC163622 - RFC163639).pdf

o P474894 (RFC163640 - RFC163727).pdf

o P526822 (RFC163728 - RFC163753).pdf

x CCSAO Files

o J209456 – David Quinones, Bruce Andras, Marc Johnson

o P526822 - Miguel Borrotto

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 88 of 433 PageID #:15509
o N028256 – Jesse Swanigan

o M258570 – Curtis Kirkland

o N162782 – Tomas Nieves

o P272087 – Demetrius Johnson

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 89 of 433 PageID #:15510
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT C 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 90 of 433 PageID #:15511
Attachment C - Compensation

Report of Plaintiff’s Expert – Michael D. Brasfield

Jacques Rivera v. Guevara, et al.

No. 12 CV 4428

My compensation for work related to this case is $300 per hour, with a four-hour minimum. 

Deposition and trial testimony is billed at a flat rate of $2400 per calendar day. Time spent

traveling and waiting to testify is considered billable time. Reasonable expenses may be charged

with prior approval.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 91 of 433 PageID #:15512
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT D 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 92 of 433 PageID #:15513
1

Michael D. Brasfield - Curriculum Vitae

Education:

Bachelor of Arts, Police Administration - University of Washington, Seattle, WA

Senior Management Institute for Police - Police Executive Research Forum, Washington, 

D.C.

Professional Experience:

2003-2009 Elected Sheriff of Jefferson County, Washington

After retiring for a second time, and returning to the small rural county that I had chosen 

as my permanent retirement home, I ran for public office. This 1,815 square mile, 

predominantly rural, county has a full time resident population of only 26,000. The 

Jefferson County Sheriff's Office, established in 1853, is one of the oldest law 

enforcement organizations in the state of Washington. The Sheriff's Office budget for 

fiscal year 2008 was $4.5 million. The Office has 50 employees and a large network of 

volunteers and reserve deputies. I was re-elected to a 2nd term which began on January 1, 

2007 by an 80% majority. I retired from this office in March 2009.

2001 – 2003 Consultant and Program Director - South Downtown Foundation

Responsibility for administering several million dollars for improving public safety in the 

International District, SoDo, and Pioneer Square neighborhoods of Seattle. Coordinated 

efforts with the City of Seattle, the Seattle Police Department and various interest and 

civic groups in the area.

1995-2001 Police Chief of Fort Lauderdale, Florida

The 33 square mile city has a full time resident population of 165,000. An estimated 

additional 60,000 "snow bird" residents return to second homes in the city during the 6-

month winter season. Fort Lauderdale serves as the seat of government for a county of 

1.5 million and is in the heart of a diverse tri-county (Dade, Broward, and Palm Beach) 

population of 4 million. As one of the premier tourist destinations in South Florida, over 

12 million passengers come through the airport each year. The ocean port handles the 

second largest number of cruise ship sailings in the world. Fort Lauderdale serves as the 

governmental and business hub of the County.

The City employed a workforce of 2,600 employees and operated with a budget of over 

$334 million. IAFF, FOP, and AFSCME Unions represent the fire, police, and general 

employees, respectively. The Fort Lauderdale Police Department had a budget of $60 

million and consisted of 500 sworn positions and 300 civilian positions. In 2000 the 

department received 600,000 calls for service, dispatched over 200,000 of those calls, 

made over 20,000 arrests, and issued over 65,000 traffic citations. The Department is 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 93 of 433 PageID #:15514
2

now nationally recognized as an innovative leader in the field of community policing and 

was one of only a handful of cities nationwide to be selected as a Community Policing 

Demonstration Site by the Department of Justice. Oversaw and operated the only 

municipal jail in the state of Florida.

A small sampling of initiatives undertaken over the 6 years includes:

x First large municipal police agency in Florida to receive accreditation

x Automobile anti-theft tactics that have reduced auto thefts by nearly 35% in one 

year

x Aggressive property crime reduction efforts in the area of strengthened pawn shop 

record sharing and accountability

x Partnerships with State Probation and Parole staff in "Ride Along Programs" with 

our patrol officers to remove violators from the community

x Establishment of "Citizens on Patrol" in specially marked vehicles to enhance 

public safety

x Aggressive enforcement of traffic and "quality of life" ordinances to help 

neighborhoods

x Establishment of a Nuisance Abatement Board to address drug and prostitution 

activity

x Significant reduction in alarm false dispatches to allow increased proactive patrol

x Innovative anti-prostitution and anti-gang programs

x Federal "Weed & Seed" designation, which has allowed us to partner with a wide 

range of community and governmental entities

x Thirteen sessions of the Citizen Police Academy - a 3 month, 35 hour program 

x Summer COPJAM activities for at risk youth

x Truancy and curfew programs which have dramatically reduced the rate of 

property crimes

In 1997 undertook a city financed $10 million technology enhancement initiative for the 

Department. Half of it was for a new state of the art Computer Aided Dispatch (CAD) 

and Record Management System (RMS), and the other half for network servers, 

individual personal computers, Geographical Information System (GIS), Automated 

Fingerprint Identification System (AFIS), internet access, bar coding for property control 

and evidence, and the largest law enforcement deployment of handheld, pen based, 

Motorola Forte' computers for patrol officers.

During my 6 year tenure, we successfully competed and received nearly $8 million in 

Federal and State grants. More than forty percent of the grant funds have gone into nontraditional community and social service support programs, in lieu of police personnel 

and hardware.

During my tenure there was a dramatic improvement in the relationship between our 

unions and management. We successfully negotiated two (3 year) contracts without 

incident or rancor. Although there has been an increase in professional expectations of 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 94 of 433 PageID #:15515
3

accountability for our employees, disciplinary appeals to arbitration had been all but 

eliminated.

1990-1995 Assistant Chief - Seattle Police Department

An appointive, exempt position reporting directly to the Chief of Police - acted as the 

Executive Assistant Chief of the Department and commanded the Support Bureau. The 

Police Department employed over 1,875 personnel and had an annual budget of $120 

million.

Responsible for and oversaw the activity of nine uniquely different divisions including: 

Training; Internal Investigations; Crime Prevention: Intelligence; Communications; 

Personnel; Records & Evidence; Data Processing; and Fiscal, Property, & Fleet 

Management. As the Executive Assistant Chief, was responsible for the day-to-day 

operation of the agency including authority for hiring, discipline, and administrative 

decisions. In addition, acted as primary management labor relations and contract 

negotiator with 12 labor unions. This bureau employed approximately 100 sworn and 

450 civilians. Served as the Seattle Police Department's jail liaison executive, as well as 

jail contract negotiator. Routinely served as acting Chief of Police.

1986-1990 Major

An appointive, exempt position - command of SPD Inspectional Services Division, 

reported directly to the Chief of Police. Coordinated and implemented strategic planning 

for the entire Department and conducted periodic performance inspections of 

Departmental units. Oversaw the preparation of the Department's budget, as well as the 

formulation of departmental rules, policies, and procedures. Acted as liaison with elected 

officials and community groups.

1984-1985 Captain

Command of SPD North Precinct. Responsible for Patrol operations in an area of the city 

that encompassed a population of 200,000 people and a uniformed force of 130 

officers. The precinct contained over a dozen unique communities including the 

University of Washington. Routinely served as acting Patrol Major overseeing all four 

patrol precincts - 550 sworn personnel.

1982-1983 Captain

Command of SPD Internal Investigations Section, reported directly to the Chief of 

Police. Responsible for overseeing the investigation of alleged misconduct of nearly 

2,000 sworn and civilian members of the Department.

1980-1981 Captain

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 95 of 433 PageID #:15516
4

Command of SPD West Precinct. Responsible for Patrol Operations in the downtown 

core of the city. Major league sports facilities, waterfront maritime industries, 

transportation, and financial, retail and business headquarters serving a daytime 

population of 300,000 -command of 150 sworn officers.

1978-1979 Lieutenant

Commander of Basic Recruit Training. Responsible for the operation and administration 

of the recruit training for SPD as well as the contract recruit training with the Washington 

State Criminal Justice Training Commission for over 100 law enforcement agencies 

state-wide. Average recruit population on campus of 140 in 4 concurrent classes, as well 

as a multi-agency training staff. Also served for a brief period as a downtown watch 

commander in the downtown business area.

1975 – 1978 Sergeant

Served as supervisor in the following: Patrol - uniformed patrol operations;; Internal 

Investigations Section - investigation of citizen, departmental, and criminal allegations of 

police misconduct; Special Patrol Unit - plain clothes tactical response to priority crime 

problems, deployment at unusual occurrences, dignitary protection.

1972 – 1975 Detective

Served in the following: Accident Investigation Section - plain clothes follow-up

investigation of hit-run, serious injury and fatality motor vehicle accidents; Burglary 

Section - investigated serious crimes directed against property; Vice Section -

investigated organized crime, prostitution, pornography, liquor, and gambling activities, 

and engaged in extended undercover assignments.

1968-1971 Patrol Officer

Started with Mercer Island (WA) P.D. in 1968, and then began career with Seattle P.D. in 

1969.

Training (small sampling):

x Police Liability and the Management of Police Discipline - Americans for 

Effective Law Enforcement

x Police Technology and Efficiency - International Association of Chiefs of Police

x Total Quality Management - The Institute for Quality Service

x Assessment Center Operations and Management - Federal Bureau of Investigation

x Executive Development - Federal Bureau of Investigation

x Incident Command System – National Incident Management System – Through 

Level 4

x Gambling Enforcement and Supervision - Washington State Gambling 

Commission

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 96 of 433 PageID #:15517
5

x Labor Relations and Negotiations - Federal Bureau of Investigation and 

Washington Association of Cities

x Hazardous Materials Incident Management - National Highway Transportation 

Safety Board

x Dignitary Protection Management and Supervision - U.S. Secret Service

x Supervision of Auto Theft Investigation - National Auto Theft Bureau

x Police Traffic Supervision - Northwestern Traffic Institute

x Municipal Budget Management - Office of Management and Budget

x Training for Trainers - Washington State Criminal Justice Training Commission

x Managing Computer Operations - Department of Administrative Services

x Investment in Excellence - The Pacific Institute

x Organized and White Collar Crime - The University of Washington

x Management of Computer Fraud Investigations – USWEST

x National Center for Missing and Exploited Children - Alexandria, VA

Law Enforcement Committees & Membership:

National:

x International Association of Chiefs of Police – Honorary Life Member

x Police Executive Research Forum – Subscribing Member

x National Sheriffs’ Association – Life Member

x American Correctional Association – Member

x American Jail Association – Member

x Crisis Intervention Team International - Member

State:

x Appointed by the Governor and served as the only law enforcement member of 

the Washington State Sentencing Guidelines Commission (August 2003 – 2008)

x Appointed to, and served as the chair of the Washington State Board on Law 

Enforcement Training Standards and Education (March 2003 – 2008)

x Homicide Investigation Tracking System (HITS) Advisory Board (May 2003 –

2006)

x Executive Board member of the Washington State Sheriffs’ Association (May 

2006 – 2008)

x Washington Association of Sheriffs and Police Chiefs – Honorary Life Member

Local:

x Past chair of Jefferson County Domestic Violence/Sexual Assault Program

x Member of the Peninsula College Criminal Education Program Board

x Executive Board of Olympic Peninsula Narcotics Enforcement Task Force

x Executive Board of JeffCom 911 Communications System

x Jefferson County Law & Justice Council

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 97 of 433 PageID #:15518
6

x Olympic Law Enforcement Executives Association

Achievements (sampling):

x Past Co-Chair of Private Sector Liaison Committee - International Association of 

Chiefs of Police

x Coordinator for successful federal grant application on Community 

Policing Program (N.I.J.)

x National Institute of Justice Symposium on Closed Circuit Television for 

deterrence and investigation of crime - Washington, DC

x National Institute of Justice Symposium on Metro Area Drug Strategies -

Washington, DC

x Coordinator for federal grant application on Narcotics Strategies in Public 

Housing

x Coordinator for federal grant application on Targeting Young Adult Gang Leaders

x Federal Bureau of Investigation - National Law Enforcement Budget Advisory 

Group - Appointed by the Director of the F.B.I.

x Broward County Chiefs' Association - President and Steering & Training 

Committees

x Southeast Florida Drug Task Force - Board of Directors

x Metropolitan Broward County Organized Crime Intelligence Unit - Board of 

Directors

x Florida Police Chiefs' Association - Ethics Committee

x Visiting management assessor for cities of New Orleans (LA), Columbus (OH), 

Portland, (OR), San Francisco (CA), Bremerton (WA)

x Contract consultant (KOBA Associates) for peer review of NIJ grant work on the 

establishment of Computer Crimes Units

x Contract consultant (Federal Housing & Urban Development Grant) to visit and 

analyze 6 major U.S. cities (Boston, Baltimore, Memphis, Oxnard, Cleveland & 

Seattle) police agencies and community policing in public housing

x Subject matter and best practices expert on law enforcement personnel selection, 

screening, and back grounding – USIS Investigative Solutions Conference

x Developed statewide law enforcement employment screening and back grounding 

model for the Washington Association of Sheriffs and Police Chiefs

x Oversight responsibility for acquisition of Computer Aided Dispatch and Mobile 

Digital Terminal System

x Oversight responsibility for acquisition of Comprehensive Shared Records 

Management System

x Oversight responsibility for acquisition of Jail Booking Video Imaging System

x Oversight responsibility for management of computerized Patrol Deployment 

Model

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 98 of 433 PageID #:15519
7

x Responsibility for design and construction oversight, acceptance and start-up of 

new police precinct facility

x Evaluation of Detective Decentralization Program and Detective Case 

Management System

x Acquisition of Geo-based Automated Mapping System

Selected Publications:

x Contributor - National Institute of Justice - Off-Duty Police Employment 

Practices

x Citation - Federal Bureau of Investigation article on joint Police-Community 

Partnerships

x Author of national and state articles - alarm reduction issues and strategies

x Author of several historical articles - homicides of police officers

Prior Law Enforcement & Community Service:

x Major City Chiefs - Human Resources sub-committee

x Washington State Chiefs & Sheriffs - Information Technology sub-committee

x Mayor's Task Force on Street People and the Homeless

x Selection and oversight committee for Police Department Management Study 

consultant contract

x Selection and oversight committee for Police-Citizen Complaint Process 

consultant contract

x Executive Member - South Florida Regional Law, Safety, and Justice Committee

x Automated Fingerprint Identification System / Jails - On-site benchmark testing & 

nationwide visitation team

x Health Service and Police Community Based Alcohol Triage Program

x King County Executive - Jail Advisory Committee (JCWG)

x City of Seattle - Deferred Compensation Plan provider selection and oversight

x Evaluation and Selection Committee - RFP responses for design of new municipal 

campus

x Seattle Police Department - reorganization committee that resulted 

in Departmental restructuring

x Explorer Scout Law Enforcement Program

x United Way of Broward County - Board of Directors

x Broward County Commission on Substance Abuse - Chair, Board of Directors

x Broward County Juvenile Justice Advisory Board

x Broward County Substance Abuse Policy Advisory Board

x Broward Workshop - Criminal Justice Committee

x Florida Department of Law Enforcement - UCR Advisory Committee

x Alarm Association of Florida / Law Enforcement - Board of Directors (1996-

1997)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 99 of 433 PageID #:15520
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT E 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 100 of 433 PageID #:15521
1

Attachment E

Bibliography of Background Source Materials

Following is a list of source materials that describe generally accepted policing practices, 

including at the relevant time period. The practices described include but are not limited to 

record-keeping, file maintenance, report writing, conducting homicide investigations, witness 

interrogations, supervision, etc.

This list of reference materials is not intended to be exhaustive and is supplemented by 

my extensive experience with police practices, including my familiarity with the policies used by 

other police departments nationwide, as well as industry standards established by organizations 

like the International Association of Chiefs of Police.

Reference Materials Generally

Death Investigation: A Guide for the Scene Investigator 

U.S. Department of Justice /Office of Justice Programs / National Institute of Justice 

Crime Scene Investigation: A Guide for Law Enforcement 

U.S. Department of Justice /Office of Justice Programs / National Institute of Justice 

Homicide Guide 

International Association of Chiefs of Police 

Promoting Effective Homicide Investigations 

Police Executive Research Foundation 

Homicide Investigation Standard Operating Procedures 

John M. Howell – Police Executive Forum 

Homicide Process Mapping – Best Practices for Increasing Homicide Clearances : A Project of 

the U.S. Department of Justice, Office of Justice Programs, Bureau of Justice 

Assistance 

Practical Homicide Investigation Checklist and Field Guide, Second Edition 

Vernon J. Geberth 

Techniques of Crime Scene Investigation (now in 8th edition) 

Barry A.J. Fisher 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 101 of 433 PageID #:15522
2

Homicide investigation; practical information for coroners, police officers, and other 

investigators 

Snyder, LeMoyne 

Practical Cold Case Homicide Investigations Procedural Manual 

Richard H. Walton 

Death Investigation: Systems and Procedures 

Randy Hanzlick

Forensic Pathology – Practical Aspects of Criminal and Forensic Investigations 

Dominick DiMaio & Vincent J. M. DiMaio 

Death Scene Investigation: A Field Guide 

Scott A. Wagner 

Death Investigator’s Handbook – Volumes 1 & 2 

Louis N. Eliopulos 

Cold Case Homicides: Practical Investigative Techniques 

Richard H. Walton 

Homicide Scene Investigation – A Manual For Public Prosecutors 

http://www.justiceacademy.org/iShare/Library-Training/Homicide-Scene-Manual.pdf

Death Scene Checklist Sheet 

http://www.insidethetape.com/Jan-2011-EATH%20SCENE%20CHECKLIST%20SHEET.PDF

Additional References

IACP - Brady Disclosure Requirements

IACP Model Policy - Brady Disclosure Requirements

Dr. Henry Faulds (1843-1930). A towering figure in the history of forensic sciences, it was 

Faulds who first recognized the value of fingerprints to criminal identification. The Faulds 

scrapbooks include research notes, original drawings and studies of fingerprint patterns and 

typology, as well as correspondence with individuals and crime fighting organizations around the 

world, dating from the (late 1870’s) until shortly before the doctor's death in 1930.

International Association for Identification (www.theiai.org) founded in the (1915). 

x Sparks from the Anvil 1933-1937

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 102 of 433 PageID #:15523
3

x IAI Newsletter 1940-1951 

x ID News Aug 1951 - 1987 

x Journal of Forensic Identification (JFI) 1988 - 2013 

Locard, E. L’Enquete Criminelle et les Methodes Scientifique. Paris: Ernest Flammarion, (1920). 

Homicide investigation; Frankel, Harold A. (1931) 

Criminology – Robert H. Gault Northwestern University (1932) 

La police scientifique. les homicides.--Les vols.--Les incendies criminels.--Les faux.--La fausse 

monnaie. Bischoff, Marc (1938) 

Homicide investigation; practical information for coroners, police officers, and other 

investigators, by Snyder, LeMoyne (1944, 1950, 1959, 1967, 1977) 

Law of Belligerent Occupation - The Judge Advocate General's School (1945) 

Techniques of Crime Scene Investigation (now in 8th edition) originally published in (1949) 

Techniques of Crime Scene Investigation is a classic book on how to use forensic science to 

investigate crimes. The text was first published in Swedish in 1949 by Chief Superintendent 

Arne Svensson, director of the Laboratory, Criminal Investigation Department, and 

Superintendent Otto Wendel, Criminal Investigation Department, Stockholm, Sweden. In 1955 it 

was printed in English as Crime Detection and then revised into a second, expanded American 

Edition under the title Techniques of Crime Scene Investigation in 1965. In 1981 I was invited to 

revise it in a third edition and subsequently into fourth, fifth, sixth, seventh and eighth editions. 

Kirk, P. L. Crime Investigation. New York: Interscience, John Wiley & Sons (1953). 

The detection of secret homicide; a study of the medico-legal system of investigation of sudden 

and unexplained deaths. Havard, John D. J. (1960) 

Institute on Homicide Investigation Techniques / presented by the Southwestern Law 

Enforcement Institute, Dallas, Texas; general editor: Robert A. Wilson. (1961) 

Practical homicide investigation. With an introd. by William P. Maheady. (1961) 

“We have learned the lesson of history, ancient and modern, that a system of criminal law 

enforcement which comes to depend on the ‘confession’ will, in the long run, be less 

reliable and more subject to abuses than a system which depends on extrinsic evidence 

independently secured through skillful investigation.” Escobedo v. Illinois, 378 U.S. 478, 

488–489 (1964) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 103 of 433 PageID #:15524
4

Thorwald, J. Crime and Science. Harcourrt, Brace & World, Inc.: New York, [LC Cat. no. 67-

20323]. (1966) 

Police Detective Function (W.S.U.) by V. A. Leonard (1970) 

Murder investigation. Oughton, Frederick (1971) 

Fox, Richard H. and Carl L. Cunningham. Crime Scene Search and Physical Evidence 

Handbook. 

Washington, D.C.: U.S. Department of Justice, National Institute of Justice, (1973). 

Homicide: investigative techniques, by Daniel J. Hughes. (1974) 

Kirk, P.L. Crime Investigation, 2nd Edition. New York: John Wiley & Sons, (1974). 

Police: the investigation of violence / Keith Simpson (1978) 

Smyth, F. Cause of Death: The Story of Forensic Science. Van Nostrand Rheinhold Company: 

New York, [ISBN 0-442-20041-2]. (1980) 

Zonderman, J. Beyond the Crime Lab: The New Science of Investigation. John Wiley & Sons: 

New York, [ISBN 0-471-62296-6]. (1980) 

Homicide investigation standards textbook / Joseph C. DeLadurantey, Daniel R. Sullivan. (1980) 

Saferstein, R. Forensic Science Handbook, Volumes I, II, III. Englewood Cliffs, N.J.: PrenticeHall, (1982/1988/1993). 

DeForest, P.R., R.E. Gaensslen, and H.C. Lee. Forensic Science: An Introduction to 

Criminalistics. New York: McGraw-Hill, Inc., (1983). 

Rosenfield, I.; Ziff, E. van Loon, B. DNA for Beginners. Writers and Readers Publishing, Inc. 

[ISBN 0-86316-023-9, pkb.]. (1983) 

Practical homicide investigation: tactics, procedures, and forensic techniques / Vernon J. 

Geberth. (1983)

Cahalane, Police Practice and Procedure

Skehan, Practical Police Work

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 104 of 433 PageID #:15525
5

New Jersey Division of Criminal Justice - The Property and Evidence Function

Ogden, Guidance for Prosecutors Regarding Criminal Discovery

O.W. Wilson, Police Records, Their Installation and Use

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 105 of 433 PageID #:15526
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT F 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 106 of 433 PageID #:15527


Attachment F 

I compared a total of 48 criminal defense files to 44 corresponding Investigative files and 

43 corresponding permanent retention files. 

The following listing provides a case-by-case account of what documents are included in 

Investigative files but are missing from criminal defense files. I did not make any inferences 

about what documents were turned over to criminal defendants – I based my conclusions on 

observations about actual differences between files. For each homicide investigation, each set of 

files—whether the Investigative file, the criminal defense file, or the permanent retention file is 

labeled with a CPD Records Division (“RD”) Number and a criminal defendant’s name. 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 107 of 433 PageID #:15528


Table of Contents 

Sherman Addison (RD# G-063126 / IF Bates RFC02417 - RFC02485) ................................... 4

Joaquin Gonzales (RD# G-129819 / IF Bates RFC02678 - RFC02729) .................................... 4

Jesus Hernandez, Hipolito Torres (RD# G-235351 / IF Bates RFC02919 - RFC02981) ........ 4

Richard Gonzalez (RD# G-256674 / IF Bates RFC02982 - RFC03028) ................................... 4

Roberto Moreno (RD# G-321911 / IF Bates RFC03322 - RFC03422) ..................................... 5

Cynthia Lee (RD# H-167635 / IF Bates RFC04135 - RFC04168) ............................................. 5

Jose Delvalle (RD# H-375595 / IF Bates RFC04585 - RFC04614) ............................................ 5

Michael Boyd (RD# H-422157 / IF Bates RFC04653 - RFC05112) .......................................... 5

Michael Green (RD# J-052070 / IF Bates RFC05471 - RFC05464) .......................................... 6

Samuel Slack (RD# J-080925 / IF Bates RFC05978 - RFC06127) ............................................ 6

Bruce Andras, David Quinones, Marc Johnson (RD# J-209456 / IF Bates RFC06322 - 

RFC06444) ...................................................................................................................................... 7

Jerry Buckner (RD# J-215119 / IF Bates RFC06445 - RFC06592) .......................................... 7

Orlando Cintron (RD# J-353821 / IF Bates RFC06630 - RFC06662) ...................................... 7

Richard Sanchez (RD# J-409858 / IF Bates RFC07033 - RFC07146) ...................................... 8

Elmer Madrid (RD# J-423347 / IF Bates RFC07147 - RFC07200) .......................................... 8

LaTonya Pitchfork (RD# K-292921 / IF Bates RFC07896 - RFC08058) ................................. 8

Orval Fain (RD# K-417078 / IF Bates RFC08152 - RFC08224) ............................................... 9

Felipe Rodriguez (RD# K-455932 / IF Bates RFC08329 - RFC08465) ..................................... 9

Amos Walker (RD# K-530917 / IF Bates RFC08733 - RFC08842) ........................................ 10

Michael Armstead (RD# K-575912 / IF Bates RFC08843 - RFC08894) ................................ 10

Warren Robinson (RD# M-020288 / IF Bates RFC08895 - RFC08937) ................................. 10

Francisco Benitez (RD# M-184949 / IF Bates RFC0968 - RFC09720) ................................... 11

Curtis Kirkland (RD# M-258570 / IF Bates RFC09904 - RFC10101) .................................... 11

Clarence Roberts (RD# M-287641 / IF Bates RFC10157 - RFC10242) ................................. 12

Warren Murdock (RD# M-381429 / IF Bates RFC10243 - RFC10288) ................................. 12

Henry Robinson (RD# M-538914 / IF Bates RFC10321 - RFC10345) ................................... 12

Ras Green (RD# M-579697 / IF Bates RFC10727 - RFC10861) ............................................. 12

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 108 of 433 PageID #:15529


Jessie Swanigan (RD# N-028256 / IF Bates RFC11204 - RFC11503) ..................................... 13

Pierre Mahone (RD# N-053000 / IF Bates RFC11504 - RFC11567) ....................................... 13

Allen Whittington (RD# N-133637 / IF Bates RFC11865 - RFC11905) ................................. 13

Tomas Nieves (RD# N-162782 / IF Bates RFC11906 - RFC12064) ......................................... 13

Tyrece Williams (RD# N-176796 / IF Bates RFC12065 - RFC12161) .................................... 14

David Delgado (RD# N-203334 / IF Bates RFC12328 - RFC12436) ....................................... 14

Jose Baez (RD# N-262285 / IF Bates RFC12572 - RFC12735) ................................................ 14

Timothy Lee (RD# N-267450 / IF Bates RFC12736 - RFC12831) .......................................... 15

Ricardo Miranda (RD# N-475910 / IF Bates RFC13109 - RFC13182) .................................. 15

Calvin McLemore, Rolando Serrano (RD# N-517875 / IF Bates RFC13249 - RFC13500) .. 15

Samuel Robinson (RD# N-581836 / IF Bates RFC13501 - RFC13671) .................................. 15

Glen Miller (RD# N-592324 / IF Bates RFC13672 - RFC13742) ............................................ 16

Richard Conner (RD# P-049272 / IF Bates RFC13890 - RFC14195) ..................................... 16

Demetrius Thomas (RD# P-060434 / IF Bates RFC14415 - RFC14565) ................................ 16

Robert Machine (RD# P-128067 / IF Bates RFC14566 - RFC14774) ..................................... 17

Demetrius Johnson (RD# P-272087 / IF Bates RFC15446 - RFC15481) ................................ 17

Miguel Borrotto (RD# P-526822 / IF Bates RFC16275 - RFC16401) ..................................... 18

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 109 of 433 PageID #:15530


Examination – Comparison – Contrasting of 44 Homicide Case Records 

(44 Investigative Files / 48 Criminal Defense Files / 43 Permanent Retention Files) 

Sherman Addison (RD# G-063126 / IF Bates RFC02417 - RFC02485) 

• Investigative File – 69 pages 

• Missing from Criminal Defense File – M.E. Body Chart (02443) 

• Missing from Permanent Retention File – Lab Report (02425-26); Medical Examiner 

Report (02438-39-43) 

Joaquin Gonzales (RD# G-129819 / IF Bates RFC02678 - RFC02729) 

• Investigative File – 52 pages 

• Missing from Criminal Defense File – M.E. Body Chart (02689); M.E. Body Chart 

(02694) 

• Missing from Permanent Retention File – Medical Examiner Report (02694; 02710-

2719) 

Jesus Hernandez, Hipolito Torres (RD# G-235351 / IF Bates RFC02919 - RFC02981) 

• Investigative File – 63 pages 

• Missing from Criminal Defense File – Investigative File Inventory (02920); Felony Case 

computer print out (02921); Subpoenas (02922-23); Laboratory Report (02924); 

Photographs (02972-81) 

• Missing from Permanent Retention File – Lab Report (02924); Defendant Statements 

(02938-46); Property Inventory Sheet (02948); Handwritten Notes/GPRs (02950-56); 

Evidence Report (02957-58; 02965-67); Photographs (02972-81) 

Richard Gonzalez (RD# G-256674 / IF Bates RFC02982 - RFC03028) 

• Investigative File – 47 pages 

• Missing from Criminal Defense File – M.E. Report of Postmortem Examination (03023-

28) 

• Missing from Permanent Retention File – Medical Examiner Report (03023-27); 

Toxicology Report (03028) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 110 of 433 PageID #:15531
	

Roberto Moreno (RD# G-321911 / IF Bates RFC03322 - RFC03422) 

• Investigative File – 101 pages 

• Missing from Criminal Defense File – Indications that case transferred. No comparison. 

• Missing from Permanent Retention File – Reinvestigation Docs (03326-34); Latent 

Fingerprints Report (03340); Correspondence (03344-46, 48); Medical Examiner Report 

(03351-54); Toxicology Report (03355); Evidence Report (03359); Photographs (03378); 

Property Inventory Sheet (03379-80); Evidence Report (03382-83); Handwritten 

Notes/GPRs (03385-3401); Victim Info (03405); Photographs (03408-18) 

Cynthia Lee (RD# H-167635 / IF Bates RFC04135 - RFC04168) 

• Investigative File – 34 pages 

• Missing from Criminal Defense File – Arrest Supplementary Report (04150) 

• Missing from Permanent Retention File – Medical Examiner Report (04143-46); 

Toxicology Report (04148) 

Jose Delvalle (RD# H-375595 / IF Bates RFC04585 - RFC04614) 

• Investigative File – 30 pages 

• Missing from Criminal Defense File – No pages missing from Criminal Defense file. 

• Missing from Permanent Retention File – PRF Redacted. No comparison. 

Michael Boyd (RD# H-422157 / IF Bates RFC04653 - RFC05112) 

• Investigative File – 460 pages 

• Missing from Criminal Defense File – Indications that case transferred. No comparison. 

• Missing from Permanent Retention File – Medical Examiner Report (04708-12); Supp 

Reports 4879, 4883, 4992 GPRs/Handwritten Notes (04798, 04806, 04798, 04863-72, 

04875-76, 04909-10, 04919-20, 04927, 04962, 04976-80, 04987-94, 04997, 05011); 

Evidence Report (04799, 04922, 04935, 04983, 04995, 05009); Fingerprint Requests and 

Response (04796, 04773, 04796, 04822-23, 04862, 04891, 04906-08, 04928-30, 04999-

50004); Defendants' Statements (04778-4788, 04825); Stop Order (04792-93; 04885-86); 

Daily Bulletin (04794-95); Hospitalization Case Report (04801); Arrest Report (04807, 

04852-55, 04894-4905, 04947, 04950, 04952-53, 04955, 04956, 04960); Property 

Inventory Sheet (04856-60, 05016-5027); Preliminary Fired Evidence Report (04921); 

Crime Analysis Pattern (04973-75); Photographs (05029-93); Request for Identification 

Photos (05095-5106) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 111 of 433 PageID #:15532



Michael Green (RD# J-052070 / IF Bates RFC05471 - RFC05464) 

• Investigative File – 389 pages 

• Missing from Criminal Defense File – Back of Photo (05207, 05209); Photograph 

(05211–12); Handwritten Notes (05236–38); Handwritten Notes (05412); Photographs 

(05194–233); Subpoena (05252); Supplementary Report (05253-54); Criminal History 

(05373, 05378, 05464, 05434); Agency Requesting Transcripts (05444-45); Statements 

(05264-75; 05276-89; 05290-97); Investigator Business Card (05298); Letter & 

Photograph (05299-300); Investigative File Inventory (05189-91); Palm Print Cards 

(05234-35); Request for Identification Photos (05240); AFIS result (05245); Subpoenas 

(05247-52); Form 101s (05256-57, 05439, 05443, 05462-63); Supplementary Report 

(05329-32); General Offense Case Reports (05328, 05333-34); Arrest Information Card 

(05390-91); Request to Hold Prisoners (05396-97, 05400-01, 05441); Release of Person 

in Custody (05399); Arrest Report (05386, 05388, 05394, 05416, 05429-30, 05433, 

05442, 05446); Arrest Warrant (05456, 05459); Felony Case Printout (05466); Complaint 

for Preliminary Examination (05458, 05460-61) 

• Missing from Permanent Retention File – GPR (05263); Transcript of Defendant 

Statement (05264-5297); Complaint for Search Warrant (05448) 

Samuel Slack (RD# J-080925 / IF Bates RFC05978 - RFC06127) 

• Investigative File – 150 pages 

• Missing from Criminal Defense File – Request for Latent Fingerprint Comparison 

(05982); Photograph (05983); Latent Fingerprint Examination Report (05984); Subpoena 

(05987); Arrest Report (06042); Arrest Report (06056); Handwritten Notes (06072); 

Photographs (06074-79) 

• Missing from Permanent Retention File – Medical Examiner Report (06089-92); Request 

for Latent Fingerprints (05982, 05989, 05996, 06002, 06034-35, 06084-85); Fingerprint 

Results (05984); Evidence Report (05992-94, 06058, 06082-83); General Offense Case 

Report (06030); GPRs (06031, 06043, 6053, 06061-6071); Handwritten Notes (06072); 

Evidence Report (06032, 06035, 06050); Hold Past Court Call Request (06033, 06041); 

Property Inventory (06038-39, 06048, 06060); Arrest Report (06042, 06054, 06056); 

Fired Evidence Report (06045); Supplementary Report (06052); Photographs (06074-79); 

Latent Fingerprint Exam Report (06080) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 112 of 433 PageID #:15533


Bruce Andras, David Quinones, Marc Johnson (RD# J-209456 / IF Bates RFC06322 - 

RFC06444) 

• Investigative File – 123 pages 

• Missing from Criminal Defense File – Handwritten Notes (06323); Investigative File 

Inventory (06324-25); Investigative File Controls (06326-27); Felony Case computer 

printout (06328-30); Court Notification/Sworn Member card (06331); Handwritten Notes 

(06332); Subpoena (06333); Handwritten Notes (06334); Subpoena (06335); Subpoena 

(06337); Typed Statement (06344-50); Handwritten Statement (06401-02); Handwritten 

Notes (06413); Envelope with RD# (06442); Request for Identification Photos (06443); 

Photographs (06444) 

• Missing from Permanent Retention File – Investigative File Inventory (06324-27); 

Felony Case computer printout (06328-30); Latent Fingerprint Examination Reports 

(06338-39); Evidence Report (06340, 06397-99); Criminal History (06341-42); Typed 

Statement (06344-50); Arrest Report (06356); GPRs (06357-58, 06377-81, 06421); 

Request for Evidence (06359); Preliminary Fired Evidence Report (06361); Property 

Inventory Sheet (06363-65); Evidence Report (06367-70); Handwritten Notes (06384, 

06421-32); Property Inventory Reports (06385-92); Criminal History (06393-94); 

Handwritten Statement (06401-02); Request for ID Photos (06443); Photographs (06444) 

Jerry Buckner (RD# J-215119 / IF Bates RFC06445 - RFC06592) 

• Investigative File – 148 pages 

• Missing from Criminal Defense File – Investigative File Inventory (06488); Envelope 

(06573); Illinois Drivers License (06574-75); Photographs (06576-88, 91-92); Selective 

Service System Status Card (06589-90) 

• Missing from Permanent Retention File – Medical Examiner Report (06452-56); 

Toxicology Report (06547); Investigative File Inventory (06488); Laboratory Report 

(06490-91); Handwritten Notes (06497); Evidence Report (06507); Arrest Report 

(06508); GPR (06509); Mail Routing Slip (06513); Request for Mail Cover Check 

(06470, 06514); Envelope (06516-17); Daily Bulletin (06523-24); Memo from Detective 

(06525); Memo (06527); Criminal History (06528); GPR (06539); Evidence Report 

(06540); Criminal History (06542-43); Criminal History (06544-45); Property Inventory 

Sheet (06546-51); GPRs (06560-70); Victim's drivers license (06574-75); Identification 

Photographs (06576-87, 06591-92); Selective Service Card (06589-90) 

Orlando Cintron (RD# J-353821 / IF Bates RFC06630 - RFC06662) 

• Investigative File – 33 pages 

• Missing from Criminal Defense File – Defendant obtained outside counsel so the PD 

closed the file. No investigative materials included. 

• Missing from Permanent Retention File – Medical Examiner Report (06642-48) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 113 of 433 PageID #:15534


Richard Sanchez (RD# J-409858 / IF Bates RFC07033 - RFC07146) 

• Investigative File – 114 pages 

• Missing from Criminal Defense File – Case Assignment Slip (07034); Court Attendance 

Reports (07035-39); Handwritten Notes on Naprosyn Notepad (07040); M.E. Report of 

Postmortem Examination (07041-46); Court Attendance Report (07047); Supplementary 

Report (07054); Investigative File Inventory (07070-71); Investigative File Control 

(07072); Subpoena (07073); Firearms Receipt & Worksheet (07098); Photograph 

(07130-31) 

• Missing from Permanent Retention File – PRF redacted. No comparison. 

Elmer Madrid (RD# J-423347 / IF Bates RFC07147 - RFC07200) 

• Investigative File – 54 pages 

• Missing from Criminal Defense File – SAO Disposition Reports (07148-49); Court 

Attendance Reports (07150-52); M.E. Report of Postmortem Examination (07153-57); 

Supplementary Reports (07158-65); Cause of Death Supplementary Report (07184-85); 

M.E. Body Chart (07186); Line Up Supplementary Reports (07197-200) 

• Missing from Permanent Retention File – Medical Examiner Report (07153-56); 

Toxicology Report (07157) 

LaTonya Pitchfork (RD# K-292921 / IF Bates RFC07896 - RFC08058) 

• Investigative File – 163 pages 

• Missing from Criminal Defense File – State’s Attorney Letter (07897); Court Attendance 

Reports (07898-900); Investigative File Inventory (07940-41); Investigative File Control 

(07942); Form 101 (07943); Oklahoma City Police Department Fax Transmittal Sheet 

(07964); LEADS Responses (07967-76); Fugitive Arrest Receipt (07977); Oklahoma 

City Waiver of Extradition & Certification (07978-79); Arrest Report (07980); LEADS 

Responses (07990-94); Photographs (08003); Handwritten Notes (08005-06); Criminal 

History (08025); Complaint (08026); Arrest Warrant (08027); Physical 

Description/Fingerprint Record (08028); Handwritten Notes (08034); LEADS Response 

(08037); Request for Non-published Telephone Information (08039); LEADS Responses 

(08040-43); Criminal History (08046-47); Handwritten Notes (08052); LEADS 

Responses (08053-56); Letter to Cleveland Police Dept. (08057); Subpoena (08058) 

• Missing from Permanent Retention File – Medical Examiner Report (07901-05); 

Statements of Defendant (07951-58); Arrest Report (07964-66, 07980); LEADS Report 

(07967-74); Fugitive Arrest Receipt (07977); Waiver of Extradition (07978-79); Info for 

Daily Bulletin (08031); Handwritten Notes (08034, 08052); Request for telephone 

records (08039); Stop Order (08001-02); Request for UFAP Warrant (08007); 

Supplementary Report (08010) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 114 of 433 PageID #:15535



Orval Fain (RD# K-417078 / IF Bates RFC08152 - RFC08224) 

• Investigative File – 73 pages 

• Missing from Criminal Defense File – Felony Case computer printout (08153); Court 

Attendance Reports (08154-57); M.E. Report of Postmortem Examination (08158-62); 

Supplementary Report (08174); Investigative File Inventory (08178-79); Investigative 

File Control (08180); Preliminary Fired Evidence Report (08183); Handwritten Notes 

(08213); Handwritten Notes (08215) 

• Missing from Permanent Retention File – Handwritten Notes (08211-21, 08184); 

Property Inventory Sheet (08204-06, 08209-10, 08222); Forensic Report (08207); Line 

Up Photo Report (08201); Arrest Report (08197-200); Crime Lab Fired Evidence Report 

(08183); Supplementary Report (08174); Medical Examiner Report (08158-62) 

Felipe Rodriguez (RD# K-455932 / IF Bates RFC08329 - RFC08465) 

• Investigative File – 137 pages 

• Missing from Criminal Defense File – Court Attendance Reports (08330-34); Felony 

Case computer printout (08340-41); SAO Disposition Report (08342); Court Attendance 

Reports (08343-47); Supplementary Report (08348-49); Supplementary Reports (08352-

55); Supplementary Report (08371); Investigative File Inventory (08375-76); 

Investigative File Control (08377); Supplementary Report (08378-79); GPR (08380); 

Order of Release to Detectives (08381); Evidence Report (08382); Form 101 (08383); 

Supplementary Reports (08384-86); Arrest Report (08387); Handwritten Notes (08388); 

Supplementary Report (08389-90); Evidence Report (08391); Request to Hold Prisoner 

(08392); Handwritten Notes (08438); GPR (08439); Handwritten Notes (08442); 

Envelope (08453); Attorney Business Card (08454); Photographs (08455-63); Request 

for Identification Photos (08464); Court Attendance Report (08465) 

• Missing from Permanent Retention File – Medical Examiner Report (08335-39); Arrest 

Reports (08371, 08386-87, 08412-13, 08443-44); Handwritten Notes (08380, 08414-17, 

08428-08442); Holdover Request (08392); Firearms Receipt & Worksheet (08395); 

Preliminary Fired Evidence Report (08398); Evidence Report (08403); Line-up Photo 

Report (08407); Request for Ballistics Comparison (08410); Property Inventory Sheet 

(08445-52); Request for Identification Photos (08464); Photographs (08455-63) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 115 of 433 PageID #:15536


Amos Walker (RD# K-530917 / IF Bates RFC08733 - RFC08842) 

• Investigative File – 110 pages 

• Missing from Criminal Defense File – Court Attendance Report (08734); SAO 

Disposition Report with Handwritten Notes (08742); Court Attendance Report (08743-

44); Supplementary Report (08745-46); Body Chart (08747); Supplementary Report 

(08772); Court Notification/Sworn Member (08776); Investigative File Inventory 

(08777-78); Court Notification/Sworn Member (08779; 08781); Handwritten Notes 

(08780); Investigative File Control (08782); Handwritten Notes (08784); Photographs 

(08842) 

• Missing from Permanent Retention File – Arrest Report (08788-89, 08795-96); Request 

for Latent Fingerprint Comparison (08797); Handwritten Notes (08800); Recovered 

Vehicle Supplementary Report (08804-05); Evidence Report (08806-13); Property 

Inventory Reports (08824); Supplementary Report (08814-15); Supplementary Report 

(08816-18); Supplementary Report (08819-20); Supplementary Report (08821); 

Supplementary Report (08825-27); Supplementary Report (08828-31) 

Michael Armstead (RD# K-575912 / IF Bates RFC08843 - RFC08894) 

• Investigative File – 52 pages 

• Missing from Criminal Defense File – Court Attendance Reports (08844-52; 08862-64); 

Supplementary Report (08880-82) 

• Missing from Permanent Retention File – Medical Examiner Report (08853-60); 

Toxicology Report (08861) 

Warren Robinson (RD# M-020288 / IF Bates RFC08895 - RFC08937) 

• Investigative File – 43 pages 

• Missing from Criminal Defense File – Court Attendance Report (08896); M.E. Report of 

Postmortem Examination (08897-902); Felony Case computer printout (08903); Court 

Attendance Report (08904-16); Supplementary Report (08936-37) 

• Missing from Permanent Retention File – Medical Examiner Report (08897-8901); 

Toxicology Report (08902) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 116 of 433 PageID #:15537


Francisco Benitez (RD# M-184949 / IF Bates RFC0968 - RFC09720) 

• Investigative File – 113 pages 

• Missing from Criminal Defense File – SAO Letter (09609); Court Attendance Reports 

(09610-18); Cause of Death Supplementary Report (09627-28); Cause of Death 

Supplementary Report (09629-30); Supplementary Report (09644-45); Supplementary 

Report (09646); Supplementary Report (09647); Investigative File Inventory (09652); 

Subpoena (09654); Supplementary Report (09673); Supplementary Report (09675); 

Supplementary Report (09676); Envelope with Handwritten Notes (09715); Foot Locker 

Receipt (09716); Boston Shirt Yard Receipt (09717); Stop Order/Missing Person Printout 

(09718-19); Handwritten Notes (09720) 

• Missing from Permanent Retention File – Medical Examiner Report (09619); Toxicology 

Report (09623); Medical Examiner Report (09624); Investigative Fie Inventory (09652); 

Supplementary Report (09656); Report with Handwritten Notes (09660); Notes regarding 

witness statements (09669); Handwritten Notes added to General Offense Case Report 

(09671); Property Inventories Sheets (09678-89); Signed Statement (09690-92); Arrest 

Report (09693); Felony Minute Sheet (09694); Evidence Report (09696); General 

Progress Reports/Hand Written Notes (09698-9700-15, 09720); Foot Locker Receipt 

(09716); Boston Shirt Yard Receipt (09717) 

Curtis Kirkland (RD# M-258570 / IF Bates RFC09904 - RFC10101) 

• Investigative File – 198 pages 

• Missing from Criminal Defense File – Court Attendance Reports (09905-11); ASA Letter 

(09919); SAO Disposition Report (09920); Court Attendance Reports (09921-32); 

Investigative File Control (09967); Investigative File Inventory (09968-69); Photographs 

(09972-81); Handwritten Notes (09982); Vehicle Information printout (09983); 

Handwritten Notes (09984); Handwritten Notes (09986); Handwritten Notes (09987); 

Handwritten Notes (09989-90); Envelope (09991); Criminal History (10007-08); 

Handwritten Notes (10009-10); Investigative File Control (10012); Evidence Report 

(10023); Form 101 (10033); Request for Analysis/Receipt for Exhibit (10060); CB 

Record Summary (10065); Subpoena (10094) 

• Missing from Permanent Retention File – Medical Examiner Report (9912-17); 

Toxicology Report (9918); Lab Report (10013-14); Investigative File Control (9968-69); 

Mug shot photos (9971, 9973, 9975, 9977, 9979-80); Notes of names and addresses and 

witness statements (9972, 9974, 9976, 9978, 9982, 9984, 9986-87, 9989-90, 10076, 

10093); crime scene photos (9993-10006); Handwritten Notes (10009-10); Felony 

Minute Sheet (10020, 10033); Arrest Reports (10021, 10032, 10064); Signed Statement 

of State witness Weaver (10053); Signed Statement (10054); Photo lineup information 

(10058); Request for Analysis/Receipt for Exhibit (10060); GPR with typed and 

handwritten notes (10061); Property Inventory Sheets (10067-69, 10087-92); Criminal 

History (10071-72); Arrest Info Card (10073-75); Handwritten Notes (10076); Criminal 

History (10078-80); GPR (10081) Criminal History (10082-85) GPR (10098) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 117 of 433 PageID #:15538


Clarence Roberts (RD# M-287641 / IF Bates RFC10157 - RFC10242) 

• Investigative File – 86 pages 

• Missing from Criminal Defense File – SAO Letter (10158-59); Court Attendance Reports 

(10160-64); M.E. Report of Postmortem Examination (10165-68); Court Attendance 

Report (10169); Investigative File Inventory (10190); Investigative File Control (10191); 

Subpoena (10193) 

• Missing from Permanent Retention File – Medical Examiner Report (10165-68); 

Investigative File Inventory (10190); Arrest Report (10208); ASA Felony Minute Sheet 

(10209); Stop Order (10218); Wanted Person Report (10219); Supplementary Report 

(10220-21); General Offense Case Report (10222); Handwritten Lineup Report (10224); 

Handwritten Notes re witness interviews (10225-10228); Evidence Report and Inventory 

Documents (10230-42) 

Warren Murdock (RD# M-381429 / IF Bates RFC10243 - RFC10288) 

• Investigative File – 46 pages 

• Missing from Criminal Defense File – Court Attendance Reports (10244-50); Court 

Attendance Reports (10258-59) 

• Missing from Permanent Retention File – Medical Examiner Report (10251-10257); 

Supplementary Report (10272); Supplementary Report (10283-10284); General Offense 

Case Report (10285) 

Henry Robinson (RD# M-538914 / IF Bates RFC10321 - RFC10345) 

• Investigative File – 25 pages 

• Missing from Criminal Defense File – Investigative File incomplete. No comparison. 

• Missing from Permanent Retention File – Medical Examiner Report (10324-28) 

Ras Green (RD# M-579697 / IF Bates RFC10727 - RFC10861) 

• Investigative File – 135 pages 

• Missing from Criminal Defense File – Photographs (10767-73); Handwritten Notes 

(10775-77); Latent Fingerprint Examination Report (10786); General Offense Case 

Report (10831-32); Property Inventory Sheets (10848-50) 

• Missing from Permanent Retention File – Medical Examiner Report (10733-37); 

Toxicology Report (10738); Investigative File Inventory (10764-65); Photographs 

(10767-73); Business Card (10774); GPRs and Handwritten Notes (10831-46, 10775-77); 

Criminal Records searches (10778, 10827-29); Report re fingerprint matching defendant 

(10786); Property Inventory Reports (10788-89 10822-25, 10847-51, 10856); Felony 

minute sheet (10792); Crime Scene Processing Report (10793); Request (10795); Arrest 

Report (10796); Defendant's Statement (10810-11); CHA Senior Housing Security 

Report (10854-55) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 118 of 433 PageID #:15539


Jessie Swanigan (RD# N-028256 / IF Bates RFC11204 - RFC11503) 

• Investigative File – 300 pages 

• Missing from Criminal Defense File – Handwritten Notes (11281, 11276, 11283, 11319, 

11324-11325, 11407, 11409, 11420); Request for Identification Photos (11311-11312); 

Photograph (11313); Request for Identification Photos (11314-15); Photographs (11316-

11318); Photographs (11284-11309); Scan of Keys (11321-11323); General Offense 

Case Report (11271-11272); Cause of Death Supplementary Report & Body Chart 

(11230-11232); Line Up Supplementary Report (11242-11243); Line up Supplementary 

Report (11250-11251); Recovered Vehicle Supplementary Report (11273-11274) 

• Missing from Permanent Retention File – Medical Examiner's Report (11224-11228); 

GPR/Handwritten Notes (11276, 11281, 11283, 11325, 11341-11347, 11350, 11389, 

11406-09, 11416-28, 11463-64, 11475, 11477, 11479-85, 11488); Arrest Report (11282, 

11372, 11403, 11414-15, 11486); Photos (11284-11310, 11313,11316-18, 11321-11323); 

Phone Message (11324); Request for Identification Photos (11311, 11314); Fingerprint 

Report (11330, 11392); Release of Vehicle (11334); Motor Vehicle Inventory (11348); 

Tow Report (11351, 11467); Request for Analysis (011354); Hold-over Request (11365, 

11412, 11458, 11468); Property Inventory Sheets (11366, 11368, 11369, 11371, 11393-

94, 11471, 11473, 11489, 11491, 11493, 11494); Evidence Report (11373-76, 11459, 

11461, 11465); Polygraph Results (11385); Material Submitted for the Daily Bulletin 

(11410); Lab Report (11501-02) 

Pierre Mahone (RD# N-053000 / IF Bates RFC11504 - RFC11567) 

• Investigative File – 64 pages 

• Missing from Criminal Defense File – General Offense Case Report (11524); 

Investigative File Inventory (11526); Handwritten Notes (11557) 

• Missing from Permanent Retention File – Medical Examiner Report (11507-10); 

Toxicology (11511) 

Allen Whittington (RD# N-133637 / IF Bates RFC11865 - RFC11905) 

• Investigative File – 41 pages 

• Missing from Criminal Defense File – Supplementary Reports (11884-87); 

Supplementary Report (11890); General Offense Case Report (11904-05) 

• Missing from Permanent Retention File – Medical Examiner Report (11877-80) 

Tomas Nieves (RD# N-162782 / IF Bates RFC11906 - RFC12064) 

• Investigative File – 159 pages 

• Missing from Criminal Defense File – Photographs (11955-66); Handwritten Notes 

(12063) 

• Missing from Permanent Retention File – GPRs/Handwritten Notes (12016, 12056-

12064); Property Inventory (12042-53); Letter from Optometrist (12009); Lab Reports 

(12007-08); Medical Examiner's Report (11999-12005); Toxicology Report (12006); 

Arrest Report (11988, 11911); Statement (11986-87); Statement (11984-85); Statement 

(11981-83); Photographs (11955-66) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 119 of 433 PageID #:15540


Tyrece Williams (RD# N-176796 / IF Bates RFC12065 - RFC12161) 

• Investigative File – 97 pages 

• Missing from Criminal Defense File – M.E. Report of Postmortem Examination (12072-

12076); Cause of Death Supplementary Report (12080-12082); Investigative File Control 

(12098) 

• Missing from Permanent Retention File – Medical Examiner's Report (12072-75); 

Toxicology Report (12076); Arrest Report (12136); Property Inventory (12139, 12142-

49); Statement (12131-32); GPRs/Handwritten Notes (12108-09, 12120-24); Arrest 

Records (12110-11); Stop Order/Missing Person Order (12103-04); Reports (12105-07) 

David Delgado (RD# N-203334 / IF Bates RFC12328 - RFC12436) 

• Investigative File – 109 pages 

• Missing from Criminal Defense File – Indications that case transferred. No comparison. 

• Missing from Permanent Retention File – Medical Examiner Report (12334-38); 

Toxicology Report (12339); Medical Examiner Report (12340-44); Toxicology Report 

(12345); Investigative File Inventory (12367); Criminal Histories (12384-89); 

Handwritten Note (12390); Criminal Histories (12391-92); Handwritten Statement 

(12392-97); Property Inventory (12398-408); Arrest Report (12414); Handwritten Note 

(12415); Firearms Use Report (12416, 12418); Memo (12417, 12419); Officer's Battery 

Report (12420-21); GPRs (12422-34) 

Jose Baez (RD# N-262285 / IF Bates RFC12572 - RFC12735) 

• Investigative File – 164 pages 

• Missing from Criminal Defense File – Criminal History (12640-41); Line Up Report 

Sheet (12644); Handwritten Notes (12646); GPR (12647); Handwritten Notes (12648); 

Handwritten Notes (12725) 

• Missing from Permanent Retention File – Medical Examiner's report (12582-86); 

Toxicology Report (12587); Criminal History (12630-31); Criminal History (12640-41); 

Arrest Report (12642); Request for Identification Records (12643); Handwritten line up 

report (12644); Identification Procedural Control (12645); Handwritten Notes from 

lineup (12646); GPRs (12647-48); Stop Order Cancellation (12651); FBI and Illinois 

State Criminal Record (12654-71); Request for Identification Records (12672); Property 

Inventory (12673-78); Arrest Report (12680); Arrest Information (12694); GPRs (12695-

96); Stop Order (12697); Material for Use in Daily Bulletin (12698); Criminal History 

(12699-700); Request for identification records (12701); Property Inventory (12705-09); 

Arrest Report (12711); GPRs (12721-22, 12724-27); Criminal Record (12732-33); Memo 

(12735) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 120 of 433 PageID #:15541
	

Timothy Lee (RD# N-267450 / IF Bates RFC12736 - RFC12831) 

• Investigative File – 96 pages 

• Missing from Criminal Defense File – M.E. Report of Postmortem Examination (12742-

45); Cause of Death Supplementary Report (12748-49); Photographs (12772-75); 

Property Inventory Sheet (12830) 

• Missing from Permanent Retention File – PRF redacted. No comparison. 

Ricardo Miranda (RD# N-475910 / IF Bates RFC13109 - RFC13182) 

• Investigative File – 74 pages 

• Missing from Criminal Defense File – Investigative File Inventory (13116-17) 

• Missing from Permanent Retention File – Handwritten notes (13114, 13127); 

Investigative File Inventory (13116); Arrest Reports (13124, 13126, 13133, 13148); ASA 

Notes (13123, 13125, 13138-39); Written Statement (13134-37); Line-up Notes (13140); 

Request for Ballistics Comparison (13154); Property Inventory Sheet (13155-56, 13159-

61, 13180-82) GPRs (13172-77); Documents re: a car (13167, 13178) 

Calvin McLemore, Rolando Serrano (RD# N-517875 / IF Bates RFC13249 - RFC13500) 

• Investigative File – 252 pages 

• Missing from Criminal Defense File – Photographs (13316-81); Investigative File 

Inventory (13383-84); Subpoena (13385); Form 101 (13389); GPRs (13390-91); Order 

with handwritten notes (13392); Request for Evidence Identification Photographs 

(13499); Handwritten notes (13500) 

• Missing from Permanent Retention File – PRF redacted. No comparison. 

Samuel Robinson (RD# N-581836 / IF Bates RFC13501 - RFC13671) 

• Investigative File – 171 pages 

• Missing from Criminal Defense File – Court Attendance Reports (13502-05); Report of 

Postmortem Examination (13506-09); Results of Toxicologic Analysis (13510); Case 

Assignment Slip (13511); SAO Disposition Report (13512); Court Attendance Report 

(13513); Letter (13514); Court Attendance Reports (13515-22); File Folder (13551); 

Notes (13552); Investigative File Inventory (13553-54); Investigative File Control 

(13555-56); Subpoena (13557); Stamp/Notes (13558); Statement (13592 & 94); Blank 

Inventory of Things Seized (13614); Supplementary Report (13639); Blank Envelope 

(13647); To-From Memo (13648); Handwritten Notes (13649-52); CPD Message 

(13659); Mug Shots (13660-71) 

• Missing from Permanent Retention File – PRF redacted. No comparison. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 121 of 433 PageID #:15542



Glen Miller (RD# N-592324 / IF Bates RFC13672 - RFC13742) 

• Investigative File – 71 pages 

• Missing from Criminal Defense File – Investigative File Inventory (13673); Cause of 

Death Supplementary Report (13674-75); Supplementary Report (13682-84, 13693-96) 

• Missing from Permanent Retention File – Investigative file inventory (13673); 

Supplementary Report (13676-81); Supplementary Report (13685-87); Supplementary 

Report (13688-89); Supplementary Report (13690-92); Supplementary Report (13693-

96); Arrest Report (13697); Written Statement (13704-07); Written Statement (13708-

12); Felony Minutes Report (13713-14); Property Inventory Sheets (13715-21); Evidence 

Reports (13723); Evidence Report (13724); GPR/Handwritten Notes (13727-39); Police 

Report (13740) 

Richard Conner (RD# P-049272 / IF Bates RFC13890 - RFC14195) 

• Investigative File – 306 pages 

• Missing from Criminal Defense File – Handwritten Notes (13891); Investigative File 

Inventory (13935); Handwritten Notes (13947); Court Order (14028); Interstate 

Identification Index (14123-27) 

• Missing from Permanent Retention File – PRF redacted. No comparison. 

Demetrius Thomas (RD# P-060434 / IF Bates RFC14415 - RFC14565) 

• Investigative File – 151 pages 

• Missing from Criminal Defense File – Court Attendance Report (14416); Case 

Assignment Slip (14417); SAO Disposition Report (14418); Court Attendance Reports 

(14419-31); Court Attendance Report (14438); Court Notification/Sworn Member 

(14469); Crime Laboratory Report (14471); Property Inventory Sheets (14472-74); Court 

Notification/Sworn Member card & Handwritten Notes (14478-79); Statement of 

Demetrius Thomas (14516-30); Subpoena (14565) 

• Missing from Permanent Retention File – No PRF. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 122 of 433 PageID #:15543


Robert Machine (RD# P-128067 / IF Bates RFC14566 - RFC14774) 

• Investigative File – 209 pages 

• Missing from Criminal Defense File – SAO Disposition Reports (14571-73); Court 

Attendance Reports (14574-83); Supplementary Report (14633-34); Handwritten Notes 

(14640); Investigative File Inventory (14641-14642); Investigative File Control (14643); 

Subpoena (14647); Handwritten Notes (14650, 14712, 14758); Supplementary Report 

(14759-60); Handwritten Notes (14761); Form 101 (14762); Arrest Report (14763); 

General Offense Case Report (14764-14765); Envelope (14767); Photographs (14768-69, 

14770-74) 

• Missing from Permanent Retention File – Medical Examiner Report (14567-14570); 

Interview (14637); Investigative File Inventory (14641-42); Request for Crime Lab 

Analysis (14644); Report of Registered Vehicle (14651); Photographs (14652-54); Copy 

of "calling card" (14655); Memo (14657); Vehicle Inventory Report (14659); Property 

Inventory sheets (14664-71); Arrest Report (14678); Criminal History (14679); 

Handwritten Statement (14680-83); Handwritten Statement (14684-86); Handwritten 

Reports (14702); Criminal History (14709-11); Handwritten Notes (14712); Request for 

Telephone Call Records (14723); Property Inventory Sheet (14745-50); GPR (14751-55); 

Handwritten Note (14758); Arrest Report (14759-60); General Offense Case Report 

(14764-65); Photographs (14768-74) 

Demetrius Johnson (RD# P-272087 / IF Bates RFC15446 - RFC15481) 

• Investigative File – 36 pages 

• Missing from Criminal Defense File – Indications that case transferred. No comparison. 

• Missing from Permanent Retention File – Medical Examiner Report (15448-51); 

Toxicology Report (15452); Line Up Report (15470-71) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 123 of 433 PageID #:15544


Miguel Borrotto (RD# P-526822 / IF Bates RFC16275 - RFC16401) 

• Investigative File – 127 pages 

• Missing from Criminal Defense File – Letter to Officer Riccio (16276); Court Attendance 

Report (16277-82); Subpoena (16308); Subpoenas (16310-11); Subpoenas (16315-16); 

Complaint for Preliminary Examination (16324-25); Form 101s (16326-27); License 

Plate Sticker Replacement (16335); LEADS Response (16338); General Offense Case 

Report (16386); Social Security Card (16392-93); Vehicle Search (16394); Handwritten 

Notes (16395); Handwritten Notes (16397); Envelope & Letter (16398-400); American 

Standard Enterprise Receipt (16401) 

• Missing from Permanent Retention File – Medical Examiner Report (16283-86); Pages 2-

3 of Arrest Report (16291-92); Investigative File Inventory (16306); Criminal History 

(16309); Arrest Report (16329); Property Inventory Sheets (16332-34); License Plate 

Sticker Replacement Application (16335); Handwritten Note (16337); Criminal History 

(16338-52); GPRs (16359-64); Property Inventory Sheets (16365-67, 16370-75); 

Evidence Report (16378); Request for Evidence (16380); Property Inventory Sheets 

(16381-83); Photographs (16389-91); Social Security Card (16392-93); Vehicle 

Registration Inquiry (16394); Envelope (16395); Handwritten names and contact 

information (16397); Envelope and Letter (16398-400); Receipt for Sale of Car (16401) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 124 of 433 PageID #:15545
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT G 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 125 of 433 PageID #:15546
" H*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

H GILHII 1985

)- 2*#).*)

 --4) -. No N/A N/A N/A N/A N/A N/A L N/A N/A N/A

I GIOLPJ 1985  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJ GMJHIM HPOL

# -()$.*)

-$)-*2)

))$ *$).*)  .  . =GIKKJ  .

:;*$)1 )/*-4$)

$)1 ./$"/$1 !$' 

:;*.$)


)1 ./$"/$1 $' 9 :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9:

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

K GMNHGP 1985 *)'*0)" No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AL GMPJKL 1985 '1-*)/$'') No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AM GNNHPJ 1985  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AN HIPOHP HPOL *,0$)*)5' 5  .  .

=GIMOP

=GIMPK * :

:;*.$)


)1 ./$"/$1 $' :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9:

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

O HLPPGP 1985

	 )-4 4 .

'( -'1 - 5

* '$1 -


0$.$1 - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

? 89;9;7 7?>; %'%	$  , % %

368?86268?88

368?8:

368?=8268?>7 ! 0! 0! 0

01!!1$!


!% 


 (%&&(/ 0

76 89;9;7 7?>; 	"!&!!$$% % %

368?86268?89

368?=8268?>7 ! 0! 0! 0

01!!1$!


!% 


 (%&&(/ 0

HH ILMMNK HPOL $#-*)5' 5  .  . =GJGIJ;GJGIO * :

:;*.$)


)1 ./$"/$1 $' 9 :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HI JGJIKO 1985 $"0 '*-$"0 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJ JHNIMN 1985 )- *0'-  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHK JHNLGN 1985  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHL JIHPHH HPOL * -/**- )*

 .60/$/$.

$)*(+' / ::::::::::

HM JOIHJH 1985 *" -*$) // No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHN KHONIH 1985  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHO KLHIIP 1985 
.- '# * No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHP KNHOGG 1985 0'--.,0$''* No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 126 of 433 PageID #:15547
" I*!IO

Records Division Number Year Defendant(s)

H GILHII 1985

)- 2*#).*)

 --4) -.

I GIOLPJ 1985  / J GMJHIM HPOL

# -()$.*)

-$)-*2)

))$ *$).*)

K GMNHGP 1985 *)'*0)"L GMPJKL 1985 '1-*)/$'')M GNNHPJ 1985  / N HIPOHP HPOL *,0$)*)5' 5O HLPPGP 1985

	 )-4 4 .

'( -'1 - 5

* '$1 -


0$.$1 -

? 89;9;7 7?>; %'%	$  ,

76 89;9;7 7?>; 	"!&!!$$%HH ILMMNK HPOL $#-*)5' 5HI JGJIKO 1985 $"0 '*-$"0 5HJ JHNIMN 1985 )- *0'-  HK JHNLGN 1985  / HL JIHPHH HPOL * -/**- )*HM JOIHJH 1985 *" -*$) // HN KHONIH 1985  / HO KLHIIP 1985 
.- '# *HP KNHOGG 1985 0'--.,0$''*

Identifying Information

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

 . GIHOK;GIHOM *

=0+* )!*-/- /!$' .!-*() ! ). 

=	)2-$// ))*/ .

= ) -'!! ). .  +*-/

=  $+/.!*-3#$$/.

=-- ./
)!*-(/$*)-

=-- ./ +*-/.

=*./(*-/ (:*3$*'*"4 +*-/

=*4$"-(

=0++' ( )/' +*-/>?  .

=GIILK

=GIJHG

=GIJHI

=GIJHK

=GIJHM

=GIJHO

=GIJII

=GIJIM

=GIJIP

=GIJMI;GIJMJ  . =GIJMH  / 6)**(+-$.*) :::

* :::* :* : / 6)**(+-$.*) :::* :::* :* : .  .  . Lab Report at RFC02425-26, Medical Examiner report at RFC02438-39-43

* :::* :* : .  .  . Medical Examiner report at RFC02514-15, 2526-2535* :::* :* : . *  . Medical Examiner Report at RFC 02565-2529; Toxicology Report at RFC 02570; . GILNK;GILNL *

@B*/ .B
$./ $)
)1 )/*-4=0+* )!*-

/- /!$' .!-*() ! ). =-- ./


)!*-(/$*)-.=	)2-$// )*/ .  .

=GILNM

=GIMIM

=GIMNG

=GIMNI<GIMNN  . =GIMKI  / 6)**(+-$.*) :::

* :::* :* :Yes Yes Yes Medical Examiner report at RFC02694 & 2710-2719 . GINJH;GINJI *

@B
 +*-/.B
$./ $)
)1 )/*-4

@BHN*/ .B'$./ $)
)1 )/*-4;'$) .0+2$/#.

)*/
$./ =	)2-$// )*/ =-*+ -/4
)1 )/*-4

=*2  #$' $.+*.$/$*).=*/*- #$' 


)1 )/*-4 +*-/=// ( )/=0++' ( )/'

 +*-/  .

=GINJP

=GINKO

=GIOPK * : .  .  .

Handwritten Notes RFC02739; 2878-2894, Lab Report at RFC02740-2742, 

handwritten note from state witness explaining her fear (summary report is in 

PRF) at RFC02748, Defendant statements at RFC02789-2807, 2812-2874, 

Police Report re threats to victim's family at RFC 02895-97, Gun Forensics 

Report at RFC02915-2916, consent to search form at RFC02917, Vehicle Tow Report at RFC 2735 & 02918, Vehicle Disposition Report at RFC02736-02738,

% 68?86 !

3'"! !$&$&%

3'%!&'""/"!$&

% 68?;< ! 0Yes No Yes

Lab Report at RFC 02924; Defendant statements at RFC 02938-46; Property 

Inventory at RFC 02948; Handwritten notes/GPRs at RFC 02950-56; Evidence 

Report at RFC 02957-58, 2965-67; Photos at RFC 02972-81;

% 68?86 !

3'"! !$&$&%

3'%!&'""/"!$&

3!$&!$+"!$& % 68?;< ! 0Yes No Yes

Lab Report at RFC 02924; Defendant statements at RFC 02938-46; Property 

Inventory at RFC 02948; Handwritten notes/GPRs at RFC 02950-56; Evidence 

Report at RFC 02957-58, 2965-67; Photos at RFC 02972-81;

* :::* :* :Yes Yes Yes Medical Examiner Report at RFC 3023-27; Toxicology Report at RFC 03028; . GJGLO *

=0+* )>*/!*-/- /!$' .?

=-- ./ +*-/

=	)2-$// )*/ .

=0++' ( )/' +*-/.  .

=GJGOJ

=GJGOL

=GJGON

=GJGOP

=GJGPH

=GJHHH * : . *  .

Arrst Reports at RFC 3106-08, 3110; Hold Past Court Form at RFC 3109; 

Handwritten Notes/GPRS at RFC 3111-3116, 3082-91; Photos at RFC 3122-28; 

Defendant Statement at RFC 3079;Evidence Reports at RFC 3065-67, 95, 96; 

Line-up Notes (Line-up documented in Supp. Report in PRF) at RFC 3093; 

Property Inventory at RFC 03097-98

 . GJIGJ;GJIGK *

=*./(*-/ (:*3$*'*"4 +*-/

=*4$"-(

=0++' ( )/' +*-/>?

=0+* )!*-/- /!$' .> ! ). ?

=0+* )>)*/!*-./- /!$' .?

=  $+/!*-3#$$/. * :* : .  .  .

Transcript of defendant statements at RFC 03229-3255; Lab Reoprts (from Pam 

Fish) at RFC 03210-3215; Property Inventory Sheets at RFC 03216, 3266-69; 

Handwritten Notes at RFC 03273-3282; Evidence Report documenting line up 

(described in Supp report that is in PRF) at RFC 03258.

 . GJHJG *

@B*/ .B
$./ $)
)1 )/*-4=*4$"-(=

0++' ( )/' +*-/>?=

*./(*-/ (:*3$*'*"4 +*-/=$59-.=

	)2-$// )*/ .  .

=GJHLJ

=GJHMI

=GJHOM

=GJHOP

=GJHPH

=GJHPP

=GJIGH * : / 6)**(+-$.*) :::

 . GJJIK;GJJIL  .

=*./(*-/ (:*39

=	)2-$// )*/ .  .

=GJJOL

=GJJON;GJJOO

=GJJPG

=GJJPI

=GJJPK

=GJJPM

=GJJPO

=GJKGG * : . *  .

Reinvestigation docs at RFC 03326-34; Latent Fingerprints Report at RFC 

03340; Correspondence re offender in Mexico at RFC 03344-46, 48; Medical 

Examiner Report at RFC 03351-54; Toxicology Report at RFC 03355; Evidence 

Report at RFc 03359; Photos at RFC 03378; Property Inventory at RFC 03379-

80; Evidence Report re line up photos at RFC 03382-83; Handwritten 

Nontes/GPRs at RFC 03385-3401; Victim info at RFC03405; Photos at 3408-

3418;

* :* :* :* : .  .  . Medical Examiner Report at RFC 03452-3456; Toxicology report at RFC 03457;* :* :* :* : / 6)**(+-$.*) :::* :* :* :* : .  .  . Medical Examiner Report at RFC 03529-3533; Toxicology Report at 3534;* :* :* :* : . *  . Medical Examiner Report at RFC 3554-58; Toxicology Report at RFC 035559;

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 127 of 433 PageID #:15548
" J*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

IG 	GMKLGK 1986  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AIH 	GPHLNL 1986 )/$"* )*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AII 	GPKLNJ 1986 	--4**+ - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AIJ 	GPLOKK 1986  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AIK 	HGGNMG 1986

*. +# $./

>$/$(82-**' 2.&$? No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

IL 	HGLLLN 1986

*. +# $./

>$/$(8*#)* ? No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

IM 	HIMOML 1986  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AIN 	HMNMJL HPOM

- "*-44)*(

4)/#$
  .  . =GKHLG  .

:;*$)1 )/*-4$)

$)1 ./$"/$1 !$' 

:;*.$)


)1 ./$"/$1 $' 9 :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9:

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

IO 	HNINIP 1986  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AIP 	HNKKGJ 1986  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJG 	HPJMPN 1986

- "*-41$.

0.. ''	-+ - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

JH 	IGOHGM 1986

$''$ 9**.

$- ') 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

JI 	IMLKHK 1986 ))4	*'( . No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJJ 	INPNOG 1986 	 )-4*#).*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJK 	JHMHPO 1986 0)-/$5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJL 	JIJION 1986  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJM 	JNLLPL HPOM *.  '1''  . * :* :

:;*.$)


)1 ./$"/$1 $' 9 :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

JN 	JNMOHK 1986  -*-/$) 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AJO 	KIIHLN HPOM

$# '*4

/-$$..

-'	--$.

 1$*)'/*)

 .60/$/$.

$)*(+' / ::::::::::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 128 of 433 PageID #:15549
" K*!IO

Records Division Number Year Defendant(s)

Identifying Information

IG 	GMKLGK 1986  / IH 	GPHLNL 1986 )/$"* )*)II 	GPKLNJ 1986 	--4**+ -IJ 	GPLOKK 1986  / IK 	HGGNMG 1986

*. +# $./

>$/$(82-**' 2.&$?

IL 	HGLLLN 1986

*. +# $./

>$/$(8*#)* ?

IM 	HIMOML 1986  / IN 	HMNMJL HPOM

- "*-44)*(

4)/#$
 

IO 	HNINIP 1986  / IP 	HNKKGJ 1986  / JG 	HPJMPN 1986

- "*-41$.

0.. ''	-+ -

JH 	IGOHGM 1986

$''$ 9**.

$- ') 5

JI 	IMLKHK 1986 ))4	*'( .JJ 	INPNOG 1986 	 )-4*#).*)JK 	JHMHPO 1986 0)-/$5JL 	JIJION 1986  / JM 	JNLLPL HPOM *.  '1'' JN 	JNMOHK 1986  -*-/$) 5JO 	KIIHLN HPOM

$# '*4

/-$$..

-'	--$.

 1$*)'/*)

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . GJLOJ *

@B*/ .B)B*/ .B
$./ $)
)1 )/*-4=

-- ./ +*-/=' # 0' 0$ =0+* )

!*-/- /!$' .> ! ). ?  .

=GJMJJ

=GJMJM

=GJMKN

=GJMKP

=GJMLJ

=GJMLL

=GJMLN

=GJMMI

=GJMMK * : / 6)**(+-$.*) :::

* :* :* :* : . *  . Medical Examiner Report at RFC 3707-3710; Toxicology Report at RFC 03711;

* :* :* :* : / 6)**(+-$.*) ::: . GJNPO;GJNPP *

@B*/ .B)B*/ .B
$./ $)
)1 )/*-4=

$59-=0+* )!-*(>)*/!*-./- /!$' .?

=*./(*-/ (:*3$*'*"4 +*-/=0++' ( )/-4

 +*-/  .

=GJOKL

=GJONN * : / 6)**(+-$.*) :::

* :* :* :* : . *  .

Medical Examiner Report at RFC 3892-3894; Toxicology Report at RFC 03895; 

Supp. Report witness interview at RFC 3898-99; Supp. Report of Interview with 

Defendant at RFC 03905-3906;

* :* :* :* : . *  . Supp Report at RFC03962-64 . GKGHL;GKGHM *

=J*!/# K0+* ).:*- -!*-/- /!$' .

=	)2-$// )*/ .

=*4$"-(

=*./(*-/ (:*3$*'*"4 +*-/

=-$($)'	$./*-4

=0++' ( )/' +*-/>?  .

=GKHIN

=GKHJJ * : / 6)**(+-$.*) :::

* :::* :* :Yes No Yes Medical Examiner Report at RFC04143-46; Toxicology report at RFC04148* :* :* :* : / 6)**(+-$.*) :::* :* :* :* : / 6)**(+-$.*) :::* :* :* :* : .  .  . Medical Examiner Report at RFC04265-69;* :* :* :* : . *  . Medical Examiner Report at RFC 04338-39; Toxicology Report at RFC 04337;* :* :* :* : . *  . Medical Examiner Report at RFC 04361-64; Toxicology Report at RFC 04365;* :* :* :* : . *  . Medical Examiner Report at RFC 04381-85; Toxicology Report at rFC 04386; . GKKJP *

@B	)2-$// )*/ .B
$./ $)
)1 )/*-4;*.

'$./ =0+* ).!*-/- /!$' .>?= ) -'

-*"- .. +*-/.=*./(*-/ (:*3$*'*"4 +*-/

=0++' ( )/' +*-/>?=*4$"-(  . =GKKOG * : . *  .

Medical Examiner Report at RFC 04415-18; Toxicology Report at RFC 

04419;Property Inventory Report at RFC 0441-42, 4452; Evidence Report re 

cartridge at RFC 04446, 4453; Transcript of Witness Statement at RFC 04454-4457; Defendant Statement at RFC 04458-63; Handwritten notes/GPRs at RFC 

04477-

 . GKLIM *

=0+* ).!*-/- /!$' .> ! ). ?

=0+* ).*/!*-/- /!$' .> ! ). ?

=*;-*( (*

=
 // -!-*( ! ). //*-) 4

=*./(*-/ (:*3$*'*"4 +*-/.

=	)2-$// )*/ 

=#*/*"-+#.:&.*!#*/*.8 -.*)

= ) -'!! ). .  +*-/

=0++' ( )/' +*-/.>.?

=0++' ( )/' +*-/.

=)' -:$/# -)-.*)*-0++9 +*-/  . =GKLNG  . =GKLJI  / 6)**(+-$.*) :::

* :::* :* :Redacted, no comparison N/A N/A N/A

* :* :* :* : . *  . Medical Examiner Report at RFC 04622-25; Toxicology Report at RFC 04626; . GKNMO *

=0+* ).!-*()>)*/./- /!$' .?

=0+* ).!-*()!*-/- /!$' .

=// ( )/

=0++' ( )/' +*-/.

=
 // -:)1 '*+ !-*($/$5 )

= ,0 ./!*-
 )/$!$/$*)#*/*

=1$ )  +*-/  .

=GKONM

=GKPOM

=GKPOP

=GKPPI

=GKPPK

=GKPPO

=GLGGG<GLGGH

=GLGGK<

=GLGHH<GLGHI

=GLGIH  . =GKNOP  .  .  .

Medical Examiner Report at RFC 04708-04712; Supp. Report re pattern 

analysis of robberies; Supp Reports 4879, 4883, 4992; GPR/Handwritten Notes 

at 4798, 4806, 4798, 4863-72, 4875-76, 4909-10,4919-20, 4927, 4962, 4976-

4980, 4987-4994, 4997, 5011 Evidence Report at 4799, 4922, 4935, 4983, 

4995, 5009 - Fingerprint requests and response at RFC 04796, 4773, 4796, 

4822-23, 4862, 4891, 4906-08, 4928-30, 4999-50004, , Defendants' Statements 

at RFC 04778-4788, 4825- Stop Order at RFC 04792-93, 4885-86, Daily Bulletin 

at 4794, 4795; Hospitalization Case Report at RFC 04801, Arrest Report at 

4807, 4852-55, 4894-4905, 4947, 4950, 4952-53, 4955, 4956, 4960 Property 

Inventory at 4856-60, 5016-5027; Preliminary Fired Evidence Report at RFC 

04921, Crime Analysis Pattern at 4973-75, Photos at 5029-5093, Request for 

Identification Photos at RFC 05095-5106.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 129 of 433 PageID #:15550
" L*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

JP 	KONMJN 1986 -0.0#)) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AKG GLIGNG HPON

(0 '
 

$# '- )

$# '&.*)


2- ) -)/' 4  .  .

= GLIGN6 GLIGP6 GLIHH;GILHI6

GLIJM<GLIJO6GLKHI6GLHPK6GLHPM6

GLHPO<GLIGM6GLIGO6GLIHG6

GLIHI6GLIHK6GLIHM<GLIJJ6GLILI;

GLIK6GLJNJ6GLJNO6GLKMK6

GLKJK6GLKKK<GLKKL6GLIMK<GLINL6

GLINM<GLIOP6GLIPG<GLIPN6

GLIPO6GLIPP<GLJGG6GLHOP<GLHPH6

GLIJK<GLIJL6GLIKG6GLIKL6

GLIKN;GLIKP6GLILG<GLILI6GLILM<

GLILN6GLKJP6GLKKJ6GLKMI;GLKMJ6

GLJIP<GLJJI6GLJIO6GLJJJ<

GLJJK6GLJPG<GLJPH6GLJPM<GLJPN6

GLKGG<GLKGH6GLKKH6GLJPP6

GLJOM6GLJOO6GLJPK6GLKHM6

GLKIP<GLKJG6GLKJJ6GLKKI6GLKKM6

GLKLM6GLKLP6GLKMM6GLKLO6

GLKMG;GLKMH * :* : .

=GLIGN

=GLIGP

=GLIHH;GILHI

=GLIJM<

GLIJO

=GLKHI

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

KH GLJLHJ 1987

)0 ' '$$)*

	 4-). - 5

(0 ' - 5

-)&$  -* No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

KI GNJPIG 1987 ( . 2.*( No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AKJ GNLGNJ 1987  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AKK GOGPIL HPON (0 ''&  .  .

=GMGNI

=GLPOK

=GLPOJ6GMGNK;GMGNP

=GLPON

=GLPOI

=GMGKI

=GMGLM * :* : . =GMGNI

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

KL HHNKPN 1987 '*- )/$)*$'')0 1 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AKM HJPIGG 1987 
 )-**-$"0 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A:= 86?:;< 7?>= (' ! % % %

36<98:26<98;

36<999

36<99;

36<99=

36<9::26<9;6

36<:6716<:68

36<::9

36<:::

36<989

36<996

36<998

36<99: ! 0! 0%

36<989

36<998

36<99:

01!!1$!


!% 


 (%&&(/ 0

:> 86?:;< 7?>= $'$% % %

6<989.6<98:16<98;.6<98<16<98=.

6<98>16<996.6<997.6<998.

6<999.6<99=.6<:79.6<::8.6<::9.

6<::: ! 0! 0% 6<989.6<998.6<:79

01!!1$!


!% 


 (%&&(/ 0

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 130 of 433 PageID #:15551
" M*!IO

Records Division Number Year Defendant(s)

Identifying Information

JP 	KONMJN 1986 -0.0#))KG GLIGNG HPON

(0 '
 

$# '- )

$# '&.*)


2- ) -)/' 4

KH GLJLHJ 1987

)0 ' '$$)*

	 4-). - 5

(0 ' - 5

-)&$  -*

KI GNJPIG 1987 ( . 2.*(KJ GNLGNJ 1987  / KK GOGPIL HPON (0 ''&KL HHNKPN 1987 '*- )/$)*$'')0 1KM HJPIGG 1987 
 )-**-$"0 5:= 86?:;< 7?>= (' ! %:> 86?:;< 7?>= $'$%

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . GLHKH *

=*./(*-/ (:*3$*'*"4 +*-/

=0+* )!*-/- /!$' .>?

=0+* ).)*/!*-/- /!$' .>?

=-*+ -/4
)1 )/*-$ .

=0++' ( )/' +*-/>?

=*4$"-(

=1$ )  +*-/. * :* : .  .  .

Medical Examiner Report at 5117-19; Toxicology Report at RFC 5120; Property 

Inventory at RFC 05145-49, 5152; Evidence Report at RFC 05150; Pewliminary 

Fired Evidence Report at RFC 5158; Defendant Statement at RFC 05159-62; 

Evidence Report re Photo Line up at RFC 05175; Arrest Report at RFC -5177; 

GPR/Handwritten Notes at RFC 05180-5185

 . =GLHOP;GLHPH *

=
 // -!-*(# -$!!

=$59-

=// ( )/*!-)/' 4

=// ( )/*!
 

=0+* ).

=0+* ).!*-/- /!$' .

=
 ,0 ./

= ,0 ./!*-
 )/$!$/$*)#*/*.

=#*/*.< -.*).

='(+-$)/-

= ) -'!! ). .  +*-/

=0++' ( )/-4 +*-/.

=-- ./ +*-/.

=-*+ -/4
)1 )/*-4

=*./(*-/ (:*39  .

=GLKGL

=GLIGN

=GLIGP

=GLIHH;GILHI

=GLIJM<GLIJO

=GLKHI

=GLKIH<GLKII

=GLKIK

=GLKIM

=GLJMI

=GLJOG;GLJOJ * : .  .  .

Handwritten GPRs at 5263; Transcript of defendant statement at 5264-5297; 

Complaint for Search Warrant at RFC 5448;

 . GLMNM;GLMNO *

@B*/ .B
$./ $)
)1 )/*-4=0+* ).*/!*-

/- /!$' .> ! ). ?=0+* )!*-/- !$' .>

) ! ). ?=-- ./
)!*- -*= ) -'

-*"- .. +*-/.=0++' ( )/' +*-/=

*./(*-/ (:*3$*'*"4 +*-/  .

=GLNGP

=GLNIG

=GLNIJ

=GLNLN

=GLNML

=GLOGG

=GLOIK * : .  .  .

Medical Examiner Report at RFC 05634-40; Toxicology Report at RFC 5641; 

Complaint for Search Warrant at RFC 5739; Defendant Statement at RFC 

05770; Arrest Report at 5693, 5715, 5717, 5783; Handwritten notes/ GPRs at 

RFC 5699, 5706-09, 5716, 5719-5721, 5723-28, 5749, 5756-57, 5762-66, 5779, 

5799-5800, 5803, 5808, 5822-5835; Property Inventory at RFC 5722, 5735-37, 

88-90, 92-92; Complaint for Search Warrant at RFC 5738-47; Evidence Report 

re lineup photos at RFC 5758, 5774; Fired Evidence Report at RFC at 5784; 

Photos at RFC 5842-5855.

* :* :* :* : / 6)**(+-$.*) ::: . GLPHP *

@B.B)B	)2-$// )*/ .B
$./ $)


)1 )/*-4=-*+ -/4
)1 )/*-4=%*--$( 


)$ )/*/$!$/$*)= ) -'!! ). . 

 +*-/.=0++' ( )/' +*-/=*4$"-(  .

=GLPIH

=GLPIJ * : / 6)**(+-$.*) :::

 . =GLPNP;GLPOG *

=.

=-*+ -/4
)1 )/*-4

= ,0 ./!*-)'4.$.:  $+/!*-3#$$/.

= '*)4$)0/ .*-(HGH=0+* )!*-/- /!$' .

=#*/*.; -.*)

=*./(*-/ (:*3$*'*"4 +*-/.  .

=GMGKK

=GMGNI * : . *  .

Medical Examiner Report at RFC 06089-6092; Request for Latent Fingerprints 

at RFC 05982, 5989, 5996 6002 6034-35, 06084-85; Fingerprint Results at RFC 

5984; Evidence Report at RFC 5992-5994, 6058, 6082-83; Handwritten GPRs 

RFC 06030-31, 6043, 605, 06061-60723;Evidence Report at RFC 06032, 6035 

6050; Hold Past Court Calll Request at RFC 06033, 6042; Property Inventory at 

RFC 6038-39, 6048, 6060, 6038, 6039; Arrest Report at RFC 06042, 6054, 

6056; Fired Evidence Report at RFC at 6045; Release of Prisoner (documented 

in supp report though) at RFC 6052; photos at 6074-6079; Latent Fingerprint 

Exam Report for victim Prints at RFC 06080;

 . GMHNG *

=0+* )!*-/- /!$' .>) ! ). ?

=*./(*-/ (:*3$*'*"4 +*-/

=0++' ( )/' +*-/.

=*4$"-( * :* : .  .  .

Medical Examiner Report at RFC06141; Criminal History Reports at RFC06179, 

6190-92; Arrest Report at RFC06180; Evidence Reports at RFC06181-82, 6189; 

Police Reports and Handwritten Notes from 1986 murder that may have been 

committed by same offender at RFC06193-6198; GPRs at RFC06206-6221; 

Photos at RFC06225-6230

 . GMINI *

@B.B
$./ $)
)1 )/*-4=0+* )!*-

/- /!$' .>) ! ). ?=

*./(*-/ (:*3$*'*"4 +*-/=0++' ( )/'

 +*-/.>?=*4$"-( * : . =GMIPM  .  .  .

Medical Examiner Report at RFC06242-6246; Handwritten Witness Statement at 

RFC06279-80; Handwritten notes at RFC06281, RFC 06315-6321; Evidence 

Report at RFC 06282; Arrest Report at rFC06295; Memo re: difficulty contacting 

a witness at RFC06296; Report of Material Submitted for Use in the Daily 

Bulletin at RFC 06297; Arrest Warrant at RFC 06300; Property Inventory at 

RFC06305-06

% 36<98:26<98; !

3'"! %!$&$&%

3	 )$&& !&%

3$ 	%&!$+

3 $"$ &*/&&$% "!$&%

3#'%&!$
 &&! !&!%

3 %

36<989

36<998

36<99:

36<9>:

36<:86

36<:88

36<:8:

36<:8<

36<:8?

36<:9716<:98 ! 0% ! %

File Inventories at RFC06324-27; Criminal History Computer Screen for Perp #3 

Quinones at RFC06328-30; Various court call requests; Fingerprint Examination 

Reports at RFC 6338-39 (and other places); Evidence Report from Criminal Lab 

Division at RFC06340, 6397-99; Arrest History for Chacon, Quinones at 

RFC06341-42; Statement/Confession of Quinones at RFC06344-50; Arrest 

Report dated 6/8/87 at RFC 6356; GPRs at RFC06357-58, 6377-81, 6421; 

Evidence Requests/Reports at RFC06359-70; Handwritten Notes at RFC06384, 

6421-32; Property Inventory Reports at RFC06385-92; Arrest History for Marc 

Johnson at RFC06393-94; Statement of Witness Cordoba at RFC06401; 

Request for ID Photos and Photos at RFC06443-44

% 6<98:16<98; !

77	 )$&&  !&% -=%& 
 ( &!$+

4	!' 5

76% ->%&! 
 ( &!$+46<9;=1

6<9;>.6<9==16<9>7.6<:87.6<:8>.6<:965 %

6<989.6<998.

6<9>:.6<:79.

6<:86.6<:88.

6<:8:.6<:8<.

6<:8?.6<:9716<:98 ! 0% ! %

File Inventories at RFC06324-27; Criminal History Computer Screen for Perp #3

Quinones at RFC06328-30; Various court call requests; Fingerprint Examination 

Reports at RFC 6338-39 (and other places); Evidence Report from Criminal Lab 

Division at RFC06340, 6397-99; Arrest History for Chacon, Quinones at 

RFC06341-42; Statement/Confession of Quinones at RFC06344-50; Arrest 

Report dated 6/8/87 at RFC 6356; GPRs at RFC06357-58, 6377-81, 6421; 

Evidence Requests/Reports at RFC06359-70; Handwritten Notes at RFC06384, 

6421-32; Property Inventory Reports at RFC06385-92; Arrest History for Marc 

Johnson at RFC06393-94; Statement of Witness Cordoba at RFC06401; 

Request for ID Photos and Photos at RFC06443-44

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 131 of 433 PageID #:15552
" N*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

:? 86?:;< 7?>= 
$! %! 

%-'&&%

 !"& %/

 (%&&(&$%%% $!/

6<98816<::: 00000000

LG IHLHHP HPON  --40&) -  .  . GMKOO7GMLNJ;MLPI * :* :* :* :LH ILIIGK 1987 ' -/.($''$ No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ALI JLJOIH HPON -')*$)/-*)

 .60/$/$.

$)*(+' / 

# A.*!!$ 

'*. /#$.. 

 0. 

 ! ))/

*/$) 

*0/.$ 

*0). '9

''$)1 ./$"/$1 (/ -$'.($..$)"!-*($' 9

GMMJG;GMMMI ::::::::

LJ JLLIIG 1987 #*(.#* No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ALK JMPILN 1987


--4//# 2.

)/#*)40''$). No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

LL JOOKOH 1987

'$. *-/$5

 -*
 *)

-()* - 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

LM KGPOLO HPON $#-)# 5  .  .

GNGJK7GNGJL;GNGJP7GNGKG7

GNGKH;GNGKM7GNGKN7GNGLK7GNGNG;

GNGNH7GNGNI7GNGNJ7GNGPO7

GNHJG;GNHJH * :* : . GNGKG

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

LN KIJJKN HPON

*'!*# *

'( --$  .  .

GNHKO;GNHKP7

GNHLG;GNHLI7

GNHLJ;GNHLN7

GNHLO;GNHML7

GNHOK;GNHOL7

GNHOM7GNHPN;GNIGG * :

:;*.$)


)1 ./$"/$1 $' 9 :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

LO KNOGMI 1987 0)$1 - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ALP HGJGJK 1988 * -/0"- No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AMG HNMHNG 1988

))*/ / -($) ># 14

- /$*)? No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 132 of 433 PageID #:15553
" O*!IO

Records Division Number Year Defendant(s)

Identifying Information

:? 86?:;< 7?>= 
$! %! LG IHLHHP HPON  --40&) -LH ILIIGK 1987 ' -/.($''$LI JLJOIH HPON -')*$)/-*)LJ JLLIIG 1987 #*(.#* LK JMPILN 1987


--4//# 2.

)/#*)40''$).

LL JOOKOH 1987

'$. *-/$5

 -*
 *)

-()* - 5

LM KGPOLO HPON $#-)# 5LN KIJJKN HPON

*'!*# *

'( --$

LO KNOGMI 1987 0)$1 -LP HGJGJK 1988 * -/0"-MG HNMHNG 1988

))*/ / -($) ># 14

- /$*)?

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

% 6<98:16<98; !

77	 )$&&  !&% -=%& 
 ( &!$+

4	!' 5

76% ->%&! 
 ( &!$+46<9;=1

6<9;>.6<9==16<9>7.6<:87.6<:8>.6<:965 %

6<989.6<998.

6<9>:.6<:79.

6<:86.6<:88.

6<:8:.6<:8<.

6<:8?.6<:9716<:98 ! 0% ! %

File Inventories at RFC06324-27; Criminal History Computer Screen for Perp #3

Quinones at RFC06328-30; Various court call requests; Fingerprint Examination 

Reports at RFC 6338-39 (and other places); Evidence Report from Criminal Lab 

Division at RFC06340, 6397-99; Arrest History for Chacon, Quinones at 

RFC06341-42; Statement/Confession of Quinones at RFC06344-50; Arrest 

Report dated 6/8/87 at RFC 6356; GPRs at RFC06357-58, 6377-81, 6421; 

Evidence Requests/Reports at RFC06359-70; Handwritten Notes at RFC06384, 

6421-32; Property Inventory Reports at RFC06385-92; Arrest History for Marc 

Johnson at RFC06393-94; Statement of Witness Cordoba at RFC06401; 

Request for ID Photos and Photos at RFC06443-44

 . GMKOO *

=0++' ( )/' +*-/

=*0-/*(+'$)/-).($//'

=
-

=#*/*.< -.*)

=	)2-$// )*/ 

= ,0 .//*	*'-$.*) -

=0+* )</- /!$' .

=0+* )<

=
 +*-/

=*;-*( (*  .

=GMLMM

=GMKPN  . =GMLIL  . *  .

Medical Examiner Report at RFC 06452-56; Toxicology Rep at RFC06547; 

Investigative File Index at RFC06488; Laboratory Report at RFC06490-91; 

Handwritten note at RFC06497; Evidence Report at RFC06507; Arrest Report at 

RFC06508; Handwritten GPRs at RFC06509; Mail routing slip (rejecting mail 

cover request) at RFC06513; Request for mail cover check at RFC06470, 

06514; Copy of Envelope at RFC06516-17; Daily Bulletin at RFC06523-24; 

Memo from Detective at RFC06525; Notice of person wanted for investigation at 

RFC06527; Criminal History at RFC06528; Handwritten GPRs at RFC06539; 

Evidence Report at RFC06540; Criminal History at RFC06542-43; Criminal 

history of victim at RFC06544-45; Property Inventory at RFC06546-51; 

Handwritten GPRs at RFC06560-70; copy of victim's drivers license at 

RFC06574-75; Identification photographs of suspect and others at RFC06576-

87, 91-92; Selective Service card of victim at RFC06589-90;

* :* :* :* : . *  . Medical Examiner Report at 6595-98; Toxicology Report at 6599;* ::: . GMMJH * : . *  . Medical Examiner Report at RFC06642-06648* :* :* :* : .  .  .

Medical Examiner Report at RFC06677; Oct 8 1987 Supp Report at 6704; Nov 7 

1987 Lineup Report at 6697, Nov 7 Supp Report at 6699; Nov 7 Supp Report at 

6701.

 . GMNKK;GMNKL *

=#*/*.:&.*!#*/*.< -.*)

= ,0 .//*	*'./ "0'-*0-/''

=-- ./
)!*-(/$*)-

=$5-

=-$($)'	$./*-$ .

=
1$ ) 0($..$*)*-(

=-- ./ +*-/

=	)2-$// )*/ .  .

=GMONG

=GMOOJ

=GMNKN;GMNKO * : . *  .

Investigative File Inventory at RFC06744-45; Handwritten Notes at RFC06747-

49; Photographs of suspects, witnesses at RFC06750-74; search results for 

suspect at RFC06775-77; Supp Report at RFC06778-91; Request for GSR 

testing at RFC06792; Clear database printout at RFC06793-94; General 

Offense/Arrest Report at RFC06828-29; Medical Examiner's report at RFC06830-

34; Toxicology Report at RFC06835; Evidence Report at RFC06838-42; 

Handwritten GPRs at RFC06843-45; Arrest Report at RFC06846; Handwritten 

GPR at RFC06847-48; Criminal histories of victim, witnesses, suspects at 

RFC06849-53; Daily Bulletin at RFC06854-56; Stop Order at RFC06857-58; 

Crimina history of suspect at RFC06859; Preliminary Evidence Report at 

RFC06860; Property Inventory Sheet at 06861-65; Request to hold prisoner at 

RFC06866; Arrest Report at RFC06867; Property Inventory at RFC06868; 

Soundex search results at RFC06869; Handwritten notes at RFC06870; victim's 

past arrest information at RFC06872; Criminal history and notes at RFC06873-

74; Handwritten GPR at RFC06875-92;

 . GMPKI *

@B	)2-$// )*/ .B
$./ $)
)1 )/*-4=

#*/*.:&.*!#*/*.8 -.*)=-*+ -/4


)1 )/*-4=-$($)'	$./*-$ .=

0++' ( )/-4 +*-/.*./(*-/ (:*3$*'*"4

 +*-/= ,0 .//*	*'./*0-/''=-- ./

 +*-/.= '*)4$)0/ .<*-(HGH.=*). )//*

 -#*-(=0+* )!*-/- /!$' .> ! ). ?=// ( )/=0+* )*/!*-/ /!$' .> ! ). ?

= ) -'-*"- .. +*-/.=1$ )  +*-/.=

*4$"-(  .

=GMPJP

=GMPKH

=GNGHK * : .  .  .

Defendant Statement at RFC 06948-51; Fired Evidence Report at RFC 06984; 

Defendant Statements at ; Handwritten Notes/ GPRs at RFC 07004-10, 07013; 

Photos at RFC 07016-7032; Property Inventory at RFC 6990-92, 6975-77; 

Evidence Report at RFC 06985; Firearm Lab Report at RFC 06981-84; Arrest 

Report 6968-73; Evidence Report re photos of lineup at RFC 06966; Medical 

Examiner Report at RFC 6902-06;

 . GNGNG;GNGNH *

I	)2-$// ))*/ .$)!$' 6G'$./ *)
)1 )/*-4

>GNHHO7GNHIO?  .

GNGKG7GNHHO7

GNHIO * : / 6)**(+-$.*) :::

* :::* :* : . *  . Medical Examiner Report at RFC07153-56; Toxicology Report at RFC07157 . GNIIP;GNIJG *

=*./(*-/ (:*3$*'*"4 +*-/.

=0+* )!*-/- /!$' .>?

=

=4+ */ 

=	)2-$// )*/  . =GNINM * : / 6)**(+-$.*) :::

 . GNJHJ;GNJHK *

N+" .*!)*/ .>N*0)/ !*-6))*// ''

2#$#*) .- ($..$)"?6K*;-*( (*.6

0/*+.4 +*-/6K	)2-$// )*/ .6-- ./

 +*-/6''#*/*.  .

GNJHI6GNJIL;

GNJIM6GNJOJ  .

GNJHO6GNJIG6

GNJKJ6GNJOO6GNJPG  . *  .

Medical Examiner Report at RFC 07281-84; Toxicology Report at RFC 07285; 

Handwritten Notes at RFC 07312, 07319-20, 24-26, 30, 38, 41-42, 45, 55-57, 82-

86; Firearm Report at RFC 07318; Letter from purported witnes at CCJ re 

confession at RFC 07343; Photo at RFC 07371, 7378; Arrest Report at RFC 

07372; Evidence Report at RFC 07373-76; Property INventory at RFC 7380; 

Fired Evidence Report at RFC 07395; Property Inventory at RFC 07397-

 . GNKLH * 
*-/*-4 +*-/6990+* ) * :* : / 6)**(+-$.*) :::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 133 of 433 PageID #:15554
" P*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

MH HPNJIH 1988


0$.*-$"0 56$"0 '

*-$"0 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

MI IGLHLO 1988 *((4$#-. No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AMJ IINMNL 1988 1$*''5* No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AMK IOLPOP 1988 *'!**.-$* No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AML IPIPIH HPOO 
*)4$/#!*-&:$/#!*-  .  .

GNOPN7GNOPO;GNPGG7GNPKG;GNPKH7

GNPKI7GNPKJ7GNPMK7GNPMN;

GNPNM7GNPNN7GNPNO;GNPNP7GNPOG7

GNPPG;GNPPK7GOGGJ7GOGGL;GOGGM7

GOGIL7GOGIM7GOGIN7GOGIO7GOGJK7GOGJN7GOGJP7GOGKG;GOGKJ7

GOGKM;GOGKN7GOGLI7GOGLJ;GOGLM7

GOGLN7GOGLO * :* : . GOGGL;GOGGM7GOGJK7GOGLI

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

MM JHOJGO 1988

1$ -	 -)) 56)/*)$*

' )/$) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

MN KHNGNO HPOO -1$'' :-1'$)  .  .

GOHLJ7GOHLK;GOHLN7GOHLO;GOHMI7

GOHNK7GOHNO;GOHNP7GOHOG7

GOHOJ7GOIHJ7GOIHL * :* : . GOIHJ7GOIHL

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

MO KHPHNI 1988 #-$./*+# -$1$- ''$ No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AMP KLLPJI HPOO

1$-/$5

 '$+ *-$"0 5  .  .

GOJJG;GOJJK7GOJKG;GOJKH7GOJKI7

GOJKJ;GOJKN7GOJKO;GOJKP7GOJLI;

GOJLL7GOJNH7GOJNL;GOJNM7GOJNN7

GOJNO;GOJNP7GOJOG7GOJOH7

GOJOI7GOJOJ7GOJOK;GOJOM7GOJON7

GOJOO7GOJOP;GOJPG7GOJPH7

GOJPI7GOKJO7GOKJP7GOKKI7

GOKLJ7GOKLK7GOKLL;GOKMJ7GOKMK7

GOKML * : . GOJOG7GOKJP  . GOJOO7GOKJO7GOKKI

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 134 of 433 PageID #:15555
" HG*!IO

Records Division Number Year Defendant(s)

Identifying Information

MH HPNJIH 1988


0$.*-$"0 56$"0 '

*-$"0 5

MI IGLHLO 1988 *((4$#-.MJ IINMNL 1988 1$*''5*MK IOLPOP 1988 *'!**.-$*ML IPIPIH HPOO 
*)4$/#!*-&:$/#!*-MM JHOJGO 1988

1$ -	 -)) 56)/*)$*

' )/$)

MN KHNGNO HPOO -1$'' :-1'$)MO KHPHNI 1988 #-$./*+# -$1$- ''$MP KLLPJI HPOO

1$-/$5

 '$+ *-$"0 5

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.6

9999)

*./*-/ (

- +*-/$)$/ ::::::: . *  .

Computer printout of criminal history (unreadable) at RFC07514; Medical 

Examiner Report at RFC07517; Court attendance reports at RFC07525-35; 

Supp Report 10/11/88 saying witness/participant participated in lineup and 

conclusion was "Deception Indicated"

 . GNLLP *

H1$ )  +*-/6/*+- -6J
 +*-/.6''

#*/*"-+#.>JL+" .;-$( . ) 6'$) 0+6

(0".#*/.*! ! ))/?6''	)2-$// )*/ .>HH

+" .?6*/#0+* ).60. *! /#

0++' ( )/-4)*./(*-/ ( +*-/6*+4*!

*$' 0-$/4-6 $''$"$$'$/4-6

0.$) ..-.6+*..$'4)*/ .>$)1 )/*-4%0./

.// .A.?  .

GNLOP6GNLPM;

GNLPO6GNMGK6

GNMGN;GNMHH6GNMMP  . GNMJH  .  .  .

Medical Edaminer Report at RFC07690-95; Toxicology Report at RFC07696; 

Photographs of crime scene, victim, and lineups at RFC07562-88, 90-94, 99; 

Handwritten notes at RFC07589; Business card at RFC07595; Handwritten 

notes at RFC07596-98, RFC07607-08; Medicaid card at RFC07600; Social 

Security card at RFC07602-63; Message notes at RFC07604, 09-; Request for 

identification photos at RFC07605; business cards at RFC07606; results of 

search for license plate at RFC07612-15; Investigative File control at 

RFC07616; Arrest Report at RFC07628, 34; Property Inventory at RFC07629-

30; Request to hold prisoner at RFC07631; Evidence Report at RFC07632-33; 

Stop Order at RFC07635; Handwritten GPRs at RFC07636; request for analysis 

at RFC07638; Results of fingerprint analysis at RFC07641; Vehicle disposition at 

RFC07642; Evidence Report at RFC07644-46; Property Inventory at RFC07647-

48; Fired evidence report at RFC07649; Supp report at RFC07650; Property 

Inventory at RFC07652-57; Evidence Report at RFC07658-60; Handwritten 

GPR at RFC07668-70;

 . GNNHP;GNNIG * #*/*.6*+4*!0.$) ..-60+* )  .

GNNKN6GNNMN;

GNNNH6GNNNN  . GNNMG6GNNNI  .  .  .

Copy of cassette tape at RFC07721; Identification photographs at RFC07722-

24, 26-36; Photographs of victim? at RFC07725; Preliminary Fired Evidence 

Report at RFC07739; Evidence Report at RFC07740; Property Inventory at 

RFC07742-44; Handwritten notes at RFC07747; Evidence Report at RFC07757; 

Request to hold prisoner at RFC07760; Arrest Report at RFC07761; Arrest 

Information at RFC07762; Property Inventory at RFC07763; Handwritten GPRs 

and notes at RFC07766-68; print out of database search results at RFC07769-

71; Request for non-published telephone and handwritten notes at RFC07772; 

Handwritten GPR at RFC07776; Handwritten notes at RFC07777; printout of 

search results for victim at RFC07779-80; Criminal History at RFC07781-83; 

copy of business card at RFC07786; Handwritten GPR at RFC07787; Arrest Report at RFC07792; Handwritten GPR at RFC07793-97

 . GNOGI * ''J	)2-$// ))*/ .6''.0+* ).  .

GNOGH6GNOGM6

GNOJO * : .  .  .

Handwritten notes at RFC07801; Photographs at RFC07804; Investigative File 

Control at RFC07805; Evidence Report at RFC07807; Property Inventory at 

RFC07810-13; Arrest Report at RFC07822; Evidence Report at RFC07825; 

Print out of computer search for suspect at RFC07830; Handwritten GPR at 

RFC07837-38; Typed statement of suspect at RFC07842-56; Arrest report at 

RFC07859; typed statement of suspect at RFC07860-73; Handwritten GPRs at 

RFC07977-81; Arrest Report at RFC07884; Criminal history of victim at 

RFC07887

 . GNPKG;GNPKH *

K	)2-$// ))*/ .$)!$' 6G'$./ *)
)1 )/*-4

>GOGGL;GOGGM7GOGJK7GOGLI?

H$)!$' 6G'$./ *)
)1 )/*-4>OGLH?70. 

*!B)*/ .B*)$)1 )/*-40)' -  .

GOGGL;GOGGM7GOGJK7

GOGLI * : . *  .

Medical Examiner Report at RFC 07901-05; Statements of Defendant at RFC 

07951-7958; Arrest Report at RFC 07964-66, 07980; LEADS Report at RFC 

07967-7974; Fugitive Arrest Receipt RFC 7977; Waiver of Extradiion at RFC 

07978-79; Info for Daily Bulletin at 08031; Handwritten Notes at 08034, 0851; 

Request for telephone records at RFC 08039; Stop Order at RFC 08001-02; 

Request for UFAP warrant at RFC 08007; Supp. Report explaining defendant 

lives out of state at RFC 08010.

 . GOGPN *

H-*+ -/4
)1 )/*-4# /6I1$ )  +*-/.6K

	)2-$// ))*/ .6$)" -+-$)/3($)/$*)

 +*-/.)*;-*( (*- "-$)"!$)" -+-$)/

 3($)/$*)6
 +*-/6*./(*-/ ( +*-/6

	*.+$/'$5/$*) +*-/6*/#0+* ).  .

GOHKJ6GOHKL6

GOHKN6GOHKP  . GOHGI  / 6)**(+-$.*) :::

 . GOHNO;GOHNP *

I	)2-$// ))*/ .$)!$' 6G'$./ *)
)1 )/*-4

>GOIHJ7GOIHL?  . GOIHJ7GOIHL * : .  .  .

Handwritten Notes at RFC08211-08221, 8184; Property Inventory at RFC08204-

06, 09, 10, 8222; Forensic Report at RFC08207, Line Up Photo Report at 

08201; Arrest Report at RFC08197-8200; Crime Lab Fired Evidence REport at 

RFC08183; Supplemental Report at RFC08174; Medical Examiner Report at 

RFC 08158-8162;

 . GOIMJ *

M	)2-$// ))*/ .># 1$'4- / ?6

*./(*-/ (- +*-/6''0+* ).  .

GOIML6GOJIG6

GOJII6GOJIK6

GOJIM;GOJIO *  .  .  .

Medical Examiner Report at RFC08234-08238; Arrest Reports at RFC08258-

08259, 8304, 8307; Toxicology Report at RFC 8283; Fired Evidence Report at 

8270; Evidence Report at 8272-75, 8306, 8311-12; Preliminary Fired Evidence 

Report at 8276; GPRs/Handwritten Notes at RFC 8301-02, 8309, 8320-24, 8326-

28; Letter Invoking Miranda at RFC 8303; Hold Past Court Request at 8308; 

Property Inventory at 8310, 8314-19;

 . GOJNL;GOJNM *

HH.$)!$' 6I'$./ *)
)1 )/*-4>GOJOG7

GOKHK;GOKHN7GOKIO;GOKIP7GOKJJ;GOKJK7GOKJP7

GOKKH?

O	)2-$// ))*/ .$)!$' 6H'$./ *)
)1 )/*-4

>GOJOO7GOKJG;GOKJI7GOKJN;GOKJO7

GOKKG7GOKKI?  .

GOJOO7GOKJG;

GOKJI7GOKJN;GOKJO7

GOKKG7GOKKI * : .  .  .

Medical Examiner Report at RFC08335-8339; Arrest Reports at RFC08371, 

08386-87, 08412-13, 08443-44, Handwritten Noets at RFC 08380, 08414-17, 

08428-08442; Holdover Request for Defendant at RFC08392; Firearms Receipt 

& Worksheet at RFC08395, Preliminary Fired Evidence Report at RFC08398, 

Evidence Report at RFC08403, Line-up Photo Report at RFC08407, Request for 

Ballistics Comparison at RFC08410, Property Inventory at RFC08445-52, 

Request for Identification Photos at RFC 08464, Photos at RFC 08455-63.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 135 of 433 PageID #:15556
" HH*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

NG KMMGJJ 1988 ( .-$.6-2$) 4- - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ANH KMOKII 1988  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ANI LGIHNJ 1988 #-' .-/4 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ANJ LJGPHN HPOO (*.'& -  .  .

GONJK7

GONKI7

GONKJ;GONKK7

GONKL;GONKM7GONNI7

GONKN7

GONNM7GONNN;GONNO7GONNP7

GONOG7GONOK7GONOH7GONOI7

GOOKI * :* : . GONOG7GONOK

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

NK LNLPHI HPOO $# '-(./   .  .

GOOKK;GOOLI7GOOMI;GOOMK

GOOOG;GOOOI * :* :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

NL GIGIOO HPOP -- )*$).*)  .  .

GOOPM7GOOPN;GOPGI7GOPGJ7

GOPGK;GOPHM7GOPJM;GOPJN * :* :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

NM GINGJM 1989 #2) //.6'1$)1$. No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/ANN GNPKJL 1989

)0 '  .0.6)" '

.$*6 -*+*)/ 62$)

-/$56' -/%  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO HINGGO 1989 -&*.* No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 136 of 433 PageID #:15557
" HI*!IO

Records Division Number Year Defendant(s)

Identifying Information

NG KMMGJJ 1988 ( .-$.6-2$) 4- -NH KMOKII 1988  / NI LGIHNJ 1988 #-' .-/4NJ LJGPHN HPOO (*.'& -NK LNLPHI HPOO $# '-(./ NL GIGIOO HPOP -- )*$).*)NM GINGJM 1989 #2) //.6'1$)1$.NN GNPKJL 1989

)0 '  .0.6)" '

.$*6 -*+*)/ 62$)

-/$56' -/% 

NO HINGGO 1989 -&*.*

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . GOLHM;GOLHN *

O)*/ .>IJ*0)/ !*-?6I-- ./ +*-/.6I

-- ./0++' ( )/-4 +*-/.6H""-1/ 

// -40++' ( )/-4 +*-/6H1$ )  +*-/6

*+4*!0.$) ..-60. *! /#

0++' ( )/-4 +*-/6*./(*-/ (- +*-/6''

0+* ).6*;-*( (*- "0).#*/- .$0 

/ ./6*;-*(( (*- #*'- ,0 ./  .

GOLOP6GOMGM6

GOMGO6GOMHG6

GOMHI  . GOLJJ  .  .  .

Medical Examiner Report at 8473-76;Handwritten Notes at RFC08515, 8529-30; 

8579 -8612; Arrest Report 8577, 8469, 8535, 8532; Property Inventory at 

RFC08618-22; Evidence Reports at 8615-17, 8531; Request for Ballistics 

Comparison at RFC 8575; Consent to Search at 8574; Line Up Report in PRF at 

RFC 8550-51 is signed by a different sergeant than the same line up report in 

the SF at RFC 161293-94, and unsigned at RFC08527-085-28; Preliminary 

Fired Evidence Report at RFC 08537-38; Request for Hold Over at RFC 08534; 

Request for Gunshot Residue Test at RFC 08533; Firearms Receipt at 

RFC08522;

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.$)$/ ::::::: / 6)**(+-$.*) :::

 . GOMNM *

*+4*!-*++(+'*4   -'- $/)$*)

*0)/6(0".#*/*! ! ))/6H	)2-$// )

)*/ 60+* )  . GONHN  . GOMPO  .  .  .

Credit Union Statement for Victim at RFC 08679; Photo of Defendant at RFC

08681; Preliminary Fired Evience Report at RFC 08685; Forearms Receipt and 

Worksheet at RFC08687; Evidence Reports re: taking photos at RFC 08689-90, 

8703-04, ; Handwritten Notes at RFC 08691, RFC08702, RFC 08716-; Request 

for Ballistics Comparison at RFC 08698; Stop order request at RFC 08708; 

Material Submitted for Daily Bulletin at RFC 08709; Property Inventory sheets at 

RFC 08724-8732; Medical Examiner Report at RFC08654-57

 . GONNN;GONNO *

H	)2-$// ))*/ .$)!$' 6G'$./ *)
)1 )/*-4

>GONOG7GONOK7GOOJO?7

0. *!B)*/ .B*)$)1 )/*-4$.0)' -  .

GONOG7GONOK7

GOOJO * : .  .  .

Arrest Report at RFC 08788-89, 08795-96; Request for Latent Fingerprint 

Comparison at RFC08797; Handwritten Notes at RFC08800; Recovered Vehicle 

Supp. Report at RFC08804-05; Evidence REport re: blood stain at RFC08806-

13; Property Inventory Reports at RFC 08824; Supp. Report re: latent 

fingerprints and other taxi robberies at RFC08814-15, Report re: fingerprints at 

RFC 8816-18, Supp. Report re: line up at RFC 08819-20, Supp. Report re 

Vehicle Recovered at RFC08821, Supp Report at RFC 08825-8827; Supp 

Report re: description of the offender at RFC 08828-31.

* :::* :* : . *  . Medical Examiner Report at RFC 08853-60; Toxicology Report at RFC 08861;* :::* :* : . *  . Medical Examiner Report at RFC 8897-8901; Toxicology Report at RFC 8902*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.6

9999)

*./*-/ (

- +*-/$)$/ ::::::: .  .  .

Assignment sheet at RFC 8938-39; Medical Examiner Report at RFC 8940-42; 

Toxicology Report at RFC 8943

 . GPGPM;GPGPN *

// ( )/.*!1$/ ')$&$)* -/-( /6

J
)1 )/*-4 +*-/.6I	)2-$// ))*/ .>L

*0)/ !*-?;))*// ''2#$#*) .7+*..$'4

.)0++' ( )/-4 +*-/.>HG- 

0)*0)/ !*-6/# $)1 )/*-4%0./'$./.+'0-';

.)0++.6.*$/))*/  / -($) $!)

#*2()4- ($..$)"?6*./(*-/ (- +*-/6

-$($)'	$./*-$ .60+* ).6H+" *!+-$)/ 

)*/ .6$-  +-/( )/ +*-/6-$(  ) 

-* ..$)" +*-/6-$( 
 +*-/  .

GPHNL6GPIGL6

GPIHL6GPILK6

GPIMK6GPIMM6

GPIMO6GPING  . GPIGM  .  .  .

Assignment sheet at RFC 8978; Medical Examiner Report at RFC 9025-30; 

Toxicology Report at RFC 09031

 . GPINJ;GPINK

 .>/# - - )*

$/ (.($..$)"

!-*(/# 

$)1 )/*-46

#*2 1 -/# - 

2 - I$/ (.

/#/2 - '$./ 

*)/# $)1 )/*-4

!*-(0/($..$)"!-*(/# !$' ;

*'4"-+#

3($)/$*)

 .0'/.)

-$(  ) 

#*/*.?

*..$'4)*/ .($..$)">$)1 )/*-4%0./'$./.

A.? * :* : . *  .

Addendum to death investigation (RFC 9279); Investigative File Inventory (RFC 

9273); Case Supplement Report (RFC 9278-9284); Supplemental Case Report 

re Line Up (RFC 9285-86); Supplemental Case Report re initial investigation 

(RFC 9286-89); Case Supplement Report (RFC 9290-9291); Case Supplement 

Report (RFC 9292-9293); Case Supplement Report (RFC 9294-9298); Case 

Supplement Report (RFC 9299-9301) (re cause of death); Case Supplement 

Report (RFC 9302-9304) (re reclassifying as a homicide); Grand Jury Testimony 

(RFC 9305-9322); Arrest Report (RFC 9355); Medical Examiner's Report (RFC 

9356-9360); Toxicology Report (RFC 9361); Case Supplement Report re 

morgue (RFC 9362); Arrest Report (RFC 9364-9365); Report (early in 

investigation, re offense) (RFC 9366-9367); ASA case fact sheet (re theory of the 

case) (RFC 9368-9369); Lab results (re cause of death) (RFC 9373-9376); 

Crime Scene Processing Reports (RFC 9377-9378); General Progress Report 

notes (RFC 9404-9411).

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 137 of 433 PageID #:15558
" HJ*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

NP HMLKKL 1989

#-$./*+# --/" 6
0$.

 - 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

OG HOKPKP HPOP -)$.* )$/ 5  .  .

=GPNHL=GPNIG=GPMGP=GPMHG;GPMHO

=GPMHL=GPMLK=GPMLI=GPNHM=GPNHN=GPNHO;GPNHP

=GPMIN;GPMIO6GPMIP;GPMJG6

GPMKK;GPMKL6GPMKM6GPMKN6

GPMNJ6GPMNM6GPMNL * :* : .

=GPNHL=GPNIG

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

OH IKLOGN 1989

0-**-' .6-'*.

*() No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

OI ILOLNG HPOP

0-/$.$-&')

$# '-" )/  .  .

GPPGL;GPPHH7GPPIH;GPPJI7GPPHP7

GPPIG7

GPPMN7HGGHI7

GPPMO;GPPMP7

GPPNI;GPPOH

GPPOI7GPPOK7GPPOM7GPPON7GPPOP7

GPPOJ7

GPPPG7GPPPH7

HGGGN;HGGGO

HGGGP;HGGHG7

HGGIJ7

HGGJJ7

HGGMG7

HGGML

HGGNN7HGGPK * :* : .

GPPOI7GPPOK7GPPOM7GPPON7GPPOP7HGGGP;HGGHG

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

OJ IMKIHP 1989 )$ 'A $''4 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AOK

IMKMKH$):/- /!$' 

)0( -IONMKH HPOP '- ) * -/.  .  .

HGHLO;HGHLP7HGHMG;HGHMK7HGHML;

HGHMO7HGHMP7HGHPG7HGHPH7

HGHPJ * :* :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

OL JOHKIP HPOP -- )0-*&  .  . •RFC10244-250, RFC 10258-259  .

N/A - No inventory in 

investigative file * :

:;*

	)2-$// )*/ .

$)
)1 ./$"/$1 $' 9 :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

OM KGGIIN 1989  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AON LJOPHK HPOP 	 )-4*$).*)




	
  

OO LKHPLJ 1989 *#))4'*- . No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 138 of 433 PageID #:15559
" HK*!IO

Records Division Number Year Defendant(s)

Identifying Information

NP HMLKKL 1989

#-$./*+# --/" 6
0$.

 - 5

OG HOKPKP HPOP -)$.* )$/ 5OH IKLOGN 1989

0-**-' .6-'*.

*()

OI ILOLNG HPOP

0-/$.$-&')

$# '-" )/

OJ IMKIHP 1989 )$ 'A $''4OK

IMKMKH$):/- /!$' 

)0( -IONMKH HPOP '- ) * -/.

OL JOHKIP HPOP -- )0-*&OM KGGIIN 1989  / ON LJOPHK HPOP 	 )-4*$).*)OO LKHPLJ 1989 *#))4'*- .

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . GPKOK;GPKOL *

''N
)1 )/*-4 +*-/.6H-- ./ +*-/6

*./(*-/ (- +*-/6J*/ .>P*0)/ !*-;

))*// ''2#$#*) .?60+* )6*+$ .*!I

0.$) ..-.6+*..$'4	)2-$// ))*/ .

>$)1 )/*-4%0./.// .+'0-'*/ .62$/#*0/

.+ $!4$)"#*2()4?  .

GPLHI6GPLMH6

GPLML6GPLMN6

GPLMP6GPLNH6

GPLNJ6GPLNL6

GPLNN;GPLOJ6GPLOM;

GPLON6GPMGH  . GPKPK6GPKPN  .  .  .

Assignment sheet (9438); Medical Examiner's Report (9441-44); Toxicology 

Report (9445); Supplementary Report w/ description of car and suspect from 

eyewitness Sandra Mantilla (9476 and 9524); Felony minute sheet form (9491); 

Request for firearm comparison (9494); arrest report (9495-96); request for 

communication tapes (9497); line up report date amended from 4/3/89 to 5/3/89; 

handwritten notes re suspect, car, investigation, how to contact a witness, etc. 

(9510-12, 9555, 9559--9583, 9586-87, 9601); statement of Christopher Carthage 

(9515-18); fired bullet report (9526); Arrest report (9531-32); recovered vehicle 

supplementary report (9533-34); request to hold Mark English for interrogation 

(9535); inventory sheets (9536, 9542-51); photographs of suspects, weapons, 

and an escort service business card (9589-9600, 9602-03); a key (9606-07).

 . GPMLI *

=0+* ).</- /!$' .<

=0+* ).</- /!$' .<

= ) -'!! ). .  +*-/

=  $+/.

=/*+- -:$..$)" -.*)

=	)2-$// )*/ 

=*0-/$.+*.$/$*)
 // -!-*(

=*./(*-/ (:*3$*'*"4 +*-/.  .

=GPNGI

=GPNHH

=GPNIG * : .  .  .

Medical Examiner Report (9619); Toxicology Report (9623); Second Decedent's Medical Examiner Report (9624); Inventory Sheet (adds items missing from one 

in PRF) (9652); Signatory change on report (9656); Report with handwritten 

notes in margin (9660); Notes regarding witness statements (9669); handwritten 

notes added to general offense case report (9671); Property Inventories of 

photos, bullet, blood vial, blood swab (9678-89); Signed statement of Francisco 

Benitez (9690-92); Arrest Report (9693); Felony Minute Sheet (9694); Evidence 

Report (9696); General Progress Reports/Hand Written Notes (9698-9700-15, 

9720); Receipt for 3 items at Foot Locker, $79.35 (9716); Receipt for one item at 

Boston Shirt Yard, $6.48 (9717).

 . GPNNJ;GPNNL *

0++' ( )/-4
 +*-/60++' ( )/-40. 

*! /# +*-/6*./(*-/ (- +*-/6''J

	)2-$// ))*/ .60+* )  .

GPONH6GPOON6

GPOPN * : .  .  . Medical Examiner Report (9722-27); Court Attendance Report (9732)

 . GPPMO;GPPMP *

L$)!$' 6G'$./ *)
)1 )/*-4>HGGMH7

HGGOH7HGGPJ7HGGPO;HGGPP?

HG	)2-$// ))*/ .$)!$' 6J'$./ *)
)1 )/*-4

.B)*/ .B>GPPOI7GPPOK7GPPOM7

GPPONGPPOP7HGGGP;HGGHG7HGGLJ;

HGGLK7HGGNM?  .

GPPOI7GPPOK7

GPPOM7GPPON

GPPOP7HGGGP;HGGHG7

HGGLJ;HGGLK7HGGNM * : . *  .

Medical Examiner Report (9912-17); Toxicology Report (9918); Lab Report 

(10013-14); Investigatory File Control (9968-69); Mug shot photos (9971, 9973, 

9975, 9977, 9979-80); Notes of names and addresses and witness statements 

(9972, 9974, 9976, 9978, 9982, 9984, 9986-87, 9989-90, 10076, 10093); crime 

scene photos (9993-10006); Notes re interview with State witness Weaver 

(10009-10); Felony Minute Sheet (10020, 10033); Arrest Reports (10021, 10032, 

10064); Signed Statement of State witness Weaver (10053); Signed Statement 

of State witness Flowers (10054); Photo lineup information (10058); 

Documentation of lab testing (10060); General Progress Report Notes regarding 

lab testing of the weapon and an undisclosed witness (10061); Vials of blood 

and wood inventoried (10067-69, 10087-92); Criminal History on Alternate 

Suspects and General Progress Report witnesses and suspects (10071-10085); 

hand written notes re murder (10098).

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.)

*./(*-/ (

- +*-/$)$/ ::::::: . *  .

Assignment slip (10103); Medical Examiner Report (10106-12); Toxicology 

Report (10113); Supplemental Report of witness statements, but appears to 

relate to a different homicide case than the rest of the file (10118)

 . HGHPG *

HG0++' ( )/-4 +*-/.$)!$' 6L'$./ *)


)1 )/*-4>HGHPK;HGIGL7HGIHH;HGIHL7HGIIG;

HGIIH? * :* : .  .  .

Medical Examiner Report (10165-68); Investigative File Inventory (adds a 

Supplemental Report of 9/25/89, which is not in the PRF) 10190; Arrest Report 

(dated 9/22/89) (10208); ASA Felony Minute Sheet (10209); Stop Order dated 

7/13/89, wanting Defendant for another unrelated robbery, the day before this 

offense (10218); Wanted Person Report re unrelated armed robbery (10219); 

Supplemental Report regarding unrelated armed robbery (10220-21); General 

Offense Report for unrelated armed robbery (10222); handwritten lineup report 

(10224); handwritten notes re witness interviews (10225-10228); Evidence 

Report and Inventory Documents (10230-42).

* :::* :* : .  .  .

Medical Examiner Report (10251-10257); Supplemental Report (10272); 

Supplemental Report (10283-10284); General Offense Case Report (10285).

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.)

*./(*-/ (

- +*-/$)$/ ::::::: / 6)**(+-$.*) :::

* :::* :* : .  .  . Medical Examiner Report (10324-28)*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.)

*./(*-/ (

- +*-/$)$/ ::::::: . *  . Medical Examiner Report (10357-60); Toxicology Report (10361)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 139 of 433 PageID #:15560
" HL*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

OP LKMLLO 1989 $#-(*.60' '.*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/APG LLGGKI 1989 *-" -1 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/APH LLHKMH 1989

))*/ / -($) ># 14

- /$*)? No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

PI LLMIMG 1989  *-" 0-$ ' No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/APJ LLOLLI 1989 )/#*)4-5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/APK LNPMPN HPOP .- )  .  .

HGNNL;HGNNN6HGOKO;HGOLG6HGNMN;

HGNNJ6HGOJH;HGOJI6HGNOM * :* : . HGNNL;HGNNN * :

PL LOOGGL 1989

 .0.0- 56$"0 '*%.6

0'0- 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

PM LPPGGH 1989

)/*$)  '' 46 )-$&

4'*-6
(*)/ 4'*- No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

PN GHMLGL 1990 ))4./-6' 3-/$) 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/APO GHOHGL 1990 '1$.)# 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 140 of 433 PageID #:15561
" HM*!IO

Records Division Number Year Defendant(s)

Identifying Information

OP LKMLLO 1989 $#-(*.60' '.*)PG LLGGKI 1989 *-" -1 5PH LLHKMH 1989

))*/ / -($) ># 14

- /$*)?

PI LLMIMG 1989  *-" 0-$ 'PJ LLOLLI 1989 )/#*)4-5PK LNPMPN HPOP .- )PL LOOGGL 1989

 .0.0- 56$"0 '*%.6

0'0- 5

PM LPPGGH 1989

)/*$)  '' 46 )-$&

4'*-6
(*)/ 4'*-

PN GHMLGL 1990 ))4./-6' 3-/$) 5PO GHOHGL 1990 '1$.)# 5

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.)

*./(*-/ (

- +*-/$)$/ ::::::: .  .  .

Medical Examiner Report (10398-10401; Toxicology Report (10402); General Offense Report altered version (10412-13 - alteration at 10413)

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.)

*./(*-/ (

- +*-/$)$/ ::::::: / 6)**(+-$.*) :::

 . HGKKP;HGKLG *

K0++' ( )/-4 +*-/.>))*/ / -($) 2#$#

*) .?6*/#	)2-$// ))*/ .6 ' . *! -.*)

$)0./*4!*-(6 '*)4$)0/ # /6-$( 


 +*-/*)"0).#*/- .$0 6*./(*-/ (- +*-/6''

+#*/*/.6*/#0+* ).  . HGKNO6HGLHN  . HGKOG6HGKPK  / 6)**(+-$.*) :::

 . HGLJM *

J ) -'!! ). .  +*-/.6M0++' ( )/-4

 +*-/.>))*/ / -($) 2#$#*) .?6-$($)'

	$./*-4*! ! ))/6	*' ,0 ./6I-- ./

 +*-/.6 ' . *! -.*)$)0./*4- +*-/6

-- ./--)/6$/) ..// ( )/6*/#

0+* ).6''+#*/*.6+*..$'4.>$)1 )/*-4

%0./.// .6)*$)!*-(/$*)*)#*2()4

+" .?  . HGLKP6HGMHL  . HGLMP6HGLNO  . *  .

File Inventory (10535); mug shots and photograph (10538-44, 10575); hand 

written notes re the investigation (10545, 10549, 10554, 10593-94, 10608-9, 

10615, 10618-19, 10630, 10631-42); ASA report (10558); notes re lineup 

(10563); suplemental report from unrelated robbery involving suspect (10564); 

Arrest Report and documents/reports re arrest (10565-74); Message slip re fire 

arms analysis (10576); Property Inventory (10577, 10583-89, 10592); Memo re 

seeking ballistics comparison, gun to bullets (10578); Written statement of 

suspect Leonard Cook (10604-05); Supplemental Report re arrest of Cook 

(10606-07); Release of Person In Custody form (charges against Cook rejected) 

(10610); criminal record of suspects Murial and Cook (10611-14); stop orders re 

Cook and Murial (10622-23).

 . HGMNH *

*/#	)2-$// ))*/ .6H)*)'4)*/ 6

*./(*-/ (- +*-/6*/#+#*/*.6*/#0+* ).  . HGNGI6HGNIJ * : . *  .

Page 2 of Supplemental Report re lineup (10656, 10700); Supplemental Report

re interviewing alternate suspect Jose Arreguin and Arreguin's friend Celedonio 

Guzman (10663-64); file inventory (10671); pictures (10672); Defendant's 

statement (10673-77); Arrest records re defendant for another offense (10682, 

10710-11); Arrest Report (10683, 10687); Felony record minute sheet (10686); 

Defendant's statement (10694-97); Request Memo: Guevara signed the dendant 

out (10698); General Progress Report hand written notes (10701-02); Car 

report, VIN to car check (10703); Medical Examiner Report (10716-19); 

Toxicology Report (10720); Illegibly Copied Memo (10721-22); Handwritten 

notes (10723)

 . HGNMK;HGNML *

''.0+* ).6H0++' ( )/-4 +*-/>+*..$'4

0. *! /#?6H )9!! ). .  +*-/6*+4

*!0.$) ..-!*-% 2 '-42#*' .' .#*+6

+#*/*.*! ! ))/6+*..$'4.)

#)2-$// ))*/ .9$/$*)')*/ 8/# $)1 )/*-4

'$./.*;-*( (*6#*2 1 -/# - 2.)*.0#

( (*$)/# $)1 ./$"/$1 !$' 9  .

HGNNL;HGNNN6

HGOJK6HGOKK;HGOKM  . HGNPL  . *  .

Medical Examiner Report (10733-37); Toxicology Report (10738); Investigative 

File Inventory (10764-65); photographs (10767-73); business card for pawn 

shop (re proceeds) (10774); General Progress Report and hand written notes 

(10831-46, 10775-77); criminal records searches (10778, 10827-29); Report re 

fingerprint matching defendant (10786); Property Inventory Reports (10788-89 

10822-25, 10847-51, 10856); Felony minute sheet (10792); Crime Scene 

Processing Report (10793); Request for testing of blood on Defendant's jacket 

(10795); Arrest Report (10796); Defendant's Statement (10810-11); CHA Senior 

Housing (victim's building) Security Report (10854-55).

 . HGOMJ *

H-*"- ..0++' ( )/-4 +*-/6P
)1 )/*-4

 +*-/.6''J ! ))/-- ./ +*-/.6-$($)'

	$./*-4*!H ! ))/6(0".#*/.*!HK+ *+' 

$)1*'1 $)/# $)1 ./$"/$*)>/# 42 - ''$)'0 

$)0++' ( )/-4 +*-/.?6+*..$'4.)

	)2-$// ))*/ .>$)1 )/*-4%0./.// ..?  .

HGPKG6HGPKI6

HGPKK * : / 6)**(+-$.*) :::

 . HGPOK *

I	)2-$// ))*/ .6+*..$'4)*/ .>$)1 )/*-4

%0./.// ..?60+* )  . HGPOI;HGPOJ * : / 6)**(+-$.*) :::

 . HHGJK *

''K	)2-$// ))*/ .6(0".#*/.*! ! ))/

)J*/# -+ -.*).>I*!/# (2 - )*/$)'0 

)42# -  '. $)/# !$' ;)/*)$**-- .6 *-" 

'*)*?60+* ).6+*..$'4.>$)1 )/*-4

%0./.// . ) -'-*"- .. +*-/.?  . HHGLI;HHGLK6HHGPN * : . *  .

Photos at RFC 011036-49; Request for I.D. Photos at RFC 011050; Handwritten 

Notes at RFC 011052-54, 11091, 96-99; Defendant's statement at RFC 11067-

69; Alibi Statement at RFC 11070-71; Arrest Report at RFC 11074; Evidence 

Report at RFC 11075, 79-81, 93; Property Inventory Report at RFC 11076, 94-

95;

 . HHHGM *

J
)1 )/*-4 +*-/.6K	)2-$// ))*/ .>))*/

 / -($) 2#$#*) .?60+* ).6*./(*-/ (

- +*-/  .

HHHGL6HHHJL6

HHHJO6HHHKG;HHHKJ * : . *  .

Defendant Statement at 11112-11124; Arrest Report at 11125; Evidence Report 

at 11128; Property Inventory at 11133, 11146-47, 11165-66; Handwritten Notes at 

11134-11138, 11140-43; Supp. Report in PRF at 162302 has different approval 

date (01/12/90) than the same Supp Report in SF at RFC 11149 (01/24/90) and 

SF version is unsigned. Supp. Report in PRF at 162298 has different approval 

date (01/12/90) than the same Supp Report in SF at RFC at 11151 and SF 

verision is unsigned. Photos at 11167-69;

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 141 of 433 PageID #:15562
" HN*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

PP GIOILM HPPG  .. 2)$")  .  .

HHKIG6HHKGP6HHKGN6HHJIK;

HHJIL6HHJHP6HHIOJ6HHINM6

HHIOH6HHJHH;HHJHO6HHIOK;HHJGP6

HHJIH;HHJIJ6HHINH;HHINI6HHIJG;HHIJI6

HHIKI;HHIKJ6HHILG;HHILH6HHINJ;

HHINK * :* : .

HHKIG6HHKGP6HHKGN6HHJIK;HHJIL6

HHJHP6HHIOJ6HHINM6HHIOH

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HGG GLGHJJ 1990 )- -*2) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHGH GLJGGG HPPG $ -- #*)  .  . HHLIK6HHLIM6HHLLN * :* : . HHLLN

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HGI HHKIOG 1990 -$)($/# No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHGJ HJJMJN HPPG '' )#$//$)"/*)

 .>
)1 ./$"/$1 

!$' $)*(+' / ?  . HHPGK;HHPGL6HHOOK;HHOON6HHOPG ::::::::

HGK HMINOI HPPG *(.$ 1 .  .  . HIGMJ6HHPLL;HHPMM * :* : . HIGMJ

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HGL HNMNPM HPPG 4-  $''$(.  .  . HIGPO6HIGNI;HIGNM6HIGOG;HIGOI * :* :* :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HGM HPIIHK 1990 !- ) '#*- No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHGN IGHIMJ 1990 # *) !! -.*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHGO IGJJJK HPPG 1$ '"*

 .60/$/$.

$)*(+' / ::::::::::

HGP IJNLIP 1990  "$)'  .0. No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 142 of 433 PageID #:15563
" HO*!IO

Records Division Number Year Defendant(s)

Identifying Information

PP GIOILM HPPG  .. 2)$")

HGG GLGHJJ 1990 )- -*2)HGH GLJGGG HPPG $ -- #*) HGI HHKIOG 1990 -$)($/#HGJ HJJMJN HPPG '' )#$//$)"/*)HGK HMINOI HPPG *(.$ 1 .HGL HNMNPM HPPG 4-  $''$(.HGM HPIIHK 1990 !- ) '#*-HGN IGHIMJ 1990 # *) !! -.*)HGO IGJJJK HPPG 1$ '"*HGP IJNLIP 1990  "$)'  .0.

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . HHINN;HHINP *

J0++' ( )/-4 +*-/.6. 1 -'.6

.0+* ).6! '*)4($)0/ .# /  .

HHINL;HHINM6

HHIOH6HHIOJ6

HHJHP6HHJIK;HHJIL6

HHJKJ6HHKGN6

HHKGP6HHKHJ6

HHKIG * : .  .  .

Medical Examiner's Report at 11224-11228; GPR/Handwritten Notes: 11276, 

11281, 11283, 11325, 11341-11347, 11350, 11389, 11406-09, 11416-28, 11463-

64, 11475, 11477, 11479-85, 11488, ; Arrest Report at 11282, 11372, 11403, 

11414-15, 11486; Photos at 11284-11310, 11313,11316-18, 11321-11323, Phone 

Message for detective at 11324, Request for Identification Photos at RFC 11311, 

11314; Fingerprint Report at 11330, 11392 ; Release of Vehicle at 11334; Motor 

Vehicle Inventory at 11348; Tow Report at RFC 11351, 11467, Request for 

Analysis at RFC 011354, Hold-over Request at RFC 11365, 11412, 11458, 

11468, Property Inventory at 11366, 68, 69, 71, 93-94, 11471, 73, 89, 91, 93, 94 

; Evidence Report at 11373-76, 11459, 11461; 11465 Polygraph Results at 

11385; Material Submitted for the Daily Bulletin at 11410, Lab Report at 11501-

02

 . HHMGJ *

L
)1 )/*-4 +*-/.6I0++' ( )/-4 +*-/.

>))*// ''2#$#*) .?6*./(*-/ (- +*-/6/4+ 

.// ( )/*!/#  ! ))/6 ,0 ./!*-

$)" -+-$)/*(+-$.*)6 '*)4$)0/ # /6

+*..$'4J	)2-$// ))*/ .60+* ).  .

HHMJG6HHMJL6

HHMNJ * : . *  .

Medical Examiner Report at RFC 11573-76, Toxicology 11577; Victim's I.D. 

11605-08

 . HHLIM *

0+* )6H0++' ( )/-4 +*-/>+*..$'40. 

*! /#?60/*+.4- +*-/6+*..$'4I.# /.*!

#)2-$// ))*/ .  . HHLKM6HHLLN * : .  .  . Medical Examiner Report at RFC 11507-10; Toxicology at RFC 11511

 . HHMNO *

-$(  ) -* ..$)" +*-/6*2  #$' 

!*-(60. *! /#0++' ( )/-4 +*-/6

*./(*-/ (- +*-/6*;-*( (*;- ,0 .//*

#*'$)1 )/*-$ +-*+ -/46'$& '4''N	)2-$// (

)*/ .6+#*/*.*!- ..**&6*+4*!1$/$(A.

-$1 -'$ ). 6*+4*!- ./0-)/0.$) ..-6

0+* ).  .

HHMPO6HHNGG6

HHNGI6HHNMJ6

HHNML6HHOIH6

HHOIO  . HHMON  .  .  .

Medical Examiner Report at RFC 11839-42; Property Inventory at RFC 11720, 

11738, 11740, 11742, 44, 45, 47, 61; Unsigned Report in street file at RFC 

11723 and signed version in PRF at RFC 162465; Arrest Report at RFC 11731; 

GPR/Handwritten Notes: RFC 11697-11703, 11756-60, 62-65; Statement of 

Defendant at 11704-06; Statement of Witness Arron Thomas at RFC 11707-10; 

Car Photos at RFC 11771; Vehicle Disposition Report at RFC 11772; Address 

Book Entries at RFC 11776-11820; Phone Message from Mrs. Ortega at RFC 

11821; Photos at 11822; Victim Drivers License at 11824-25; Message from 

eyewitness Latonya Moore at RFC 11828; Photos at 11829-30;

* :::* :* : .  .  . Medical Examiner Report at RFC 11877-80; . HHPLJ *

I! '*)4($)0/ .# /.6-$($)'#$./*-$ .60/*+.4

- +*-/6// A.//*-) 4.0+* )6''+#*/*.  . HIGMG;HIGMK * : . *  .

GPRs/Handwritten Notes at RFC 12016, 12056-12064; Property Inventory at 

RFC 12042-53; Letter from Optometrist re physical evidence at RFC 12009; Lab 

Reports at RFC 12007-08; Medical Examiner's Report at RFC 11999-12005; 

Toxicology Report at RFC 12006; Arrest Report at RFC 11988, 11911; Statement 

of Witness Isarael Roman at RFC 11986-87; Statement of Witness Getulio 

Roman at RFC 11984-85; Statement of Witness Denise Pruitt at RFC 11981-83; 

Photos at RFC 11955-11966;

* ::: . HIHGJ6HIHIK * : .  .  .

Medical Examiner's Report at RFC 12072-75; Toxicology Report at RFC 12076; 

Arrest Report at RFC 12136; Property Inventory at RFC 12139, 12142-49; 

Statement of Witness Joethel Griffin at RFC 12131-32; GPRs/Handwritten Notes 

at RFC 12108-09, 12120-24; Arrest Records for person arrested with victim 

recently at RFC 12110-11, ; Stop Order/Missing Person Order re: Person 

Unidentified as wtiness/suspect at RFC 12103-04; Reports Regarding Victims 

Recent Arrest on weapons violations at RFC 12105-07;

 . HIHMJ  . : .

HIHMO6HIHON6

HIHOP6HIHPL6 * : .  .  .

GPRs/Handwritten Notes: RFC 12168, 12187-92, 12195; Property Inventory at 

RFC 12199-12205; Handwritten Line-Up Report at RFC 12186; Statement of 

Witness Ancermo Paredes at RFC 12178-79

 . HIIHI;HIIHJ *

H0++' ( )/' +*-/>)*/' -2#$#*) ?6/*+

- -6-$( 
 +*-/6 '*)4$)0/ # /6H


)1 )/*-4 +*-/6I ) -'!! ). .  +*-/.6

''+#*/*.>(0".#*/.;0)' -*!2#*(?  .

HIIKH;HIIKI6HIJHI;

HIJHK6HIJHL6

HIJHO;HIJHP * : . *  .

Investigative File Inventory at RFC12212-13; Lineup photographs at RFC12215-

22; Stop Order at RFC12223-24; Criminal history at RFC12225; Release of 

person in custody at RFC12227; Portion of Medical Exminer Report at 

RFC12230. 12239; Request to hold prisoner at RFC12240; Handwritten notes at 

RFC12241-42; Property Inventory at RFC12243; Arrest Report at RFC12244; 

Property Inventory at RFC12261-68; Release of Person in custody at 

RFC12269; Criminal Histories at RFC12270-73, 12276-82; Request to hold 

prisoner at RFC12283; Arrest Report at RFC12284; Criminal histories at 

RFC12290-94; Arrest Information at RFC12295; Consent to search form at 

RFC12296; Request to hold prisoner at RFC12297; Handwritten arrest report at 

RFC12298; Leads inquiry with handwritten notes at RFC12299; Vehicle tow 

report at RFC12300; Property Inventory at RFC12301-10; Hanwritten notes and 

GPRs at RFC12312-21;

 . HIJMN *

=-$( 
9 +*-/

=-$(  ) -*9 +*-/

=1$ )  +*-/

=-*+ -/4
)1 )/*-$ .

=*./(*-/ (

=0++' ( )/' +*-/

=	)2-$// ))*/ .  .

=HIJPG

=HIKHL  .

=HIKHN

=HIKHP  . *  .

Medical Examiner report at RFC12334-38; Toxicology report RFC1239; Medical 

Examiner report at RFC12340-44; Toxicology report at 12345; Investigative File 

Inventory at RFC12367; Criminal histories at RFC12384-89; handwritten note at 

RFC12390; Criminal histories at RFC12391-92; Handwritten statement of 

witnesses at RFC12392-97; Property Inventory at RFC12398-408; Arrest Report 

at RFC12414; Handwritten note at RFC12415; Firearms use report at 

RFC12416, RFC12418; Memo about shots fired by police at RFC12417, 12419; 

Officer's battery report at RFC12420-21; Handwritten GPRs at RFC12422-34;

 . HIKJO;HIKJP * J	)2-$// )*/ .>))*// ''2#$#*) .?  .

HIKML6HILGG;

HILGI6HILHO6

HILIG6HILIN;HILIO * : .  .  .

Arrest Report at RFC12442; Handwritten GPR at RFC12445l; Criminal History at

RFC12457-62; Stop Order at RFC12463; Daily Bulletin at RFC12464; 

Handwritten GPRs at RFC12465-55; Handwritten line up report at RFC12470, 

12474-75; Property Inventory at RFC12478-80; Criminal History at RFC12483; 

Daily Bulletin submission at RFC12484; Stop Order at RFC12489-92; Criminal 

histories at RFC12497-99; handwritten GPR at RFC12500-02; Request for 

Fingerprint Comparison at RFC12503; handwritten GPR at RFC12518-25; Major 

Crimes Worksheet at RFC12526; Handwritten notes at RFC12527-28;

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 143 of 433 PageID #:15564
" HP*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

HHG IMIIOL HPPG

*. *)/) 5

*.  5  .  .

HIMKN6HIMKM6HIMKO6HINIL6

HIMKG;HIMKH6HIMKK * : . HIMKN  . HIMKM6HIMKO6HINIL

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HHH IMNKLG HPPG $(*/#4
 

 .>
)1 ./$"/$1 

!$' $)*(+' / ?  .

HINKO;HINKP7HINKI;HINKL7HIOJG7

HINNI;HINNL * :* :* :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HHI JMJHOH 1990

)/*$) - )6-- ''*) .6

	*. -$) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

HHJ KHJMGO 1990  ))$.$./ No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHHK KHKHLG 1990 *. *'*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHHL KNLPHG HPPG $-*$-)  .  . HJHHM;HJHHN * :* :* :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HHM LHJHIP 1990 '1$).#$)"/*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A77= ;7=>=; 7??6 ! !$$ ! % %

3799?62799?7

379;66

37997<2799>7

3799>92799>:

3799>;

3799?8

3799>?

379:?? ! 0% 3799?62799?7 % 379;66

01!!1$!


!% 


 (%&&(/ 0

77> ;7=>=; 7??6 ( 
!$

%-'&&%

 !"& 0000000000

HHP LOHOJM HPPG (0 '*$).*)  .  .

HJLGI;GL7HJLGM;GP7HJLHG7HJLHH7HJLHI7

HJLHJ7HJLHK7HJLHL;II7HJLLH7HJLLI7HJLLJ;LK7

HJLLL;LM7HJLLN7HJLLO7HJLPICPK7HJMHK7

HJMIG7HJMJP7HJMKN7HJMKO7HJMKP;LI7HJMLP7

HJMMG;NH * :* : . HJLLI7HJMIG7HJMKP;HJMLI  . HJMKO

HIG LPIJIK HPPG

( .0-) //

' )$'' -  .  .

RFC13673; • RFC13674; • RFC13675; • 

RFC13693-13696; • RFC13682-13684 * :* :* :

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :

HIH GILOJK 1991 ' #$''$+. No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHII GILPLG 1991 *#)0''$1) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 144 of 433 PageID #:15565
" IG*!IO

Records Division Number Year Defendant(s)

Identifying Information

HHG IMIIOL HPPG

*. *)/) 5

*.  5

HHH IMNKLG HPPG $(*/#4
 HHI JMJHOH 1990

)/*$) - )6-- ''*) .6

	*. -$)

HHJ KHJMGO 1990  ))$.$./HHK KHKHLG 1990 *. *'*)HHL KNLPHG HPPG $-*$-)HHM LHJHIP 1990 '1$).#$)"/*)77= ;7=>=; 7??6 ! !$$ !77> ;7=>=; 7??6 ( 
!$HHP LOHOJM HPPG (0 '*$).*)HIG LPIJIK HPPG

( .0-) //

' )$'' -

HIH GILOJK 1991 ' #$''$+.HII GILPLG 1991 *#)0''$1)

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . HIMIJ;HIMIK *

I$)1 )/*-4- +*-/.60/*+.4- +*-/6'- +*-/;

!$- -( 1$ )  .

HIMKM6HIMKO6

HINIL;HININ * : .  .  .

Medical Examiner's report at RFC12582-86;Toxicology Report at RFC12587; 

Criminal History of suspect at RFC12630-31; Criminal history of suspect at 

RFC12640-41; Arrest report at RFC12642; Request for identification records at 

RFC12643; Handwritten line up report at RFC12644; Identification Procedural 

Control at RFC12645; handwritten notes from lineup at RFC12646; Handwritten 

GPRs at RFC12647-48; Stop Order Cancellation at RFC12651; FBI and Illinois 

State criminal record of suspects at RFC12654-71; Request for Identification 

records at RFC12672; Property Inventory at RFC12673-78; Arrest Report at 

RFC12680; Arrest information at RFC12694; Handwritten GPRs at RFC12695-

96; Stop Order at RFC12697; Material for use in Daily bulletin at RFC12698; 

Criminal history of suspect at RFC12699-700; Request for identification records 

at RFC12701; Property Inventory at RFC12705-09; Arrest Report at RFC12711; 

handwritten GPRs at RFC12721-22, RFC12724-27; Criminal record of victim at 

RFC12732-33; Message betwen detectives at RFC12735;

 . HINNH *

0++' ( )/-4 +*-/;0. *! /# +*-/6L

+" .*!.>J+" .2 - *0)/ !*-?  . HIOHO * : / 6)**(+-$.*) :::

 . HIONP *

I-- ./ +*-/.6-$($)'	$./*-46 ! ))/

// ( )/6*./(*-/ (- +*-/6L	)2-$// )

)*/ .6#*/*.;(0".#*/.>0)' -*!2#*(?  .

HIPGG6HIPHO6

HIPKM;HIPKO6HIPLL * : / 6)**(+-$.*) :::

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.$)$/ ::::::: . * * None (just court attendance reports)

 . HJGJJ;HJGJK *

-$( 
 +*-/6-$(  ) -* ..$)" +*-/6

*./(*-/ (- +*-/6I	)2-$// ))*/ .>))*/

/ ''2#$#*) .?60+* )  .

HJGMK;HJGMM6HJGPG;

HJGPI * : .  .  .

Medical Examiner's Report at RFC13007-10; Investigative File Control Sheet at 

RFC13035; Handwritten statements of potential alibi's at RFC13051-54; Arrest 

report at RFC13055; Criminal History Report at RFC 13056-58; Handwritten 

Line Up Report at RFC13059; Handwritten GPRs at RFC13063-64; Property 

Inventory at RFC13077-82, 13101-06; Handwritten Lineup report at RFC13089-

92; Criminal history of victim at RFC13093; Message between detectives at 

RFC13108

 . HJHHM;HJHHN *

// A.//*-) 4.0+* )6H+-*+ -/4$)1 )/*-4

.# /6H-- ./- +*-/6+*..$'4! 2.)

#)2-$// ))*/ .  .

HJHNK6HJHNN6

HJHIO6HJHHK;HJHHL * : .  .  .

Handwritten notes (13114, 13127); File inventory (different from the one in the 

PRF) (13116); Arrest Reports (13124, 13126, 13133, 13148); ASA notes (13123, 

13125, 13138-39); Written statement signed by defendant (13134-37); Line-up 

notes (13140); Request for ballistics comparison (13154); property inventory 

(13155-56, 13159-61, 13180-82) General progress Report/notes re witness 

interviews, undisclosed witnesses, descriptions (13172-77); documents re a car 

(13167, 13178)

*;!$' ++ -.

$)*(+' / .

/# - - *)'4

0++' ( )/-4

 +*-/.$)$/ ::::::: .  .  .

Medical Examiners Report (13198-13202; 13204-07); Toxicology Report (13203; 

13208)

% 3799>92799>: !

3!%&!$&0!*!!+"!$&

3%

3!+$&

3
$

3 $$%&
 !$&! $

3$ 	%&!$+$ &!'&%

3&& &

3'"! !$&$&%1

3'"" &"!$&% %

379:?>

379;66 ! 0&- !!"$%! 000

% 3799>92799>: !

3!%&!$&0!*!!+"!$&

3%

3!+$&

3
$

3 $$%&
 !$&! $

3$ 	%&!$+$ &!'&%

3&& &

3'"! !$&$&%1

3'"" &"!$&% %

379:?>

379;66 ! 0&- !!"$%! 000

 .

=HJLLJ;

HJLLK *

=N.*)$)1 )/*-4'$./6HK$)$)1 ./$"/$1 !$' 

=G	)2-$// )*/ .*)$)1 )/*-4'$./6N$)

$)1 ./$"/$1 !$'  .

=HJMGM=HJMKP=HJMLG=HJMLH=HJMLI  . HJMKO  / 6)**(+-$.*) :::

 . HJMNJ  . : . =HJNJG;HJNJI * : . *  .

Investigative file inventory (13673); Supplementary Report (13676-81); 

Supplementary Report (13685-87); Supplementary Report (13688-

89);Supplementary Report (13690-92) re arrest of Miller, property recovered, 

investigation, and Miller's confession; Supplementary Report 13693-96 re 

weapons, motives, vehicle in the offense, evidence, and investigation; Arrest 

Report (13697). Burnett's written confession (13704-07). Miller's written 

confession (13708-12). Felony Minutes Report (13713-14). Property Inventory 

Reports (13715-21). Evidence Reports re finger prints and photos (13723). 

Evidence report re line up (13724). General Progress Report/handwritten notes 

(13727-39). Police Report (13740).

* :::* :* :Redacted, no comparison N/A N/A N/A . =HJOKH *

=K0++' ( )/-4 +*-/.*)/# $)1 )/*-46HK$)

!$' >-*0"#'4I;J- +*-/.- 0+'$/ .?  . =HJONL * :Yes No Yes

Medical Examiner Report at RFC13809-13813, Investigative File Inventory at 

RFC13841; Arrest Reports at RFC13857-8; Property Inventory at RFC13861- 

13867; handwritten notes of Defendant's statement at 13869-72; Criminal history 

of a suspect at RFC13873-13874; Criminal hisotry of victim at RFC13884; 

Photograph of victim at RFC13888-89

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 145 of 433 PageID #:15566
" IH*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

HIJ GKPINI HPPH $#-*)) -  .  .

=
)1 )/*-4
$./8HJPJL

=	)2-$// )*/ .8HJOPH7HJPKN

=*0-/- -8HKGIO

=
)/ -.// 
 )/$!$/$*)
) 38HKHIJ;

HKHIN * :* : . =HJOPH7HJPKJ * :

HIK GLHNJK 1991 1$$1 - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHIL GLKJPM 1991  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHIM GMGKJK HPPH  ( /-$0.#*(.  .  .

=*0-/// ))  +*-/8HKKHM7HKKHP;

HKKJH7HKKJO

=. ..$")( )/'$+8HKKHN

=$.+*.$/$*) +*-/8HKKHO

=-*+ -/4
)1 )/*-4# /.8HKKNI;HKKNK

=// ( )/*! ( /-$0.#*(.8HKLHM;

HKLJG

=*0-/*/$!$/$*):2*-) ( -8HKKMP7

HKKNO;HKKNP

=-$( 
*-/*-4 +*-/8HKKNH

=0+* )8HKLML * :* :* :* :

HIN HIOGMN HPPH

* -/#$) 

( .0'+$//

 --4&*-  .  .

HKMKH;HKMKI7HKMKG7HKMLG7

HKNHI7HKNLO7HKNNG;HKNNK7HKNMO;

HKNMP7HKLNH;HKLNJ7HKLNK;HKLOJ7

HKMJJ;HKMJK7HKNLP;HKNMG7HKMKJ7

HKMKN7HKNMH7HKNMI7HKNMJ7

HKNMK;HKNML7HKNMN * :* : . HKMKG7HKMLG7HKNHI7HKNLO * :

HIO HIPLMP 1991 $(*/#4	 ./ - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHIP HKHOMG 1991  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJG HNLMML 1991  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJH HPGMIN 1991 $#-
9**2$) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJI IHOGHP 1991 *#))4(+ - No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 146 of 433 PageID #:15567
" II*!IO

Records Division Number Year Defendant(s)

Identifying Information

HIJ GKPINI HPPH $#-*)) -HIK GLHNJK 1991 1$$1 -HIL GLKJPM 1991  / HIM GMGKJK HPPH  ( /-$0.#*(.HIN HIOGMN HPPH

* -/#$) 

( .0'+$//

 --4&*-

HIO HIPLMP 1991 $(*/#4	 ./ -HIP HKHOMG 1991  / HJG HNLMML 1991  / HJH HPGMIN 1991 $#-
9**2$)HJI IHOGHP 1991 *#))4(+ -

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . =HJPJL *

=G*;-*( (*.*)
)1 )/*-4'$./6O$)

$)1 ./$"/$1 !$' 

=G0+* ).*)
)1 )/*-4'$./6J$)$)1 ./$"/$1 

!$'  .

=HJOPH=HJPKJ=HJPKN=HKGHO=HKGJH=HKGJJ=HKGOK  .

=HJPJO=HKGGI=HKGHK=HKGIG=HKGJI=HKGMK  / 6)**(+-$.*) :::

 . =HKILN * =G*)$)1 )/*-46J$)!$' * :* : / 6)**(+-$.*) N/A N/A N/A

 . =HKJOL *

=H*)$)1 )/*-46K$)!$' 

=G	)2-$// ))*/ .*)$)1 )/*-46K$)!$'  .

=HKJHO=HKJKL=HKJLJ=HKJNN  .

=HKJKJ=HKJLO  / 6)**(+-$.*) N/A N/A N/A

 .

=HKKLP;

HKKMG *

=G	)2-$// )*/ .*)$)1 )/*-4'$./6H$)

$)1 ./$"/$1 !$' 

=G0+* ).*)
)1 )/*-4'$./6J$)$)1 ./$"/$1 

!$'  . =HKLLI  . =HKKNN  / 6)**(+-$.*) :::

 . HKMKH;HKMKI *

= ,0 ./!*-)'4.$.:  $+/!*-3#$$/.

=0+* )!*-/- /!$' .<

=0+* ).!*-/- /!$' .<

=$59-

= '*)4$)0/ .<*-(HGH.

=*;-*( (*

=*)/-/' .<0/**0) /$*)# /

=	)2-$// )*/ .

=1$ )  +*-/.

= ) -'!! ). .  +*-/

=0++' ( )/' +*-/.  .

=HKNHI

=HKNLL

=HKNMH  . =HKMLN  . *  .

Medical Examiner Report at RFC14567-14570; Interview with person who was 

with victim earlier the day of the incident at RFC14637; Investigative File 

Inventory, at RFC14641-42; Request for crime lab analysis at RFC14644; 

Report of registered vehicle at RFC14651; Photographs at RFC14652-54; Copy 

of the "calling card" that claimed credit for killing victim at RFC14655; Note from 

Det. Halvorsen to Sgt. in Auto Pound Section at RFC14657; Vehicle Inventory 

Report at RFC14659; Property Inventory sheets at RFC14664-71; Arrest Report 

RFC14678; Criminal history of witness at RFC14679; handwritten statement of 

Defendant at RFC14680-83; handwritten statement of witness RFC14684-

14686; handwritten reports of witness at RFC14702; Criminal History of 3 

Defendants at RFC14709-11; Handwritten notes at RFC14712; Request for 

telephone call records of alternate suspect at RFC14723; Property Inventory at 

RFC14745-50; Handwritten GPR at RFC14751-55; Handwritten note at 

RFC14758; Arrest Report at RFC14759-60; General offense report at RFC14764-

65; Photographs at RFC14768-74.

 . =HKOHN *

=G0+* ).*)$)1 )/*-46I$)!$' 

=G	)2-$// ))*/ .*)$)1 )/*-46H$)!$'  . =HKOHP  . =HKOKK Yes No Yes

Medical Examiner Report at RFC14779-89; Toxicology Report at RFC14790; 

Handwritten notes on file folder at RFC14816; Investigative File Inventory at 

RFC14817; Arrest Report at RFC14821; Supplementary Report with handwritten 

notes at RFC14830; Request for phone records at RFC14844; Murder Case 

Investigative Checklist at RFC14845; Arrest Report at RFC14848; Handwritten 

arrest report at RFC14851; Property Inventory sheets at RFC14852-54, 

RFC14856-69; Records of suspects' release at RFC14872-73; Arrest report of 

initial suspects at RFC14880-81; GPR (handwritten) at RFC14882-88

* :::* : . =HKPGO  / 6)**(+-$.*) ::: . =HKPOL *

=K*)$)1 )/*-46HK$)!$' >.*( (4 

0+'$/ .?

=G
)1 )/*-4.# /.*)$)1 )/*-46K$)!$' >H(4

 0+'$/ ?

=G ) -'!! ). .  +*-/.*)$)1 )/*-46K$)

!$' * :* : / 6)**(+-$.*) :::

 .

=HLGMM;

HLGMN *

=G	)2-$// )*/ .*)$)1 )/*-46L$)!$' 

=G0+* ).*)$)1 )/*-46H$)!$'  .

=HLGNJ=HLHGL=HLHHK=HLHHM=HLHMM  .

=HLGNP=HLHGK=HLHGL Yes No Yes

Medical Examiner Report at RFC15025-28; Toxicology Report at RFC15029; 

Investigative File Inventory at RFC15066-67; Arrest Report at RFC15071; 

Handwritten notes at RFC15073; Stop Order Cancellation Request at 

RFC15074; Release of Person in custody report at RFC15075; Stop Order 

Cancellation Request at RFC15076; Arrest Report at RFC15077; Lineup Report 

with handwritten checkmarks by 3 people in lineup at RFC15090; Note from 

Detective to Firearms requesting comparison of weapons in this case and a 

separate homicide (negative results) at RFC15104-05; Defendant criminal 

history at RFC15109-10; Stop Order at RFC15111; Stop Order for alternate 

suspect at RFC15120; Arrest report at RFC15121-23; Criminal history of vicitm 

at RFC15124; Evidence Report at RFC15125-26; Summary of Firearms 

evidence at RFC15129; "Lost and Found Case Report" at RFC15132; Property 

Inventories at RFC15133-46; Handwritten GPRs at RFC15147-68; Copies of 

drawings/doodles? at RFC15170-72; Photographs at RFC15178-15193

 . =HLIGP *

=K0++' ( )/-4 +*-/.*)$)1 )/*-46HH$)!$' 

>I- +*-/.2 - 0+'$/ .?

=G*;-*( (*.*)$)1 )/*-46H$)!$' * : . =HLIHG Yes No Yes

Investigative File Inventory at RFC15209; Supplementary Report for related 

homicide at RFC15229-34; Interview notes from related homicide at RFC15235; 

Criminal history of suspect at RFC15236-37; General Offense Report for related 

homicide at RFC15238-39; Handwritten GPR notes at RFC15250-51; Pictures of 

suspect at RFC15253-55.

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 147 of 433 PageID #:15568
" IJ*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

HJJ ILHOGG 1991 
 *)$*)$'' No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJK INIGON HPPH  ( /-$0.*#).*)

 .60/$/$.

$)*(+' / ::::::::::

HJL JHGPML 1991 -- )-*.. No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJM JHNNLO 1991 0 ))# 5 No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJN JKIILM 1991 1$*'*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJO JKOLML 1991 $'.*) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHJP JNILGP 1991 )/#*)49*2 '' No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHKG KGIMKH 1991  /  No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHKH KNKOPK 1991 	--4 ) No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AHKI LIMOII HPPH $"0 '*--*//*  .  .

=*0-/// ))  +*-/8HMINN;HMIOI

=0+* )8HMJGO7HMJHG;HMJHH7

HMJHL;HMJHM

=*(+'$)!*-- '$($)-43($)/$*)8HMJIK

;HMJIL

=HGH.8HMJIM;HMJIN

=
$ ). '/ /$& - +' ( )/8HMJJL7

HMJJO

=.  +*-/8HMJOM

=	)2-$// )*/ .8HMJPL7HMJPN7

HMJPO;HMKGG

=( -$)/)-)/ -+-$.   $+/8HMKGH

=
 // -/*!!$ -$$*8HMINM

=*$' 0-$/4-8HMJPI;HMJPJ

= #$'  -#8HMJPK * :* : . =HMJPL7HMJPN7HMJPO;HMKGG

:;**;-*(

 (*.$)


)1 ./$"/$1 $' 9 :


	



HKJ GNNHPJ HPOL )" '$ ++ * ::::::::::HKK IJLJLH HPOL

 .0.	 -)) 56	$+*'$/*

*-- . * ::::::::::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 148 of 433 PageID #:15569
" IK*!IO

Records Division Number Year Defendant(s)

Identifying Information

HJJ ILHOGG 1991 
 *)$*)$''HJK INIGON HPPH  ( /-$0.*#).*)HJL JHGPML 1991 -- )-*..HJM JHNNLO 1991 0 ))# 5HJN JKIILM 1991 1$*'*)HJO JKOLML 1991 $'.*)HJP JNILGP 1991 )/#*)49*2 ''HKG KGIMKH 1991  / HKH KNKOPK 1991 	--4 )HKI LIMOII HPPH $"0 '*--*//*


	



HKJ GNNHPJ HPOL )" '$ ++HKK IJLJLH HPOL

 .0.	 -)) 56	$+*'$/*

*-- .

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . =HLILN *

=G	)2-$// ))*/ .*)$)1 )/*-46HI$)!$' 

=HG0++' ( )/-4 +*-/.*)$)1 )/*-46IM$)!$' 

>.*( (4 0+'$/ .?  .

=HLIMN;HLINH

=HLINK;HLINL

=HLIOG=HLIPO=HLJNJ=HLJNN=HLJOJ  .

=HLJHK=HLKIK Yes No Yes

Investigative File Inventory at RFC15257; Letter from Telephone company of suspect at RFC15259-61; Handwritten note (in Spanish) to suspect at RFC15262-64; Handwritten spanish letters to unkown persons RFC15265-69; Handwritten addresses and notes at RFC15270-71; Notice of suspect's immigration interview at RFC15272; Search of car registrations at RFC15273-74; Handwritten address of unidentified person at RFC15275; Insurance policy of suspect at RFC15276-77; Red light ticket at RFC15278-79; Handwritten notes at RFC15280; Mail, bills, tickets, tax documents, insurance, and immigration notices for suspect and wife at RFC15282-15301; Photos (and order forms for photos) at RFC15302-12; Medical Examiner's Report at RFC15338-44; Toxicology Report at RFC15345; Phone records at RFC15374-79; Letter to FBI requesting help in locating suspect at RFC15380-81; Notes of FBI investigation in Mexico at RFC15383-86; Photograph at RFC16417; handwritten statement of alternate suspect at RFC15418-20; Property Inventory sheets at RFC15421-22; Photographs at RFC15423; Request for phone records at 15424; GPR at RFC15425; Arrest Report and records at RFC15426-28; Release records at RFC15429; List of teams playing soccer day of incident at RFC15430-31; GPRs at RFC15432-34; Property inventory sheets at RFC15435-36, RFC15438-45;

* :::* :* : . *  .

Medical Examiner Report at R15448-51; Toxicology Report at RFC15452; Line up Report at RFC15470-71

 . =HLKOK *

=3(+' .*!
/ (.$..$)"!-*(
)1 )/*-4

=J.*)$)1 )/*-46HH$)!$'  .

=HLKOJ=HLKPP=HLLGJ  . =HLKOM Yes No Yes

Handwritten note re: ballistics at RFC15483; Investigative File Inventory at

RFC15484; Supplementary Report at 15487-89; Criminal history of eyewitness 

at RFC15495; GPR at RFC15496; Property Inventory at RFC15497; GPR at 

RFC15498; Handwritten notes at RFC15499, RFC15503; Arrest Report at 

RFC15514; Criminal History of eyewitness at RFC15515-19; Handwritten GPR 

re Lineup at RFC15521; GPRs at RFC15522-24; Property Inventory Sheets at 

RFC15530-32; Handwritten GPR at RFC15542-44; Major Crimes Worksheet at 

RFC15545; GPRs at RFC15546-48; Hand drawing of scene RFC15549; Arrest 

Report at RFC15550

 . =HLLON *

=H0++' ( )/-4 +*-/*)$)1 )/*-46HL$)!$' 

>.*( (4 0+'$/ .?  .

=HLLOM=HLMHG * :Yes No Yes

Medical Examiner Report at RFC15560-63; Toxicology Report at RFC15564; 

Investigative File Inventory at RFC15587; Photographs at RFC15589; Arrest 

Report at RFC15598; Property Inventory Sheets at RFC15605-06; Stop Order at 

RFC15607; Criminal history and photograph of suspect at RFC15608;

 . =HLMHP *

=M.*)$)1 )/*-46N$)!$' 

=G*0-/// ))  +*-/.*)$)1 )/*-46M$)!$'  .

=HLMMP=HLMNI * :Yes No Yes

Lineup Report at RFC15694-95; Medical Examiner Report at RFC15696-02; 

Toxicology Report at RFC15703; Investigative File Inventory at RFC15619; 

Investigative File Control at RFC15622; Arrest Report at RFC15628; Evidence 

Report at RFC15641; Property Inventory Sheet at RFC15643-48; Material 

Submitted for Use in the Daily Bulletin at RFC15649; Stop Order at RFC15650; 

Handwritten GPRs at 15654-56; Property Inventory Sheet at RFC15655-60;

 . =HLNKO *

=G.*)$)1 )/*-46I$)!$' 

=G0+* ).*)$)1 )/*-46J$)!$' * :* : / 6)**(+-$.*) N/A N/A N/A

 . =HLNOK *

=G0+* ).*)$)1 )/*-46I$)!$' 

=K0++' ( )/-4 +*-/.*)$)1 )/*-46IL$)!$' 

>.*( (4 0+'$/ .?  .

=HLNOJ=HLOGK=HLOIJ=HLOJI=HLOKI=HLOKM * :Yes No Yes

Supplemental Report documenting arrest at RFC15920-21; Line up report at

RFC15922-23; Medical Examiner's Report at RFC15942-45; Toxicology Report 

at RFC15946; Handwritten note at RFC14783; Investigative File Inventory at 

RFC15784; Criminal Hisotry Record at RFC15793-15803; Handwritten note at 

RFC15804, RFC15805; Property Inventory Sheets RFC15814-18; Stop Order at 

RFC15819; Property Inventory Sheets at RFC15820; Request for Evidence 

(Blood Vial) at RFC15821; Criminal History Report of witness/suspect at 

RFC15825; Handwritten GPR at RFC15830; Handwritten Note at RFC15832; 

Property Inventory Sheet at RFC15835-40; Handwritten GPR at RFC15844; 

Long list of names and telephone numbers on an "identification" label at 

RFC15852-59; RFC15861-64; Program from victim's funeral and obituary at 

RFC15865-68; Photograph of Banks at RFC15869; Picture of "Porter Luckett" at 

RFC15892-93.

 . =HLPNJ *

=J.*)$)1 )/*-46I$)!$' 

=G0+* ).*)$)1 )/*-46K$)!$' 

=I0++' ( )/-4- +*-/.*)
)1 )/*-46HG$)!$'  .

=HLPNO=HMGII * : / 6)**(+-$.*) :N/A N/A

 .

=HMHHN;

HMHHO * =G0+* ).*)$)1 )/*-46N$)!$'  .

=HMGJO=HMGLO=HMGMG=HMHHM=HMIMG  . =HMHPG Yes No Yes

Medical Examiner Report at RFC16065-68; Investigative File Inventory at

RFC16117-18; Request for Latent Fingerprint Comparison at RFC16126-29; 

Supp report with handwritten notation at RFC16145 (changes time of interview 

by 15 minutes); Court Reporter typed statements at RFC16153-84; Handwritten 

Statements at RFC16185-89; Note re: preservation of recovered money at 

RFC16190; Vehicle Tow Report at RFC16191; Arrest Reports at RFC16194-98; 

Criminal History Reports at RFC16199-16203; Property Inventory Sheets at 

RFC16204-13, RFC16235-42; Handwritten GPRs at RFC16245-52; Incident 

statement from private security firm/witnesses at RFC16253-58; Medical 

Examiner Case Report at RFC16259; Photographs of Defendants at RFC16261; 

Application for employment to company where robbery occurred at RFC16266-

27; Insurance policy for Defendant's Car at RFC16268-69; Photographs at 

RFC16270-72; Call Log at RFC16274

 . =HMJGM *

=G	)2-$// )*/ .*)$)1 )/*-4'$./6K$)

$)1 ./$"/$1 !$' 

=G0+* ).*)
)1 )/*-4'$./6L$)$)1 ./$"/$1 

!$'  .

=HMJMG7HMJMK7

HMJPL7HMJPN7

HMJPO;HMKGG * : . *  .

Medical Examiner Report at RFC16283-86; Pages 2-3 of arrest report at 

RFC16291-92; Investigative File Inventory at RFC16306; Criminal history report 

of unknown person at RFC16309; Arrest Report at RFC16329; Property 

Inventory Sheets at RFC16332-34; License Plate Sticker Replacement 

Application at RFC16335; Handwritten note at RFC16337; Criminal History of 

defendant at RFC16338-52; Handwritten GPRs at RFC16359-64; Property 

Inventory Sheets ta RFC16365-67, RFC16370-5; Evidence Report at 

RFC16378; Request for Evidence (Blood Vial) and for firearms analysis at 

RFC16380; Property Inventory Sheets at RFC16381-83; Photographs at 

RFC16389-91; Copy of Defendant's social security card at RFC16392-93; 

Vehicle Registration inquiry at RFC16394; Copy of envelope addressed to 

Defendant at RFC16395; Handwritten names and contact information at 

RFC16397; Copy of envelope addressed to Defendant and letter at RFC16398-

16400; Copy of receipt for sale of car to Defendant at RFC16401

* :::* :* :* :::

* :::* :* :* :::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 149 of 433 PageID #:15570
" IL*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

HKL JKGHGM HPOL  "$)*.. * ::::::::::HKM LGPNHO HPOL

0-$  -.*)6-) ''

 -.*) * ::::::::::

HKN 	GMKLGK HPOM

)$ '$''62-

*-' . * ::::::::::

HKO 	KIJJLH HPOM  --4& - * ::::::::::HKP 	KKJHOG HPOM 1$ -#*(. * ::::::::::HLG 	KONNML HPOM $-*'' * ::::::::::HLH 	LKLGMI HPOM )-'0(' 4 * ::::::::::HLI GMGLGH HPON )/*)$*-0%$''* * ::::::::::HLJ HLPNJH HPON

 --4-) //6	*2-

) ! - * ::::::::::

HLK IGPKLM HPON

1$0$)*) .6-0 

)-.6-*#).*) * ::::::::::

HLL IHLHHP HPON  --40&) - * ::::::::::HLM IIJOOL HPON

*)'A '6*. +#

 *--* * ::::::::::

HLN JMHOMN HPON * ::::::::::HLO JOKHNN HPON  /  * ::::::::::HLP KJOGKG HPON $#-0//*) * ::::::::::HMG GMGHOO HPOO  ))$.
 * ::::::::::HMH IOPIIK HPOO - )/$ #$''$+. * ::::::::::HMI KMMGJJ HPOO ( .-$.6-2$) 4- - * ::::::::::HMJ LJGPHN HPOO (*.'& - * ::::::::::HMK LLIPMG HPOO :* ::::::::::HML GIOLJJ HPOP :* ::::::::::HMM GOPJPM HPOP 1 '$**-$"0 5 * ::::::::::HMN HLIOIJ HPOP $' -/**- -* * ::::::::::HMO IMPGHJ HPOP *. +#$ -2 * ::::::::::HMP IOLNOH HPOP *)/#).#$)"/*) * ::::::::::HNG KNJJIG HPOP 4!*-*" -. * ::::::::::HNH LJHGPO HPOP

-*.*)5' 5C1$

)# 5 * ::::::::::

HNI LKHPLJ HPOP *#))4'*- . * ::::::::::HNJ LLMIMG HPOP  *-" 0-$ ' * ::::::::::HNK KIHNIL HPOP ($ 0).*) * ::::::::::HNL KNLPHG HPPG

$-*$-)6*. $1 -

C
0$../)  * ::::::::::

HNM KOLMNH HPPG '!- **#).*) * ::::::::::HNN MGJPJN HPPG ( .' /# - * ::::::::::HNO JINJHJ HPPH


.#()&.*)60-$0-) -6

2.2'$)" * ::::::::::

HNP GHLIJL HPPH -(	*''$)".2*-/# * ::::::::::HOG GLHMLP HPPH 0)*-/ . * ::::::::::HOH GPGIHM HPPH #-' .$1 -. * ::::::::::HOI GPMOJO HPPH $ -*2' 4 * ::::::::::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 150 of 433 PageID #:15571
" IM*!IO

Records Division Number Year Defendant(s)

Identifying Information

HKL JKGHGM HPOL  "$)*..HKM LGPNHO HPOL

0-$  -.*)6-) ''

 -.*)

HKN 	GMKLGK HPOM

)$ '$''62-

*-' .

HKO 	KIJJLH HPOM  --4& -HKP 	KKJHOG HPOM 1$ -#*(.HLG 	KONNML HPOM $-*''HLH 	LKLGMI HPOM )-'0(' 4HLI GMGLGH HPON )/*)$*-0%$''*HLJ HLPNJH HPON

 --4-) //6	*2-

) ! -

HLK IGPKLM HPON

1$0$)*) .6-0 

)-.6-*#).*)

HLL IHLHHP HPON  --40&) -HLM IIJOOL HPON

*)'A '6*. +#

 *--*

HLN JMHOMN HPONHLO JOKHNN HPON  / HLP KJOGKG HPON $#-0//*)HMG GMGHOO HPOO  ))$.
 HMH IOPIIK HPOO - )/$ #$''$+.HMI KMMGJJ HPOO ( .-$.6-2$) 4- -HMJ LJGPHN HPOO (*.'& -HMK LLIPMG HPOO :HML GIOLJJ HPOP :HMM GOPJPM HPOP 1 '$**-$"0 5HMN HLIOIJ HPOP $' -/**- -*HMO IMPGHJ HPOP *. +#$ -2HMP IOLNOH HPOP *)/#).#$)"/*)HNG KNJJIG HPOP 4!*-*" -.HNH LJHGPO HPOP

-*.*)5' 5C1$

)# 5

HNI LKHPLJ HPOP *#))4'*- .HNJ LLMIMG HPOP  *-" 0-$ 'HNK KIHNIL HPOP ($ 0).*)HNL KNLPHG HPPG

$-*$-)6*. $1 -

C
0$../) 

HNM KOLMNH HPPG '!- **#).*)HNN MGJPJN HPPG ( .' /# -HNO JINJHJ HPPH


.#()&.*)60-$0-) -6

2.2'$)"

HNP GHLIJL HPPH -(	*''$)".2*-/#HOG GLHMLP HPPH 0)*-/ .HOH GPGIHM HPPH #-' .$1 -.HOI GPMOJO HPPH $ -*2' 4

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

* :::* :* :* :::* :::* :* :* :::* :::* :* :* :::* :::* :* :* :::* :::* :* :* :::* :::* :* :* :::* :::* :* :* ::: . GIGMNN * $/$(-$1 -.
$ ). 6
 .+*). . * :* :* :::* :::* :* :* :::* :::* :* :* :::* :::* :* :* ::: . GIGPII;GIGPIK * 0+* ).6- '$($)-4$- 1$ )  +*-/ * :* :* :::* ::: . GIHGLH6GIHGMG;GIHGMH  . GIHGMP;GIHGNI * :::* :::* :* :* ::: .;2$/#)

$)*-- /D GIHHKJ;KK

:;
)1 )/*-4

- '/ ./*

$!! - )/. 9 : . GIHJLN7GIHJMI

 .;2$/#)

$)*-- /D GIHIJH * :::

 . GIHKGI;GJ *

0"#*/.6*'. 3 +/$*)''4' - + )

 +*-/6H/*;!-*(( (*'$./ 6I$)!$'  . GIHJPM  . GIHKJI7GIHKPJ * :::

 . GIHKPO;LGG *

	*.+$/'$5/$*).  +*-/6-*+ -/4
)1 )/*-$ .

# /.6
 +*-/.  . GIHLOK7GIHLOP * :* :::

* ::: . GIHNHI7GIHNKN * :* :::* :::* :* :* :::* :::* :* :* :::* :::* :* :* :::* ::: . GIHPJL  . GIHPKJ7GIHPLG * ::: . GIHPMK *

 +*-/*!*./(*-/ (3(699*4#-/6/*+

- -+-$)/*0/61$ )  +*-/6-*+ -/4


)1 )/*-4# /.6#*/*. * :* :* :::

* :::* :* :* ::: . GIIGOH *

*0-/// ))  +*-/.6
)19$' *)/-*'6

-$($)'	$./*-4# /.6-*+ -/4
)1 )/*-4# /.  . GIIHIM;IP * :* :::

 . GIIIKH *

*0-/// ))  +*-/.60+* )6*(+'$)/

!*-- '$($)-43($)/$*)6	)2-$// )

// ( )/>*" -.?  .

GIIIKI7GIIIMJ7

GIIJGO7GIIJHJ * :* :::

* :::* :* :* ::: . GIIJML;MM *


)19$' *)/-*'6$. ( )*-. +-$)/*0/6

0+* )6-$(  ) -* ..$)" +*-/6 ,0 ./

!*-
 )/$!$/$*) *--.  .

GIIKIG;II7GIIKKI7

GIIKKN;KO7GIIKLI * :* :::

* :::* :* :* ::: . GIIKPO *

99*''*2;0+
)1 ./$"/$*) +*-/6*1$)"*!

-- ./  +*-/6 * :* :* :::

* :::* :* :* :::* :::* :* :* ::: . GIINMO *

 ,0 ./!*-
 )/$!$/$*)#*/*-60"#*/.6

&$)"*(+)40.$) ..-.6 ,0 ./!*-

 (+*--4 ' . *!
)(/ 6-)

-$1 -.
$ ). 6-$(  ) -* ..$)" +*-/.6

-*+ -/4
)1 )/*-4# /.6.6#)2-$// )

)*/ .  . GIIOKH7GIIOKJ * :* :::

 . GIIOKL;KM *

*0-/// ))  +*-/.6 +*-/*!*./(*-/ (

3(6-$(  ) -* ..$)" +*-/6-*+ -/4


)1 )/*-4# /60+* ).6	)2-$// )*/ .  . GIIPMM * :* :::

 . GIIPNJ;NK *


)19$' *)/-*'6*;-*(6-$(  ) -* ..$)"

 +*-/ * :* :* :::

 . GIJGJO;JP *

#*/*.60"#*/6	)2-$// )*/ .6 ' +#*) 

*)/-*'
*"6
 // -/*
6 ,0 ./!*-)'4.$.  .

GIJGJJ;JK7GIJGJN7

GIJHJK7GIJHJM * :* :::

* ::: .

GIJIIM7GIJIIO7

GIJIJH7GIJIJL;JM7GIJIJO * :* :::

* ::: . GIJILJ;LK7GIJJKG * :* :::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 151 of 433 PageID #:15572
" IN*!IO

Records Division Number Year Defendant(s) Has a Criminal 

Defense Attorney 

File been 

Produced?*

Is there any 

investigative 

material 

missing from 

the Defense 

Attorney File

Bates numbers for missing material Does the Defense Attorney 

File contain an Inventory 

Sheet?

If Yes (i.e., Inventory in 

the defense attorney 

file), does it match the 

inventory in the 

Investigative File?

Are GPRs from 

the Investigative 

File missing from 

the Attorney 

File?

Bates numbers for missing GPRs Are Handwritten 

Notes from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing Handwritten Notes Are To-From 

Memos from the 

Investigative File 

missing from the 

Attorney File?

Bates numbers for missing To-From Memos

Criminal Defense Attorney File Comparison

Items in the Investigative File Missing from the Criminal Defense File Identifying Information

HOJ HHOHJJ HPPH

 *-" 
0- )*C)$ '

*-$"0 5 * ::::::::::

HOK HIPLMP HPPH $(*/#4	 ./ - * ::::::::::HOL JKJKIO HPPH --$.*4 * ::::::::::HOM JLPLNP HPPH

 -)-'*1 -6-)&'*1 -6

-$)$'') * ::::::::::

HON KLIINI HPPH **'!* ) 5 * ::::::::::HOO KLKKJI HPPH '/$ '0/$./ * ::::::::::HOP KONLKK HPPH '$!!*--(./-*)" * ::::::::::HPG LGGOPJ HPPH # -*)--0/# -. * ::::::::::HPH LMGNJI HPPH *'!* -* * ::::::::::HPI MGHLMI HPPH 1$' 3) - * ::::::::::HPJ MHIOOL HPPH * -/(*. * ::::::::::HPK IKNMOH HPOP )/*)$*'*)* * ::::::::::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 152 of 433 PageID #:15573
" IO*!IO

Records Division Number Year Defendant(s)

Identifying Information

HOJ HHOHJJ HPPH

 *-" 
0- )*C)$ '

*-$"0 5

HOK HIPLMP HPPH $(*/#4	 ./ -HOL JKJKIO HPPH --$.*4HOM JLPLNP HPPH

 -)-'*1 -6-)&'*1 -6

-$)$'')

HON KLIINI HPPH **'!* ) 5HOO KLKKJI HPPH '/$ '0/$./HOP KONLKK HPPH '$!!*--(./-*)"HPG LGGOPJ HPPH # -*)--0/# -.HPH LMGNJI HPPH *'!* -*HPI MGHLMI HPPH 1$' 3) -HPJ MHIOOL HPPH * -/(*.HPK IKNMOH HPOP )/*)$*'*)*

Does the 

Investigative File 

include an 

inventory?

Bates Number for 

Inventory

Is the Inventory 

Complete?

Examples of Items Missing from Inventory Are there 

Handwritten 

Notes In the 

file not on 

GPRs?

Bates numbers for 

Handwritten Notes

Are there ToFrom Memos 

in the file not 

on GPRs?

Bates numbers for To-From 

Memos

Was a PRF produced? Is an Investigative File 

Inventory in the 

Permanent Retention File?

Was there anything in the 

Investigative file missing 

from the PRF?

Report type and Bates Number

Investigative File Information Permanent Retention File Comparison Items in the Investigative File Missing from the Criminal Defense File

 . GIJKNM *

*0-/// ))  +*-/.6
)/ -1$ 22$/#.*)

$1 - +*-/6 +*-/*!*./(*-/ (3(6

0+* ).6-$(  ) -* ..$)" +*-/  . GIJKNG7GIJLML;MM * :* :::

* ::: .

GIJMLM7GIJMMH;MI7

GIJMMN7GIJMMP;NG * :* :::

 . GIJNHH *


)19$' *)/-*'6 *-0((-46	)2-$// )

*/ .6 +*-/*!*./(*-/ (3($)/$*)6  . GIJNHK7GIJNPG * :* :::

 . GIJOGH *

$.+*.$/$*) +*-/.60+* ).6 ,0 ./!*-


 )/$!$/$*)#*/*.-.6/-).-$+/*!

.// ( )/ * :* :* :::

 . GIJPNO;NP *


)19$' *)/-*'6-- ./ +*-/ 1 *6

0+* ).6-$( 
 +*-/;$- -(.1$ ) 6

1$ )  +*-/6 ,0 ./!*-1$ ) 60"#*/.  . GIKGHJ7GIKGMI7GIKGMN * :* :::

 .

GIKHJN;JO7

GIKIHG>H+" 2-*)"

D? *


)1 ./$"/$1 ' -/.6
)1 ./$"/$1 ' -/.//0.6

-- ./ +*-/.6/*+- -*-) ''/$*) ,0 ./  .

GIKHKG7GIKHKI7

GIKHNL7GIKJGJ7GIKJHL * :* :::

* ::: . GIKKOL7GIKKPL * :* ::: . GIKLGN *

0+* )6*0-/// ))  +*-/.6 +*-/*!

*./(*-/ (3($)/$*)  . GIKLHP * :* :::

* :::* :* :* ::: . GIKLPO *


)19$' *)/-*'6-$($)'	$./*-4.# /6-$( 


*-/*-4 +*-/  . GIKMMJ;MM * :* :::

 . GIKOKG *

	)2-$// )*/ .6 #$' *2 +*-/6-*+ -/4


)1 )/*-4# /.6*'-*$#*/*.60"#*/.  .

GIKNGI7GIKNGM;GO7

GIKNHG7GIKNHN;HO7GIKNII;

IJ7GIKNKH7GIKNKK;KM7

GIKNPJ7GIKOIP7GIKOJH;JI7

GIKOJM;JO7GIKPGI  . GIKNKG * :::

 . GILMHG *

$'4%*-
)$ )/
*"66
)19$' *)/-*'6

#*/*"-+#.  .

GIKPHP;IG7GIKPIN;IP7

GIKPKI7GILHIH7GILMGO7

GILMHH7GILNHM7GILNIH * :* :::

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 153 of 433 PageID #:15574
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT H 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 154 of 433 PageID #:15575
1 

Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

Report of Plaintiff’s Expert – Michael D. Brasfield 

March 15, 2016 

Introduction 

The law firm of Loevy & Loevy, representing the plaintiff in this matter, contacted me in 

December of 2015 to review the Chicago Police Department’s (the “CPD”) policies and 

practices related to the creation, maintenance, storage, preservation, and disclosure of 

investigative materials in homicide cases, as concerning the Fields v. City of Chicago case 

discussed below, and more broadly. To that end, I reviewed documents regarding CPD’s 

policies and practices governing homicide investigative files. I also reviewed numerous files 

created by CPD detectives during homicide investigations and compared those files to defense 

attorneys’ files to assess whether relevant investigative material was disclosed or withheld. I 

have concluded, to a reasonable degree of professional certainty, that the CPD’s policies and 

practices related to the creation, maintenance, storage, preservation, and disclosure of 

investigative material deviated substantially from generally accepted police practices and 

resulted in the routine failure to disclose important investigative materials to criminal defendants. 

Police departments have long recognized the need to ensure that information and 

evidence collected during a criminal investigation is properly documented, stored, and ultimately 

disclosed for use in the criminal trials. The standard practice is relatively straightforward, and 

consists of a few key components: (a) requiring investigating officers to document the 

information they learn during the course of an investigation; (b) collecting, inventorying, and 

maintaining all of the investigative materials and information, in one central location; (c) 

applying policies or guidelines to ensure that the investigative material in the central file is 

disclosed to prosecutors and criminal defendants in response to formal requests for information; 

and (d) administering training around all of these issues to ensure the policies are followed. 

CPD did not comply with these standards, instead allowing detectives and other 

investigating officers to utilize multiple, parallel files for each investigation. The use of parallel 

files itself creates a significant risk that important investigative materials will not be disclosed, 

but that risk was exacerbated by the CPD’s failure to provide any training or policies regarding 

proper response to subpoenas and discovery requests. The result is predictable: a routine failure 

to disclose all relevant investigative materials to criminal defendants. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 155 of 433 PageID #:15576
2 

CPD’s problem of failing to turn over all relevant materials was brought to light by two 

federal cases in the early 1980s, but despite being acutely aware of the problem, CPD did little to 

address the practice. The policies it issued were a superficial attempt to resolve the problem and 

were deficient on their face – as they still allowed, and even required, multiple, parallel files to 

be created for each investigation. Moreover, CPD took almost no steps to train, supervise, or 

implement those policies. Finally, the policies did nothing to ensure that there was a system in 

place to properly respond to subpoenas and discovery requests. 

I have reviewed numerous Chicago homicide files, including criminal defense files and 

corresponding police investigative files. My review confirmed that because of, the deficient 

policies and widespread practices described above, criminal defendants were routinely denied 

substantive and relevant investigative materials related to their criminal cases, and that the 

written policies did little to alter the ingrained practice of keeping clandestine, parallel files. 

Finally, I reviewed the files that were withheld from Mr. Fields during his criminal trial and 

concluded that those files were withheld as a result of the same set of practices and policies (or 

lack thereof), and contained relevant and important investigative materials that should have been 

disclosed under standard police procedures. 

Table of Contents 

I. Standard police practices for maintaining and disclosing investigative files requires a 

single, comprehensive file 

II. Jones and Palmer litigation highlight Chicago’s “Street File” problem 

III. CPD personnel consistently use multiple files during a criminal investigation, and fail to 

disclose all relevant materials to criminal defendants. 

A. Multiple files are created for a single investigation, creating a serious risk that 

investigative materials are not disclosed. 

B. The CPD’s ad hoc response to subpoenas exacerbates the problem 

IV. Criminal defense files show that important investigative materials are regularly withheld 

from criminal defendants 

A. Background on the “basement files” 

B. Criminal defense files are missing pages from the basement files 

 

C. Issuing a subpoena does little to ensure disclosure of all relevant materials 

D. The missing pages contain important and relevant information that should have been 

disclosed to criminal defendants 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 156 of 433 PageID #:15577
3 

V. CPD’s policies after Jones and Palmer don’t ensure disclosure of all relevant 

investigative materials 

A. The policies are insufficient to remedy the “street files” problem 

B. The City failed to provide proper training and oversight to ensure compliance with its 

policies 

VI. The basement files show that the directives were not properly implemented 

A. The basement files from the 1983-1989 time period show that CPD’s policies were 

not followed 

1. Handwritten notes, not on general progress reports, are still routinely used 

2. To-from memos are still being used 

3. All relevant information in unofficial documents is not transcribed in official 

reports 

a. Review of Permanent Retention Files 

4. Inventories are missing or incomplete 

5. The basement files show that the “Investigative Files” did not serve as the 

central repository for investigative materials 

B. The basement files from the 1999-2006 show that the policies were not followed and 

that the problem has continued unabated into the 2000s 

C. The basement files confirm that there was no training, auditing, or oversight to ensure 

compliance with the policies 

VII. The failure to turn over files in Nathson Fields’ criminal case was a direct result of these 

practices and inadequate policies 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 157 of 433 PageID #:15578
4 

Expert Witness Qualifications 

I began my 40-year law enforcement career in 1968 as a patrol officer with the City of 

Mercer Island, Washington. In 1969, I joined the Seattle Police Department and served Seattle as 

a police officer, detective, sergeant, lieutenant, captain, major, and assistant chief. In addition to 

uniformed patrol, my investigative assignments as a detective included traffic, homicide 

investigation, burglary and theft, and vice (gambling and prostitution). As a sergeant, I served in 

patrol, the tactical squad, and internal investigations. As a lieutenant, I served as a watch 

commander in charge of 50 patrol officers, and later as the commander of the Washington State 

Criminal Justice Training Commission’s Basic Law Enforcement Academy for 2 years. This 

academy was responsible for developing and providing the initial law enforcement training for 

all commissioned law enforcement officers in Washington State. As a captain, I served as 

commander at both the downtown and north precincts, with responsibility for over 125 officers 

at each location. I also served as the commander of the Internal Investigations section of the 

Seattle Police Department for 2 years. I was the commander of the inspectional services division 

for 4 years. This division was responsible for developing, implementing, and monitoring 

departmental policies and procedures. This division was also responsible for developing and 

administering a budget in excess of $120 million. My last 5 years with the Seattle Police 

Department were served as assistant chief in command of the support services bureau. I was 

responsible for, and oversaw the activity of, nine uniquely different divisions including: internal 

investigations; training; personnel, intelligence; crime prevention; communications; records & 

evidence; data processing; and fiscal, property, & fleet management. In this capacity I routinely 

served as Seattle’s acting Chief of Police. I retired from that agency in 1995. 

I was selected by the City of Fort Lauderdale as its Police Chief in 1995. The 33-squaremile city has a full time resident population of 165,000. An estimated additional 60,000 “snow 

bird” residents return to second homes in the city during the 6-month winter season. Fort 

Lauderdale serves as the seat of government for the county of 1.5 million and is in the heart of a 

diverse tri-county (Dade, Broward, and Palm Beach) population of 4 million. As one of the 

premier tourist destinations in South Florida, over 12 million passengers come through the 

airport each year. The ocean port handles the second largest number of cruise ship sailings in the 

world. Fort Lauderdale serves as the governmental and business hub of the County. The Fort 

Lauderdale Police Department had a budget of $60 million and consisted of 500 sworn positions 

and 300 civilian positions. In 2000, the department received 600,000 calls for service, dispatched 

over 200,000 of those calls, made over 20,000 arrests, and issued 65,000 traffic citations. The 

Department is now nationally recognized as an innovative leader in the field of community 

policing and was one of only a handful of cities nationwide to be selected as a Community 

Policing Demonstration Site by the Department of Justice. I oversaw the operation of the only 

municipal jail in the state of Florida. Under my tenure, Fort Lauderdale became the first major 

agency to obtain accreditation. After over 6 years as the police chief of Fort Lauderdale, I retired 

from law enforcement a second time and returned to the Seattle area in the fall of 2001. 

After retiring as Chief of the Fort Lauderdale Police Department I returned to my 

retirement home in Washington State. About a year later I chose to run for, and was elected to, 

the office of Jefferson County Sheriff. I served in that capacity for over 6 years, and retired from 

active-duty law enforcement for the third (and final) time in the spring of 2009. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 158 of 433 PageID #:15579
5 

As both a Police Chief (6 years) and Sheriff (6 years), I have reviewed and approved 

policies and procedures of every kind. These included (but are not limited to) policies and 

procedures on criminal investigations, maintenance of police records, complaints against police 

officers, training, supervision, and discipline. I believe that of specific relevance to this case is 

that I was the chair of the Washington State Board on Law Enforcement Training, Standards, and 

Education. Through that position I regularly examined and reviewed issues and criteria that 

define standards and norms related to the practice and administration of law enforcement 

practices and operations. I also served 2 years as Commander of the Washington State Basic Law 

Enforcement Academy in Burien, Washington. In that position I was responsible for the 

administration of the training program provided to all Washington State Law Enforcement 

Officers. This was also my role as the Assistant Chief of the Seattle Police Department 

responsible for in-service and advanced training at the Academy over a subsequent 5-year 

period. Finally, for 6 years, I was the Commander of the Seattle Police Department’s 

Inspectional Services Division and responsible for the development, formulation and updating all 

police policy and procedures, including those involved in proper investigation procedures. 

As an independent consultant and sub-contractor, I have completed on-site visits to 

analyze 6 major U.S. city police agencies (Boston, Baltimore, Memphis, Oxnard, Cleveland & 

Seattle) to evaluate community policing in public housing. I have also served as a visiting 

management assessor for the cities of New Orleans (LA), Columbus (OR), Portland, (OR), San 

Francisco (CA), Bremerton (WA). Upon my return to Seattle in 2001, I provided contract 

professional services as a consultant and program director for the non-profit South Downtown 

Foundation. I had responsibility for administering several million dollars for improving public 

safety in the International District, SoDo, and Pioneer Square neighborhoods of Seattle. In this 

capacity I coordinated efforts with the City of Seattle, the Seattle Police Department, and various 

interest and civic groups in the area. 

As Sheriff of Jefferson County, I held a gubernatorial appointment to the Washington 

State Sentencing Guidelines Commission, serving as the only law enforcement official on this 

body of judicial, legislative, and executive-branch representatives. I also chaired the Washington 

State Criminal Justice Training Commission’s Board on Law Enforcement Training, Standards, 

and Education. Members of this board monitored and evaluated the training of police officers 

and participated in law enforcement decertification hearings. 

Over the last 40 years I have received extensive, specialized professional training in 

nearly all areas of law enforcement. There has been particular emphasis in the areas of training, 

internal investigations, criminal investigations, traffic homicide investigations, use of force, 

ethics, and police liability. I was awarded “life member” status with the International Association 

of Chiefs of Police in 2005. I was also awarded “life member” status with the Washington 

Association of Sheriffs and Police Chiefs in 2009. I am also a “life member” of the National 

Sheriffs Association. I have also been a member of the Washington State Sheriffs Association 

and served on the executive board of that organization. 

During my career, I have been required to investigate and/or review hundreds of internal 

investigations. I have supervised hundreds of officers, and have had to review their compliance 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 159 of 433 PageID #:15580
6 

with standards of behavior and integrity. As both a supervisor, and later a commander of internal 

investigations with the Seattle Police Department, I have reviewed and evaluated the 

thoroughness of well over hundreds of such investigations. As a police chief and as a sheriff, I 

have had the ultimate responsibility of passing judgment on such actions by law enforcement 

officers in situations ranging from traffic stops to fatal shootings. 

I have had the opportunity to conduct audits and systematic reviews of police 

departments throughout my career. As the commander (Major) of the Seattle Police 

Department’s Inspectional Services Division, I conducted both periodic performance inspections 

of various Departmental units, as well as special audits of high liability units, divisions and 

bureaus. 

As a police practices expert, I was part of a team that performed audits of police 

department service delivery provided by municipal agencies in 6 major U.S. cities (Boston, 

Baltimore, Memphis, Oxnard, Cleveland & Seattle). 

While working for the Seattle Police Department, I was part of a management assessment 

team for the cities of New Orleans (LA), Columbus (OH), Portland, (OR), San Francisco (CA), 

and Bremerton (WA). 

As an appointed board member of the Washington State Attorney General’s Homicide 

Investigation Tracking System (HITS), I participated in audits of ongoing and cold case 

homicide investigations throughout the State of Washington. 

In addition, when appointed as the Police Chief in Fort Lauderdale (FL) and when elected 

Sheriff of Jefferson County (WA), I initiated and oversaw the audits of high risk units and 

functions within those agencies. 

I received a Bachelor of Arts degree in Criminal Justice from the University of 

Washington in Seattle. I also am a graduate of the Senior Management Institute for Police 

(SMIP) of the Police Executive Research Forum. 

I have been retained in over 65 lawsuits as a police practices expert witness - 

approximately 66% for law enforcement defendants and 33% for civil rights plaintiffs or 

individuals claiming injury by law enforcement officers. These include federal district courts in 

Illinois, Pennsylvania, Florida, Washington State, Idaho, Oregon, Colorado, and Louisiana, and 

state courts in Washington, Alaska, California, Oregon, Arizona, Pennsylvania, Florida, 

Wyoming, Texas, and Kentucky. 

I. Standard Police Practices For Maintaining And Disclosing Investigative Files 

Requires A Single, Comprehensive File 

Every police department in the country must address how to properly document their 

criminal investigations. All information and evidence from an investigation must be properly 

collected, documented and preserved so that it can be disclosed to prosecutors and criminal 

defendants for use in criminal trials. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 160 of 433 PageID #:15581
7 

The standard police practice, across the country, is relatively straightforward: a lead 

detective is assigned to every major investigation, and that lead detective is in charge of 

compiling all investigative materials in a single centralized location. Although multiple 

detectives may work on an investigation, all information must be centralized and organized. 

These standards are in place to help police officers effectively solve crimes: they ensure that, 

during the investigation, information is not lost because it is dispersed among various detectives 

and that the information is organized and stored so that a supervisor or other detectives can 

locate and understand the evidence collected by their colleagues. This standard police practice 

also ensures that once charges are filed, everything that does exist from the investigation is 

complete, identifiable, inventoried, and maintained in its entirety in a central location. Whether it 

is referred to as an investigative file, a “murder book,” a completed investigation, an open 

investigation, or something else, everything should be in one package that can be located and 

produced – for whatever reason it is needed. 

Standard police practices also require the disclosure of all investigative material in the 

police file, whether centralized (standard, and preferable) or not. There should not be picking and 

choosing. Performing these disclosure requirement is not an informal practice; it is done pursuant 

to written policies and procedures, in conjunction with training on those policies and procedures, 

to ensure compliance to this crucial step in ensuring fair trials. As a practical matter, this 

disclosure for use in a criminal case usually occurs in one of two ways: either the police fulfill 

their obligations by disclosing their entire investigative file to the prosecutor (rather than picking 

and choosing which parts of a file to disclose), who in turn disclose it to the criminal defense 

attorney; or, in some cases, independently and as a safeguard, the criminal defendant or his 

counsel will subpoena the police investigative materials directly. In response to the subpoena, all 

investigative materials should be disclosed. 

It is also standard police practice to keep and catalogue every document or piece of 

information pertaining to an investigation. The police investigative role is to search for and 

document facts – all facts regardless of where those facts fit into some pre-conceived theory of 

the investigation. Not all facts, information, or individuals will necessarily enhance the 

prosecution of an identified suspect. Nonetheless, those facts have to be included in the 

investigation– to help prevent tendencies like tunnel vision, and also in fairness to the victims, 

the prosecutor, the defense, the court, and the jury. The judge will eventually rule on what is 

relevant and admissible. And investigators routinely offer explanatory information that puts that 

information in perspective, or explains why the detectives gave it little weight. But based on my 

experience, police officers are expected to, and are specifically trained on the importance of 

preserving all investigative materials and including those materials in a centralized location. 

Police departments typically emphasize this point because, in order to meet the needs of police 

agencies and the courts, case files must be maintained in a manner that make them secure but 

accessible, and the case contents should be arranged in an orderly and consistent manner. 

As a corollary, all of the information must be inventoried, indexed, or documented in 

such a manner as to be easily located and so that the content of the inventory is clearly 

understood. To that end, a copy of the investigative file inventory will typically be placed in an 

official police department file so that the department can maintain a single, accurate list of all 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 161 of 433 PageID #:15582
8 

available material, and that inventory is typically disclosed to prosecutors and criminal 

defendants so that they can ensure that they have everything. In this way, it serves not as a 

solution to the problem of ensuring that all investigative material is disclosed, but as a necessary 

backstop to try to prevent the possibility of non-disclosure despite the existence of other policies 

and procedures. 

My knowledge of these standards is based on my extensive experience with police 

practices, including my familiarity with the policies used by other police departments 

nationwide, as well as industry standards established by organization like the International 

Association of Chiefs of Police. These standards have also been documented in homicide guides 

and reference materials for decades. For a summary of these texts, please see Attachment E.

II. Jones and Palmer litigation highlight Chicago’s “Street File” problem 

In the early 1980s, two federal court cases highlighted the fact that the Chicago Police 

Department had no systems in place to ensure that investigative materials were collected 

centrally and disclosed during criminal cases, and in fact important materials were consistently 

withheld from criminal defendants. 

A. The George Jones Prosecution 

In 1981, twelve-year-old Sheila Pointer was raped and bludgeoned to death; and her 10-

year-old brother Purvy was beaten unconscious in their home.1

 George Jones – a senior at a 

nearby high school, who edited the school newspaper and was nicknamed “Bookworm” – was 

ultimately arrested and prosecuted for the crime. During the CPD investigation of the Pointer 

murder, detectives gathered evidence that undermined the witnesses who had implicated Jones, 

and which Jones could have used to help defend himself, but this information was placed “not in 

the police department's regular files but in its ‘street files.’ These were files that the police did 

not turn over to the state's attorney's office as they did with their regular investigative files.”2

After George Jones had been charged, a detective, Frank Laverty, who was investigating 

the case interviewed the victim’s brother, Purvy, who told Laverty that there were two assailants 

and both were wearing stocking masks. Laverty also documented other strong evidence that 

Jones was not the perpetrator. That information was also placed in the street file.3

 Laverty was 

told that, in light of these facts, the prosecution of Jones had been abandoned. However, in the 

spring of 1992, Detective Laverty read in the newspaper that George Jones was on trial for the 

Pointer murder.4

 Laverty went to his Commander to tell him that an innocent person was being 

prosecuted, but his Commander took no action. Laverty then went directly to Jones’ criminal 

defense attorney and told the attorney about the information in the street file. After the court 



1 Jones v. City of Chicago, 856 F.2d 985, 988 (7th Circuit 1988) 

2

 Ibid (at 988-991) 

3

 Ibid (at 990-91) 

4

 Ibid (at 991) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 162 of 433 PageID #:15583
9 

declared a mistrial, the State’s Attorney dropped all charges against Jones.5 

The United States Court of Appeals for the Seventh Circuit described the CPD’s reaction 

to these events as follows: 

Laverty should have been commended for his adherence to the principles of 

honesty, decency, and justice, instead the police department charged him with a 

disciplinary infraction for having failed to advise the state’s attorney that he 

planned to testify for the defense in George Jones’s criminal trial should that 

become necessary. He was also transferred out of the detective division, 

ostracized by his fellow officers, and assigned to a series of menial tasks 

culminating in the monitoring of police recruits giving urine samples. None of 

the defendants has been disciplined for misconduct in the arrest and prosecution 

of George Jones.6

After the charges against him were dismissed, Jones filed a civil lawsuit. He was awarded 

a substantial amount in damages for the violation of his rights. Notably, among other things, the 

jury found that the City was liable to Jones for its custom of maintaining “street files” that were 

withheld from the State’s Attorney and therefore unavailable to Jones and the rest of the criminal 

justice system.7

 The Seventh Circuit explained that the practice of “retaining records in 

clandestine files deliberately concealed from prosecutors and defense counsel cannot be 

tolerated.”8

B. The Palmer Litigation 

On April 16, 1982, shortly after Jones’ prosecution, a class of plaintiffs filed a lawsuit in 

federal court to prevent the use of street files.9

 The plaintiffs immediately moved for a temporary 

restraining order (TRO). A TRO issued on April 20, 1982, and amended on September 24, 1982, 

required the CPD to preserve all street files and documents formerly placed in street files.10 The 

TRO was amended because of allegations that detectives were continuing to keep investigative 

materials as their personal property and therefore not subject to CPD control.11

District Judge Milton Shadur oversaw the preliminary injunction hearing. Based on the 

evidence presented by the plaintiffs and by the City of Chicago, Judge Shadur found the 

following (among other things): 

• The CPD does not provide its detectives or other personnel with guidelines as to the 

extent to which “official reports” (which Judge Shadur defined as case reports, 



5

 Ibid. (at 991) 

6

 Ibid. (at 991-92) 

7

 Ibid. (at 995-96) 

8

 Ibid. (at 995). 

9 Palmer v. City of Chicago, No. 82 C 2349 

10 Ibid (at NF-L 005606-07) 

11 Ibid (NF-L 005607) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 163 of 433 PageID #:15584
10 

supplementary reports, closing reports, etc.) have to embody information in 

“unofficial reports” (defined as notes, witness interviews, worksheets, memoranda, 

etc.) In particular, Judge Shadur found that “Official Reports have sometimes been 

prepared from the perspective of what fits the preparer’s concept of the crime, so they 

omit information that – though highly relevant and sometimes exculpatory of the 

defendant charged with the offense – the preparer does not deem ‘pertinent.’”12

• The existence and use of unofficial reports is well known throughout CPD. Parallel 

files containing these reports are referred to as “street files,” “running files,” “office 

files” or “working files.” 

• Potentially relevant information contained among the CPD’s various investigative 

files and materials for a particular crime is not necessarily included in official reports. 

There has been and is no police rule, regulation, procedure, or practice that requires 

all relevant information to be placed in official reports or to be transmitted to the 

CPD’s Records Division for permanent retention.13 

• the CPD responds to requests for documents as follows: 

° In response to a subpoena, CPD produces only official reports maintained at 

Records Division along with photographs and lab reports. CPD does not 

produce unofficial reports maintained at the Area or unofficial reports in the 

possession of individual detectives.14

° In response to a defendant’s discovery motion, Assistant State’s Attorneys 

(ASAs) order official reports by phone. CPD Records Division employees 

respond to these requests by producing official reports and do not contact 

individual Areas or other units or divisions of the CPD for unofficial 

documents.15

Judge Shadur found that the exclusion of relevant information from official reports “was 

not random or infrequent.”16 In fact, by the City’s admission, there were hundreds street files in 

active use during the Palmer litigation itself. In granting the injunction, Judge Shadur found that 

the use of street files created a “grave risk” of non-disclosure of exculpatory information, 

including information that could be used to impeach witnesses. 

On appeal, the Seventh Circuit reversed Judge Shadur in part, although it did order the 

CPD to preserve and produce street files for those plaintiffs who had been convicted of 

felonies.17 It vacated the preliminary injunction in all other respects because the court found that 

the plaintiffs either lacked standing or should have asked for relief in the state courts. It did not 

revisit the factual findings that Judge Shadur made. 

III. CPD personnel routinely use multiple, parallel files during a criminal 

investigation, and fail to disclose all relevant materials to criminal defendants. 



12 Ibid (NF-L 005609-10) 

13 Ibid (NF-L 005612) 

14 Ibid (NF-L 005614) 

15 Ibid (NF-L 005614) 

16 Ibid (NF-L 005615) 

17 Palmer v. City of Chicago, 755 F.2d 560 (7th Cir. 1985); CPD Special Order 83-2A. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 164 of 433 PageID #:15585
11 

As the Jones and Palmer cases highlighted, the CPD has a long history of using multiple, 

parallel files during the course of a criminal investigation, which are frequently withheld from 

criminal defendants. 

A. Multiple Files Are Created For A Single Investigation, Creating A Serious Risk 

That Investigative Materials Are Not Disclosed. 

From at least 197718 to as late as 2006, the Chicago Police Department has maintained 

multiple, parallel files relating to a single investigation and has had no system in place to ensure 

that all important investigative materials from these multiple files are collected and provided to 

the prosecutors and criminal defendants. 

The only “centralized” repository of investigative information maintained by CPD is the 

“permanent retention file” maintained by the Records Division. But the CPD policy and practice 

is to only include the official reports in the permanent retention file.19 This practice of having an 

“official” file that does not include all of the investigative notes, documents, and materials 

deviates from standard police practice, which would have one single repository with all the 

information. 

Instead of utilizing the permanent retention file as the central repository of information, 

CPD practice is to use multiple, parallel files while an investigation is ongoing. These multiple, 

parallel files have been variously referred to at different times as “street files” “working files,” 

“running files,” “unit files,” “Area files,” or “investigative files,” among other terms. These files 

are used by detectives and other investigating officers, while an investigation was ongoing to 

gather relevant investigative materials; to communicate steps taken and steps to be taken in an 

investigation; and to record the personal opinions of the officers investigating a crime. The files 

contained notes (sometimes handwritten on scraps of paper), memos, reports, photographs, and 

various other forms of information about the case that were developed as the investigation 

unfolded. Among other things, information in these various, parallel files included details about 

the crime and the physical evidence, information about the observations or statements of 

witnesses, identification of potential leads and suspects, and items obtained from victims or 

witnesses (e.g., a victim’s telephone book or a witness’s telephone messages). The files also 

contained other criminal history information and police reports pertaining to other cases, which 

were utilized in suspect identification and elimination. 

 18 The City’s designated witness, in this and other cases involving the City’s 

practice regarding maintenance and production of investigative files, James K. Hickey, 

testified that the practice of using street files started at least as early as 1977, when he 

arrived at Area 1 homicide. Similarly, during hearings on the use of street files in 

Palmer v. City of Chicago, John Stibich, a former commanding officer in Area 4 

homicide, testified that during his time there, from December 1974 to December 1977, 

Area 4 homicide had a practice of using street files. Following Hickey’s sampling of 

the various violent crimes units in 1982, Hickey determined that each of the Areas used 

street files. 

19 Hickey Kluppelberg Deposition [2015] 22-23, 95-96 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 165 of 433 PageID #:15586
12 

Detectives working a case necessarily take notes during witness interviews and must 

communicate that information to other detectives. That is an inevitable and important part of an 

investigation. The problem with the Chicago Police Department’s practice is that these notes are 

stored across multiple files—both during and after an investigation—and are never consolidated 

into the official file which is permanently maintained by the CPD. Thus, even after an 

investigation concludes, there are still multiple files containing different sets of investigative 

materials scattered in various locations, and which are regularly withheld from criminal 

defendants. 

There are a variety of reasons that multiple, parallel files are created within the CPD 

environment: 

• Multiple detectives working on the same case, each take notes, resulting in multiple 

sets of investigative materials, but there is no formal place for detectives to keep these 

notes, and as a result they are kept on tables, coat racks, in cars, in filing cabinets, or 

desk drawers in the Areas and are never collected in a central repository.20 

• In 1980, the CPD was re-organized, and the Detective Division was split into six 

geographical areas (Areas One through Six) and two subject matters (Violent Crimes 

and Property Crimes).21 Detectives from different divisions or units of CPD often 

investigate a case together, but report to different supervisors, and work out of 

different units or Areas, resulting in multiple files kept at the different geographical 

locations throughout the City. 

• In addition to detectives, there are many others involved in investigating major crimes 

such as homicides, including patrol officers as well as specialized unit officers like 

Gang Crimes and Bomb & Arson. No set of policies or practices governed the 

investigative practices of these additional investigators or required them to coordinate 

with the Detective Division, resulting in the creation of yet more files, unknown to 

and uncoordinated by CPD. 

• There is no centralized log of the various parallel files created for each investigation, 

and thus no way to know how many files exist or where they are located. 

• Files that are kept in an Area may be moved during CPD re-organization or are 

relocated to a storage warehouse. If multiple files for the same homicide are stored at 

an Area, they are not necessarily stored or moved together, and there is no system in 

place, or documentation, for tracking the movement of these files. 22

• The documents in the files at the Area are never consolidated into the permanent, 

official files stored in CPD’s centralized Records Division. 

• Detectives also do not routinely not transcribe all information obtained during an 

investigation into an official report, resulting in different information maintained in 

the official and unofficial documents. 

• The permanent file, kept in the Records Division, therefore, does not contain all the 

relevant and important investigative materials. 



20 Palmer v. City of Chicago, 562 F. Supp. 1067, 1071 (N.D. Ill. 1983). 

21 James K. Hickey Deposition in Kluppelberg v. Burge at 64 (NF-L 001004). 

22 Loughran Deposition 43-44. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 166 of 433 PageID #:15587
13 

This practice of using of multiple, parallel files creates an unacceptable risks that 

information will not be discoverable in response to a subpoena and will, therefore, be withheld 

from prosecutors and defendants. Where detectives keep their own files, or files are kept at 

multiple areas or units throughout the City, there is no way for any detective or supervisor to 

know how many parallel files have been created for a particular case, or whether they have all 

been collected. This is why standard practice is to have a lead investigator responsible for 

keeping a single, known repository of information. 

B. The CPD’s Ad Hoc Response To Subpoenas Exacerbates The Problem 

 In Chicago, the risks created by using multiple files are exacerbated by the fact that the 

CPD Subpoena Service Unit, which is responsible for responding to requests for records, is 

untrained and lacks any policies governing how it responds to subpoenas and requests for files. 

According to Hickey, when a request for investigative documents is made to the Chicago 

Police Department, that request goes to the Records Division, Subpoena Service Unit.23 A 

sergeant was in charge of the Subpoena Service Unit, and that sergeant reported to the assistant 

director and director of the Records Division.24 It was the Record Division director’s 

responsibility to set policy at the Subpoena Service Unit.25

The Chicago Police Department had no written policy that Hickey was aware of dictating 

how the Subpoena Service Unit should search for documents responsive to a subpoena or request 

for records.26 In addition, there were no directives addressing “policies, safe checks, [or] 

procedures . . . to ensure that when a request came in either by a subpoena or by an informal 

request from and Assistant State’s Attorney . . . that all of the necessary information including 

exculpatory information was provided by the subpoena services unit in response to that 

request.”27

The subpoena service unit was staffed by non-sworn personnel with the title “clerk.”28 

There was no formal training of personnel assigned to respond to subpoenas.29 Whether all of 

the different units that worked on a given investigation were searched for documents responsive 

to a subpoena depended in large part on the discretion and experience of the personnel searching 

for the documents, such that a subpoena for all documents under a certain records number 



23 Hickey Kluppelberg Dep 358(NF-L 001299) 

24 Hickey, Rivera v. Guevara, et al., No. 12 C 4428, pages 146-47 (NF-L 000312-13) 

25 Ibid, pages 159-60 (NF-L 000316) 

26 Ibid, pages 36-37 (NF-L 000273-74); City of Chicago’s Amended Response to Plaintiff’s 

Seventeenth Set of Requests to Produce Documents to the City of Chicago, p.2-3 

27 Ibid, page160 (NF-L 000316) 

28 Ibid, pages 147-48 (NF-L 000313) 

29 Ibid, page 39 (NF-L 000274) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 167 of 433 PageID #:15588
14 

number30 would not necessarily result in the production of all documents corresponding to that 

particular investigation.31 Hickey described the Subpoena Service Unit’s effort to respond to 

document requests as an “art.”32 He acknowledged that it is possible in a case with multiple 

units working on the same investigation that the subpoena could only go to one of those units.33

All of this was true as well with respect to requests for documents made by the Cook 

County State’s Attorney’s Office to the Chicago Police Department.34 This system was in place 

before Mr. Fields’ conviction and continued in force until 2009.35 In fact, the City’s expert on 

the CPD’s policies in 2009 explained that, even if a subpoena is forwarded to an Area or unit, 

there is no system or procedure to follow up if the Area or unit fails to respond.36

This system, or lack thereof,37 for responding to requests for documents and producing 

investigative materials, including important investigative information, is deficient. Because there 

are multiple files in multiple locations pursuant to the special orders and CPD’s design, there is 

an acute need for policies, practices and training to ensure that all relevant information was 

produced to prosecutors and criminal defendants. The lack of such safeguards represents a 

significant departure from accepted police practices. 

IV. Criminal Defense Files Show That Important Investigative Materials Are 

Regularly Withheld From Criminal Defendants 

From a police practices perspective, criminal defense attorney files contain all of the 

documents disclosed and made available to the attorneys that provided counsel to defendant(s) in 

the homicide cases that I reviewed. By standard police policy and practice, criminal defendants 

should get everything that was available from the police investigation to aid the defendant in 

presenting his or her defense at trial. It would be a dangerous departure from standard police 

policies to permit a practice of picking through police files to select which investigative materials 

to turn over. 

As a practical matter, this disclosure of information usually occurs in one of two ways: 

either the police fulfill their obligations by disclosing their entire investigative file to the 

prosecutor (rather than picking and choosing which parts of a file to disclose), who in turn 

disclose it to the criminal defense attorney; or, in some cases, independently and as a safeguard, 



30 A Records Division number is a unique identifier assigned to a particular criminal 

investigation. The letters represent the year that the investigation began and investigations are 

assigned the numbers sequentially as they had. 

31 Ibid, pages 43-46 (NF-L 000275-76) 

32 Ibid, page 162 (NF-L 000316); Hickey Kluppelberg Deposition 362-63(NF-L 001303-04) 

33 Hickey Kluppelberg Deposition 362-63 (NF-L 001303-04) 

34 Hickey, Rivera, page 125(NF-L 000296); Loughran Deposition, page 50. 

35 Ibid, pages 151-53 (NF-L 000314); Loughran Deposition 14. 

36 Loughran Deposition 15. 

37 Hickey, Rivera, pages 36-37 (NF-L 000273-74); City of Chicago’s Amended Response to 

Plaintiff’s Seventeenth Set of Requests to Produce Documents to the City of Chicago, p.2-3. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 168 of 433 PageID #:15589
15 

the criminal defendant or his counsel will subpoena the police investigative materials directly, 

rather than relying exclusively on what was provided by the prosecutor. In response to the 

subpoena, all investigative materials should be disclosed. 

The basic principle is that a criminal defendant is not supposed to be tried in the dark. He 

is entitled to understand the full breadth of the evidence against him; and he is entitled to any 

evidence that may help him prove his innocence. As a matter of police practices, a well-trained 

detective would understand that information should be disclosed even if it is only supportive – 

but not conclusive - proof of innocence. As long as information known to the police or 

prosecution might contribute to doubt about the defendant’s guilt in the mind of a reasonable 

person, it is relevant and must be disclosed. 

Based on the criminal defense files reviewed in this case, as explained below, it is clear 

that these standard police practices are not followed in the Chicago Police Department, and as a 

result investigative materials that should be disclosed under normal police procedures are 

routinely withheld from criminal defendants. Moreover, these documents were withheld even 

where defendants issued subpoenas specifically requesting those documents. And finally, the 

material withheld was often relevant, exculpatory investigative information that should have 

been disclosed under generally accepted police practices. I discuss each conclusion in turn 

below. 

A. Background On The “Basement Files” 

In 2011, years after Mr. Fields’ criminal trials and multiple subpoenas by his trial and 

appellate attorneys for all files related to his case, the City of Chicago turned over during this 

civil case a new file to Mr. Fields for the first time. As discussed below, in Section VII, (pages 

39-44) that file consisted of more than 100 pages of documents related to the police investigation 

into the crimes of which Mr. Fields was convicted, and it contained numerous highly relevant 

pieces of evidence, including witness statements and a number of alternate suspects. 

Mr. Fields’ attorneys then investigated the filing cabinets where the new file was found. 

They discovered that it contained hundreds of homicide files containing investigative material, 

from multiple Areas of the CPD, spanning several decades (hereinafter, the “basement files”). 

Mr. Fields’ attorneys asked to investigate the other files in those cabinets, and they were given 

access to all of the “cleared” cases—that is, those where at least one individual had been charged 

with the homicide at issue—from 1979 through 2006. 

For the purposes of this report, I was asked to focus on files from two time periods: First, 

files concerning homicides committed between 1983 and 1989, the period of three years before 

and after Mr. Fields’ first criminal trial in 1986; and, second, files concerning homicides 

committed between 1999 and 2006, the set of basement files nearest in time to his 2009 re-trial. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 169 of 433 PageID #:15590
16 

Mr. Fields’ attorneys provided me with a spreadsheet that served as an index of basement 

files pertaining to those two time periods, which I reviewed and double-checked extensively. 

That spreadsheet is attached to this report as Attachment G.38 

The basement files came from multiple Areas throughout the City of Chicago. 

Specifically, in the time period between 1983 and 1989, there were 89 files: 48 from Area One; 

one from Area Two; nine from Area Three; and 31 from Area Four. In time period between 1999 

and 2006 there were 340 files: 308 from Area One; one from Area 2; 28 from Area Four; and 

three from unknown locations. 

B. Criminal Defense Files are Missing Pages from the Basement Files 

 I also had access to criminal defense attorney files that corresponded to certain of these 

basement files. Mr. Fields’ attorneys attempted to locate defense attorney files for as many of 

these homicide investigations as possible. Through their efforts, they located 51 files for 50 

different homicide investigations.39 Each CPD homicide investigation is assigned a “Records 

Division” (RD) number that is used to identify materials corresponding to a particular 

investigation. I reviewed all of the criminal defense attorney files counsel was able to obtain; 

none were withheld from me.40 

The 51 defense attorney files covered cases from both time periods: For the first group of 

basement files, in the time period from 1983 to 1989, I compared a total of 28 criminal defense 

files41 to 27 corresponding basement files and 27 corresponding permanent retention files. For 

the second group of basement files, in the time period from 1999 to 2006, I compared a total of 

23 criminal defense files to 23 basement files.42

I conducted a case-by-case analysis of what documents are included in basement files but 

are missing from criminal defense files. I did not make any inferences about what documents 

were turned over to criminal defendants – I based my conclusions on observations about actual 

differences between files. The results of my file-by-file comparison are contained in 

Attachment F.

 38 I intend to rely on the spreadsheet included as Attachment G at trial to help explain the 

differences between the particular files to the jury. 

39 Plaintiff located two defense attorney files for the 1985 investigation assigned RD G468726, one for defendant Albert Spraggins, and one for defendant Maurice Spraggins 

40 In a few instances, there were sparse criminal defense attorney files indicating that the 

case had been turned over to another attorney. In those instances, the defense attorney file would 

almost certainly be missing substantial investigative material in the police file. Rather than 

count those cases against the City, they were excluded from the review. 

41 These 28 files concerned 27 separate cases. Plaintiff located two defense attorney files 

for the 1985 investigation assigned RD G-468726, one for defendant Albert Spraggins, and one 

for defendant Maurice Spraggins. 

42 There were no permanent retention files for the second timeframe, 1999-2006. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 170 of 433 PageID #:15591
17 

 My comparison of the Area 143 basement files to corresponding defense attorney files 

revealed that more than 90 percent of defense attorney files are missing investigative material 

that was contained in the basement file. 

The documents missing from the defense attorney files are important investigative 

materials. For example, the following significant discoverable items were routinely absent, and 

are precisely the kinds of documents that should be routinely disclosed to a criminal defendant 

under normal police practices. 

Handwritten Notes: More than 40 of the criminal defense files (or approximately 80%) 

reviewed above were missing handwritten notes that were present in the basement files 

(some Bates examples at 3844, 5024, 5572, 6053, 7160, 8992): These are often found on 

backs of official forms, on plain sheets of paper, on the margins of official forms, and on 

scraps of paper, none of which were the official GPRs on which such information was 

supposed to documented. There were hundreds of handwritten notes contained in the 

basement files reviewed that were not in criminal defense files. They are often not 

inventoried, or if they are, they lack any type of specificity to assist in investigation and 

discovery. They are documents recording the type of information– from alternative 

suspects, to witnesses, to vehicle information, to alternative theories of the crime – that 

should be disclosed to defendants under normal police practices. 

General Progress Reports: Almost half (23 of the 51 files) were missing General 

Progress Reports that were present in the basement files. Like handwritten notes, GPRs 

contain the information regarding witness interviews that should be routinely disclosed to 

criminal defendants according to normal police practices. 

To-From Memos: Approximately 20% of the criminal defense files were missing tofrom memos that were present in the basement files: (see cases G-165272; G-215280; G248336; G-321886; G-468726; G-032399; HH-749335; HK-416661; HK-470751; and 

HK-639684) Handwritten and typed to-from memos, not on GPRs, are another classic 

type of document typically contained in “street files” that were supposed to be prohibited 

during the relevant time period from 1983-1989 and 1999-2006. I saw numerous 

examples of to-from memos contained in the basement files that were not in the criminal 

defense attorney files. Like handwritten notes, they contain a wide range of information – 

from alternative suspects, to witnesses, to vehicles, to alternative theories of the crime. 

Investigative File inventories: only 18/51 of the criminal defense files that I reviewed 

included any type of inventory to serve as an index of documents in the police 

investigative files. 

As discussed above in Section I, pages 6-8, normal police practices and procedures 

require the creation and dissemination of an inventory that serves the purpose of 

providing a compilation of all of the investigative materials related to a criminal 

investigation. The inventory sheet was apparently designed to be used as an index of 

 43 Area 1 became Area Central in 2012. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 171 of 433 PageID #:15592
18 

documents in an Investigative File. Even when an inventory sheet is available, they were 

often incomplete (i.e., missing entries that were listed on the investigative file inventory 

or not listing handwritten notes or other documents) or were so generic as to be worthless 

(e.g., including overly generic entries, such as “GPR,” with no date, number of pages, or 

author). 

Crime Laboratory Reports (some Bates examples at 8941, 9007, 14792, 20830): These 

reports are of critical importance in the judicial process. They form objective analysis of 

everything from fingerprints, to blood, to ballistics. Over 15 defense attorney files were 

missing reports that were included in the defense attorney file. . 

Photographs: Approximately half of the files are missing photographs, either crime 

scene photographs or identification photographs. Photographs are relevant investigative 

information that should always be disclosed to a criminal defendant. Particularly, 

whenever there is a dispute about identification, photographs of the suspect and alternate 

suspects are materials that are disclosed under normal police practices. 

 As discussed below in Section VII, (page 42), these same problems infected the Fields 

files as well. 

C. Issuing a subpoena does little to ensure disclosure of all relevant materials 

 Even in cases where a criminal defense attorney went out of his or her way to send a 

subpoena requesting the “investigative” or “street files,” my analysis reveals that there was no 

guarantee that a defense attorney would receive all the relevant investigative materials beyond 

the official reports in the permanent retention file. In fact, in at least one case that I reviewed, 

(RD # E-010765, Defendant Cecil Robinson) the criminal defense attorney issued a subpoena for 

all investigative material other than official reports, asking the CPD to search all of the various 

locations and types of parallel files (including, as stated in the subpoena, “any and all police 

reports, notes and memoranda contained in the Chicago Police Department ‘street files’ also 

known as ‘office, unit or working files or running files”). CRIM.DEF FILES - FIELDS 037044. 

The defense attorney’s file contained a memo in response to the subpoena claiming that no 

investigative file or other investigative material existed, when in fact there was a basement file 

containing relevant investigative information. CRIM.DEF FILES - FIELDS 037110. 

 In many other instances, the defense attorney issued a subpoena specifically for “street 

files,” and that subpoena appears in the basement file, but not all the documents in the basement 

file were disclosed in response to a subpoena: For example, subpoenas specifically for “street 

files” were issued by defense counsel in the following cases, but as described in Attachment F,

not all the documents were turned over in response: G-108642 (subpoena at ACB 010444); G148403 (subpoena at ACB 011197); G-248336 (subpoenas at ACB 014370, 014378, 014416); 

G-321886 (subpoena at ACB 016656-57); G-468276 (subpoena at ACB 20877-78); G-159857 

(subpoena at ACB 011767); J-418229 (subpoena at ACB 047015); M-690700 (subpoena at 

ACB 047759-60); M-568343 (Subpoena at ACB 048117); M-569727 (subpoena at ACB 

048157); M-580592 (subpoena at ACB 048240-243); M-587998 (subpoena at ACB 048376-77, 

048403-05); G-570120 (subpoena at ACB 023352). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 172 of 433 PageID #:15593
19 

 These subpoena responses suggest deficiencies with regard to the two most basic 

requirements of a process to ensure complete disclosures to defendants: (1) the City did not 

know what files it had and where (not centrally located or indexed); and (2) it did not have 

policies or procedures to ensure that whatever investigative material was found was turned over 

in its entirety. The latter finding is particularly troubling: it suggests that CPD personnel were 

picking and choosing which investigative materials in the files to turn over. 

D. The Missing Pages Contain Important And Relevant Information That Should 

Have Been Disclosed to Criminal Defendants 

Finally, entirely consistent with the findings above, in the majority of cases I reviewed 

investigative material in the basement files was not disclosed to criminal defendants, included 

significant amounts of relevant information that would have aided the defendant and therefore 

should have been disclosed under standard police procedures. In my experience, given the 

volume of investigative material that was not disclosed, it was inevitable that relevant 

information helpful to a criminal defendant would be withheld. That is exactly what I found. 

Below are some examples from the comparison of the defense attorney files and the 

corresponding basement files that demonstrate this problem: 

D-192218: Dion Dorn and Steven Spears allegedly participated in the fatal shooting of 

Telly Howell, a stick-up man who had previously robbed their gang. Police were informed of 

Spears’ and Dorn’s participation in the incident by an anonymous caller. Spears, who was 16 at 

the time of the murder, pled guilty and was sentenced to 25 years. A GPR that is missing from 

the Public Defender’s file contains names, contact information, and handwritten notes of past 

arrests and convictions for four individuals (John Barlett, Leola Barlett, Jamie Gordon, and Paul 

Lamont Jones) and whose connection to the case is unexplained. (ACB 003844) 

D-322218: Rodolfo Garcia was convicted for the murder of Pablo Gomez. After his 

arrest, Garcia participated in a lineup and gave a videotaped statement. At trial and on appeal, 

Garcia moved to suppress the statement, alleging that he had asked for his attorney, GiGi Gilbert, 

who was at the police station shortly after his arrest, but was denied access. Garcia did not have 

any records to prove that he had actually retained Gilbert prior to his arrest, or that Gilbert was 

present at the police station, but the basement file contains a copy of Gilbert’s business card, 

ARDC card, and Sheriff’s ID card. (ACB 004441; 004504) 

D-579065: Defendant Jimmy Velasquez allegedly fatally shot victim Raul Herrera after a 

drug deal went wrong. Officers arrived on the scene around 1:20 p.m. and eyewitnesses 

described the escape vehicle as a white 2-door car. The license plate from the white car was 

tracked to Velasquez’s sister. At trial, there was a question about which car Velasquez drove. 

He testified that he had his own working car at the time of the incident, a blue Camaro. In the 

basement file, a handwritten note (not on a GPR form) documents the statement of Tamonie 

Bustamantez. (ACB 005024). She reported that around 2 pm the day of the shooting she saw 

Velasquez was with “another guy” in a 4-door blue car. The same page of handwritten notes 

also includes the name “Hector Gonzalez” with no additional explanation. Detectives recorded 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 173 of 433 PageID #:15594
20 

a statement from Hector Gonzalez in a GPR that was also withheld from Velasquez (ACB 

005022). That handwritten note corroborating Velasquez’s testimony that he was driving his 

blue Camaro, and identifying potential alibi witnesses, was missing from the defense attorney’s 

file. 

F-048933: Christino Garcia was convicted of shooting and killing Carlos Vasquez after 

an argument in a bar on February 9, 1984. The officers listed a series of cars and license plates 

found at the scene on a GPR at CRIM.DEF FILES - FIELDS 038408, 038410, 038412. But in a 

handwritten note, not contained in the defense attorney file, there is a description of a “Yellow Tbird ZKW987.” (ACB 006096). There is no mention of a Yellow T-Bird in the defense file. 

G-011889: Earl Stademeyer and James Turner were arrested for beating and stabbing a 

man to death. Stademeyer was charged and Turner was released without charging. A Lab 

reports give serological analysis of the blood recovered at the scene. Given that there were two 

men arrested, the blood types of all those involved could have provided evidence about who was 

involved. (ACB 008941-942) 

G-014815: Guy Johns was charged with the murder of Gregory Tucker on January 12, 

1985. A Laboratory report documented serology tests on blood found on multiple exhibits that 

could have excluded Johns or implicated someone else. (ACB 00 9007-9009). This lab report 

was not included in the defense attorney’s file. 

G-165272: William Goodin was convicted of stabbing and killing his boyfriend Ronald 

Anderson. The defense attorney file contains only official police reports. It does not include any 

handwritten notes, GPRs, or to-from memos from the basement file. A to-from memo (ACB 

089330-31) describes efforts to locate Goodin, and notes that a neighbor who was shown a 

picture of Goodin said she hadn’t seen him around for some time. A Supplemental Report (ACB 

089363-89365) was missing from the defense file. In that report, officers document an interview 

with Kim Lee Duckett, where she reported that “Frosty” was one of the offenders. A 

Supplemental Report that was not included in the PD file identifies a man named Tony Murray 

as “Frosty.” (ACB 089411-089412, 089414). It also includes statements from individuals 

named Gene Pendleton, Robert Brown, and Jack Thomas, whose names and statements are not 

included in the file. 

G-257089: Freddy Brown was charged with stabbing a man after an argument about a 

locked gangway gate. A GPR missing from the defense attorney’s file states that ‘a bunch of kids 

were down there by [illegible] stabbing” (ACB 014811). The kids are not referenced elsewhere 

and are significant because they are potential witnesses. 

G-267826: James Walker was charged for shooting 4-year-old Angel Hendrix after 

Walker and Fred Williams allegedly got in a fight in front of his home. Three GPR contain 

information that was omitted from the defense attorney file. First, a GPR describing an 

interview with Fred Williams states that “He had an attitude” (ACB 015426). The substance of 

Williams’ statement was present in the defense file, but not the officer’s impression of Williams’ 

“attitude.” Another GPR lists the name “John Dawson” who reported hearing the arguments and 

someone say “kiss my ass.” (ACB 015428) Only the witnesses that were near the shooting heard 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 174 of 433 PageID #:15595
21 

this statement. But Dawson’s name and contact information were not included in the defense 

attorney’s file. Finally, another GPR lists a potential witness who was not disclosed (ACB 

015421). That GPR lists the name “Hawkins, Jarita” contact information, and a note that states 

“went in car.” As a potential witness, this name and contact information should have been 

disclosed. 

G-284291: Lucille Pye was charged with stabbing and killing Lenita Williams with a 

fingernail file on July 24, 1985. Pye and Williams were fighting over a man, Michael Jeffery. 

Information from several witnesses was missing from the defense file: Officers described 

statements from John Jenkins and Denise Williams (ACB 16220-21), in a to-from memo and 

included contact information for both witnesses that does not appear in the defense attorney’s 

file. Officers also wrote a handwritten note with the names Jean Jenkins, Debra Thomas, and 

Lucille Jeffery that was not included in the defense file. (ACB 16270) 

G-321886 – James Crockett, Manuel Rios, and Willie Mullen were charged with murder. 

GPR list names and interview notes from potential witnesses that were not disclosed in the 

defense file. (ACB 16774-75; ACB 16836) 

G-326467: George Frison, Edward Ware, and Anthony Mason allegedly shot and killed 

Kennedy Brooks. The basement file contains information regarding a potential witness, named 

Monique Kizer, who is not mentioned in the Public Defender’s file. Handwritten notes at ACB 

017185 include Kizer’s name and contact information. Officers also investigated Kizer’s arrest 

history, keeping a printout in the file. (ACB 017275). 

G-468726: Albert Spraggins & Maurice Spraggins were charged with shooting and 

murdering Albert Black on November 22, 1985. Police relied on eye-witness testimony and the 

confession of Maurice Spraggins. Plaintiff’s attorneys obtained copies of the defense attorney 

files for both Maurice and Albert. Neither file contained identification pictures of the defendants 

that were in the basement file (ACB 02865-02868, ACB 020914-020915 

G-570120: Crisino and Filberto Bravo were charged for fatally shooting Juan Olmeda 

based on eyewitness identifications. The basement file also contains details about a possible 

alternate suspect. A handwritten GPR includes a statement from Antonio Vasquez, a witness to 

the shooting, that the shooter “looked like Spade.” (ACB 23421). According to a Supplemental 

Report, contained only in the basement files, officers showed Vasquez photographs of men who 

use the nickname “Spade” and asked him to identify the man he saw shooting. Vasquez 

identified a man named Alonzo Velasco. (ACB 23456). Velasco was brought in and 

participated in a lineup, and Vasquez again identified Velasco. The defense attorney’s file 

contains a report listing Velasco as a participant in a lineup, but it does not include the fact that 

Vasquez identified Velasco as “Spade.” (Id.) 

Police also recovered a gun and casings and submitted them for testing. The ISP Forensic 

Reports (ACB 023470-47) finding no latent fingerprints suitable for comparison on the gun or 

the casings were withheld from Crisino Bravo. 

G-705434: Norman McIntosh allegedly killed Devon Hobson in a gang-related shooting 

and in retaliation for a robbery earlier that day. Hobson was with his brother, James, and his 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 175 of 433 PageID #:15596
22 

cousin Darius Thompson, and a friend Aaron Smith walking down the street. Police reports in 

the Public Defender’s file state that Darius Thompson saw man in a gray car “driving slowly in 

their direction.” McIntosh was identified by James Hobson and Darius Thompson. A GPR, at 

ACB 027247, however, records an interview with Thompson, suggests that the car was following 

them from behind, undermining the witnesses’ accounts of what they saw. 

HH-175723: Maurice Brown was charged for the fatal shooting of Antonio Willis. 

Police questioned Stanley Foots as an alternate suspect, but he was apparently ruled out because 

his girlfriend served as his alibi witness. (CRIM.DEF FILES - FIELDS 008064, 008118). A 

handwritten note that was withheld from Brown, however, states “Stanley confronted with 

Girlfriend’s contradiction.” (ACB 049385). There is no reference to a contradiction between 

Stanley and his girlfriend’s statement in the Public Defender’s file. The same note also identifies 

potential alternate suspects. The note states “Martez Haywood and Lil Arthur did it on 3519 S. 

Federal. White dude? found as well.” (Id.) Neither name appears in the Public Defender’s file. 

HH-358668: Christopher Peoples, Marcel White, and James Mitchell, allegedly shot and 

killed Brian Campbell, the husband of Ninner Powers, during an attempt to forcefully collect on 

a debt Powers owed to White. Powers recognized and identified White and Mitchell, but she did 

not recognize the third offender. The basement file identifies possible alternate suspects in 

documents that are absent from the Public Defender’s file. Lawrence Harper was an 

acquaintance and neighbor of Powers and the victim Campbell. According to supplemental 

reports, Harper was across the street at the time of the shooting, witnessed one man jump off the 

porch of the victim’s home, and then went to the victim’s home and stole a watch and ring from 

the victim’s body. (ACB 031348; 031464-65). Harper also reported that the man he saw running 

from the porch may have been “Squirt” and, from photographs, identified two other individuals 

he knew with that nickname. (ACB 031465; 31491). It does not appear that Harper, or the two 

men he identified, are referenced in the Public Defender’s file. 

HK-211174: Lakesha Collins, Laquita Calhoun, Terrence Jones, and Jeanette Daniels 

were charged with the kidnapping and murder of Alonzo Jones. Jones was found in an alley and 

had apparently been beaten and run over by a car, apparently in retaliation for molesting Laquita 

Calhoun’s children. Police reports indicate that several people beat Jones and put him in the 

trunk of a car, and but that at one point during the incident, Collins tried (unsuccessfully) to help 

Jones escape. In Collins’ statement, she asserted that, though she got into the car, she got out 

before Jones was killed. Illinois State Police lab results included in the basement file, but which 

are absent from Lakesha Collins’ Public Defender file, provide corroboration for that statement: 

those reports exclude, Collins as the source of DNA on several cigarette butts found on the 

scene. See ACB 038172-175 and ACB039216-217. ISP reports at ACB 038171 and 038232, 

which are again absent from the Public Defender’s file, state the no latent fingerprints were 

found on a knife and other pieces of evidence. Finally, the basement file states that neighbors 

may have seen part of the brawl. A GPR states that “1st floor neighbors of Jeanette see dude hit 

victim cause they come out of Apt. Came home for 1/2 hour then left for work” (ACB038292), 

but the Supplemental Report corresponding to those notes, which is included in the Public 

Defenders’ file, states that officers interviewed “1st floor residents about the beating and murder 

of Alonzo Jones. The occupants were highly intoxicated and uncooperative with the 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 176 of 433 PageID #:15597
23 

investigation. they denied all knowledge of any crimes and refused to give an person 

information” (ACB038265-86). 

J-418229: Officers were investigating a shooting at a motel in room 114. There are a 

number of witnesses who heard the gunshots. A GPR lists the name “Andre Woods,” a phone 

number, and the phrase ‘out with P.O. Tuesday.’ On the next page a handwritten note reads ‘PO 

Keith Calloway 5256’- Neither Andre Woods or this officer are mentioned elsewhere. (ACB 

046940-941). Two other witnesses are listed in GPRs in the basement file, but not in the 

supplemental reports in the defense attorney file. First, a note that “B.U. →I didn’t see nothing/ 

I didn’t hear nothing/ I didn’t do nothing.” The note includes a large red ‘x’ over it. (ACB 

046944). Another witness named Russell Bolden, who “Heard Shot Saw Nothing” was omitted 

from the supplemental reports (ACB 046966). All potential witnesses should have been 

disclosed to the defense. 

In several of these cases, there are handwritten notes, or GPRs that list names and contact 

information of individuals without additional context or explanation of their relationship to the 

investigation. In my experience, it is likely that these were individuals whose names came up 

during the investigation as possible suspects or witnesses that a detective would want to 

remember and follow up on. And in fact, as explained below, several similar notes in the Fields 

basement file listing names without any explanation, were in fact referring to important alternate 

suspects.44 These examples emphasize how important it is to disclose all investigative materials, 

because the importance or relevance of certain pieces is not always apparent looking at a 

document in isolation. 

Moreover, the fact that the relationship of various names is not explained elsewhere in 

the basement files is indicative of the practice of using multiple, parallel files for an 

investigation: there is no evidence that explains where the names came from, or evidence of any 

follow up to investigate those names. That suggests that detectives continued to store that 

information in separate files, that were not ultimately stored with the basement files. 

V. CPD’s Policies after Jones and Palmer Don’t Ensure Disclosure of All Relevant 

Investigative Materials 

All police officials are aware of the challenges of ensuring that, over the course of an 

evolving criminal investigation involving multiple investigators developing evidence at different 

locations and times, that investigating officers document their findings and that such 

investigative material is collected, preserved, compiled and disclosed. In the CPD’s case, it was 

acutely aware of these challenges since 1982, at the time of the Jones case, and the problems 

created by using multiple, parallel files. Yet, it has made only superficial attempts to resolve its 

“street files” problem. It issued written directives, but they were incomplete and insufficient in 

their scope, and beyond that they were not supplemented with the training, auditing and 

monitoring necessary to ensure that the necessary changes in practice occurred. Unsurprisingly, 

then, the street files problem continued. 



44 See Section VII, pages 42-43, describing CITY-NF-001062; CITY-NF-001076; CITY-NF001085, which list names of alternate suspects without any additional information 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 177 of 433 PageID #:15598
24 

1. A department-wide teletype issued during the Palmer litigation; 

2. Detective Division Notice 82-2 (Detective Division Notice - File Control); 

3. Special Order 83-1 (Detective Division Special Order – File Control); 

4. Special Order 83-2 (Detective Division Special Order – Investigative Files); 

5. Special Order 86-3 (Detective Division Special Order – Investigative Files); and 

6. Standard Operating Procedures (SOP) 1988 

Instead of using the Jones and Palmer litigation as an opportunity to reform its practices 

and implement standard police procedure of creating one single, centralized file for each 

investigations, those directives actually instructed detectives to create multiple, parallel files, 

each with different information and did nothing to address the fundamental problems regarding: 

(1) allowing officers discretion about what to document in the official reports; and (2) the 

absence of any system or training for responding to subpoenas and ensuring complete disclosures 

of investigative material. Moreover, the CPD provided only minimal training on these orders, 

and failed to conduct any audit, supervision, or oversight to ensure that detectives were following 

these new directives.45 

A. The Policies are Insufficient to Remedy the “Street Files” Problem 

1. The Teletype and Detective Division Notice 82-2 

In April 1982, after a Temporary Restraining Order was issued in the Palmer litigation, 

CPD issued two documents: (1) Detective Division Notice 82-246 and (2) a 1-paragraph teletype 

to commanding officers alerting them to the TRO.47 As Hickey explained, Notice 82-2 was “a 

quick and dirty document” designed to implement the TRO but was “not very workable.”48 

Notice 82-2 and the corresponding teletype were concerned only with preservation and 

were silent about procedures to collect or inventory their notes, memos, or other documents. 

Although it coined the term “Unit Investigative File,” it did not require detectives to put notes or 

memos into Unit Investigative Files; and it did not specify whether detectives had to preserve 

notes or memos that were not in the file.49 

Even with Notice 82-2’s limited requirements and scope, the CPD showed little 

commitment to implementing that Notice. There is no evidence of training to implement the 

Notice, and six months after its implementation, Commander Stibich testified that it was still the 

prevailing view that if a detective kept his own personal notes or memos – or considered those to 

be his personal property – then Notice 82-2 did not require the detective to put those notes or 



45 Hickey Fields Dep. at 10, 43. 

46 NF-L 008751 

47 NF-L 008754; Hickey, Kluppelberg Deposition 201 (NF-L 001141) 

48 Hickey Kluppelberg Deposition 221-22, 224; (NF-L 001161-62, NF-L 001164); Brzezcek 

Test. NF-L 007517 

49 NF-L 008751-53; Hickey Kluppelberg Deposition 212-13 (NF-L 001152-53) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 178 of 433 PageID #:15599
25 

memos in the file and detectives felt they could do whatever they wanted with those notes or 

memos, including destroying them.50

 

Based on this and other testimony, Judge Shadur found that Notice 82-2 responded to the 

TRO in “an improperly restrictive and grudging manner, under which detectives could consider 

their investigative writings as their personal property (and thus not ‘under Detective Division 

control’) and therefore outside the preservation requirements of Notice 82-2.”51 The comments of 

Commander Stibich and the findings of Judge Shadur make clear to me that the practice of 

keeping information in parallel files that were not shared with prosecutors or criminal defendants 

was an ingrained problem within the police department, and one that would require the sort of 

dramatic change in attitude and culture that could only be achieved through extensive training, 

monitoring, and discipline. 

 2. Special Order 83-1 

 On January 3, 1983, Detective Division Notice 82-2 was replaced by Special Order 83-1. 

Special Order 83-1 applied only to the field investigations of detectives assigned to Violent 

Crimes.52 Special Order 83-1 defined certain terms and created procedures for documenting and 

preserving investigative documents. Special Order 83-1 defined the term “Investigative File” and 

created something called an Investigative File Case Folder to secure documents relating to a 

criminal investigation. According to the terms of Special Order 83-1, an Investigative File Case 

Folder was to be created either when certain categories of violent crimes occurred53 or when a 

violent crime investigation resulted in an arrest and approval of felony charges.54 Special Order 

83-1 also created an “Investigative File inventory sheet,” which was supposed to identify each 

document placed in the Investigative File.55 The inventory sheet was to be forwarded to the 

Records Division anytime felony charges were lodged.56 Finally, Special Order 83-1 created 

General Progress Reports (“GPRs”).57 The GPR forms were to be used by detectives whenever 

they were taking handwritten notes or writing memoranda to other detectives. 

 Unlike Notice 82-2, Special Order 83-1 created an affirmative obligation for detectives to 

submit handwritten GPRs or investigative materials for review and inclusion in the basement 

file. It also mandated that detectives transcribe relevant information previously recorded on a 



50 Stibich Test. (NF-L 007468-70) 

51 NF-L 005615-16 

52 NF-L 007223-27 

53 Those categories of violent crimes were identified in Special Order 83-1, V(A)(1): 

Homicides/Medical Examiner Cases; Police-related shooting incidents; Batteries likely to result 

in death; Rapes and Deviate Sexual Assaults, and Any other major violent crime field 

investigation that the unit supervisor deems appropriate. 

54 Special Order 83-1, V(A)(1) & (2) 

55 Special Order 83-1 IV(D) 

56 Special Order 83-1, IV(D) 

57 Special Order IV(E); Hickey Kluppelberg Deposition 170 (NF-L 001110) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 179 of 433 PageID #:15600
26 

GPR or other miscellaneous documents on an official CPD case report form (general offense 

case reports, supplementary reports, etc.).58 

 In reviewing Special Order 83-1, Judge Shadur identified several deficiencies, including: 

• Unless the crime being investigated fit one of the specified of violent crimes, 

there was no obligation to create an Investigative Case File Folder unless and until the 

offender was arrested and felony charges were approved. According to Judge Shadur, 

and in line with standard police practices, this continued to pose the same type of risk 

that information would not be retained and disclosed because there was nothing to 

prevent against selective retention while the case is investigated;59 

 

• It only required detectives to include “relevant” information in the official reports 

and offered no guidance about what information a detective should deem “relevant,” 

leaving discretion for detectives to withhold information based on their assessment 

that it was not relevant.60 

• It did not include information to ensure that any detective who has or receives 

information relating to a violent crime field investigation not assigned to him will 

forward the information to the assigned detective for investigation and inclusion in 

the Investigative File Case Folder;61 and 

• It omits any provision defining how the CPD responds to a criminal subpoena or 

request by the State’s Attorney to produce information relating to a criminal 

proceeding.62 

Moreover, the training on 83-1 was inadequate. Hickey testified that he provided a onetime training to about 1,000 detectives.63 He said each training session was done in groups of 

30-40 people, and lasted approximately 3 hours.64 During that three-hour training session, he 

went over Special Order 83- 1. One training session was wholly insufficient to try to change a 

decades-long practice, especially one so ingrained in the culture of the police department. 

3. Special Order 83-2 

On May 2, 1983, Special Order 83-2 was issued. Three of the changes in Special Order 

83-2 were (1) a requirement that detectives create records reflecting all relevant information, 

V(B)(1); (2) a requirement that where a detective receives information about another crime, he or 



58 Special Order 83-1 V(B)(1) & (2), NF-L 008772-73 

59 NF-L 005620 

60 Special Order 83-1 V(B) (NF-L 005620); Hickey Kluppelberg Deposition 238; (NF-L 

001178); Hickey Kluppelberg Deposition [2015] 20. 

61 NF-L 005621 

62 NF-L 005621 

63 Hickey Kluppelberg Deposition 308-309 (NF-L 001249-50); NF-L 008808 

64 Hickey Kluppelberg Deposition 309 (NF-L 001250); NF-L 008808 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 180 of 433 PageID #:15601
27 

she pass that information along to the detective investigating that other crime, V(B)(6); and (3) 

that a copy of the Investigative File Inventory Sheet will be transmitted to either the Office of 

Legal Affairs (in case of a subpoena from a criminal defendant) or the State’s Attorney’s Office 

(in case of a discovery motion) so that the inventory sheet is disclosed to defense counsel in a 

criminal case, V(B)(6).65 Hickey also testified that Special Order 83-2 also created the 

Investigative File Control Card, IV(F).66 This Control Card was supposed to act like a library 

card so that the Investigative File could be accounted for. 

Despite these new requirements in 83-2, there is no evidence that CPD provided any 

additional training to update detectives on the differences between 83-1 and 83-2. 

Moreover, even if detectives had been adequately trained on Special Order 83-2, it was 

still deficient. Here are some of the deficiencies that should have been apparent to CPD 

policymakers. 

• Special Order 83-2 still did not comply with standard police practice to require a 

single repository for all investigative information maintained by a lead 

investigator. 

• Special Order 83-2 applied only to detectives, and it explicitly excluded from its 

directives all other officers involved in investigating major crimes, such as gang 

crimes officers, officers from bomb and arson, and officers from patrol, among 

others. 

• Special Order 83-2 provided no guidance about what information a detective 

was required to include in a supplementary report beyond information deemed 

“relevant.”67 Relevance is of course subjective and, as Commander Stibich testified, 

what is relevant to one detective may not be relevant to another.68 In fact, Hickey 

testified that a detective would only have to put information in a supplemental report 

if the detective deemed it pertinent at the time that the detective wrote the 

supplemental report, regardless of whether the detective considered the information 

relevant when he or she received it.69 For example, Hickey testified that CPD policy 

did not require suspects who had been eliminated through investigative activity to be 

documented in any way.70 Based on my experience, this is inconsistent with standard 

police practices. Alternate suspect information, for example, is highly relevant 

information and its documentation and disclosure to criminal defendants is critical.71 



65 NF-L 008746-50 

66 Hickey Kluppelberg Deposition 228-29 (NF-L 001168-69) 

67 Hickey Kluppelberg Deposition 238; (NF-L 001178); Hickey Kluppelberg Deposition [2015] 

20 

68 Stibich Test. NF-L 007474 

69 Hickey Kluppelberg Deposition [2015] 24-25, 33 

70 Hickey Kluppelberg Deposition 237-38 (NF-L 001177-78) 

71 This does not prevent an investigating officer from also documenting information explaining 

why the suspect was eliminated. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 181 of 433 PageID #:15602
28 

• Special Order 83-2 provided no guidance about how information should be 

communicated or documented among detectives, for example when one detective 

learned something about a crime being investigated by another detective; or when one 

unit learned something about a crime that is also being investigated by another unit.

While section V(B)(6) of Special Order 83-2 codifies the obligation to “forward” 

information about a crime to the assigned detective, it does not require either 

detective – the detective passing along information or the receiving detective – to 

document that information.72 Similarly, even where the detective passing along the 

information may have created a document memorializing that information – e.g., a 

memorandum or GPR – there is no requirement in Special Order 83-2 that the 

resulting memorandum or GPR be distributed to other detectives or units 

investigating that crime.73 

• Nowhere does Special Order 83-2 state that an investigative file should must be 

disclosed in response to a discovery motion or subpoena, or provide procedures 

for doing so. Despite the underlying circumstances of Jones and Judge Shadur’s 

admonishment about the failure to “defin[e] the CPD’s duty or procedure in 

responding to a criminal subpoena or request by the State’s Attorney to produce 

information relating to a criminal proceeding,” Special Order 83-2 included 

absolutely no policy directive or procedure to ensure production of investigative files. 

This is a straightforward requirement of any policy regarding maintenance and 

disclosure of investigative materials, and, as explained above, standard practice is to 

simply provide the single investigative file to the prosecutor or directly to the defense 

attorney to ensure all documents are disclosed. 

• Special Order 83-2 relies on inventory sheets instead of actual disclosure of the 

files. special orders 83-1 and 83-2 introduced the inventory sheet, which was 

apparently designed to be used as an index of investigative materials so that members 

of the CPD and other actors in the criminal justice system had a way to determine 

what information existed in police files. Special Order 83-2, required “whenever a 

subpoena or discovery motion is received in any case, two copies of the Investigative 

File Inventory Sheet will be forwarded to the Office of Legal Affairs . . . .so that one 

of such copies may be transmitted to the attorney for the defendant.”74 But the Order 

does not require that the actual documents in the file be disclosed, nor does is require 

that documents maintained in other units not covered by the Order (e.g. gang crimes 

unit) be turned over. 

• Inventory sheets are an inadequate mechanism for ensuring disclosure of 

documents generated during the police investigation. While the investigative file 

inventory sheet is designed to be used as an index of documents in the file, there is no 

guidance about what level of detail is needed in the inventory sheet to ensure that it 



72 Hickey 236-37 Kluppelberg Deposition (NF-L 001176-77) 

73 Hickey Kluppelberg Deposition [2015] 39, 43, 46 

74 Special Order 83-2, V(B)(6), NF-L 008832 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 182 of 433 PageID #:15603
29 

serves its purpose. Indeed, my review of the records demonstrates that the inventories 

are largely useless because the entries are too general, often missing dates, 

descriptions and numbers of pages, such that one cannot tell whether they have the 

document referenced. In addition, that sheet is only distributed beyond the Area or 

investigating unit if felony charges are placed IV(D); V(B)(6). This creates multiple 

problems: 

o If an inventory only has to be filled out and sent at the issuance of charges – 

as opposed to filled out as the investigation proceeds – there is a risk that 

documents will be left off the inventories that the detective no longer deems 

relevant or that are potentially harmful to the prosecution’s case. That leaves 

the individual detective far too much discretion about what to include on the 

inventory once charges are filed; 

o If any additional investigation is done after charges have been lodged (for 

example, if there are multiple offenders) there is no provision that requires 

anyone to fill out or distribute an updated inventory; 

o Inventories do not contain the substance of information obtained during an 

investigation; 

o It assumes that inventories would have to be complete, accurate, and 

consistently turned over; as discussed below, my review of files shows that 

this rarely occurred. 

• Finally, there is no provision in Special Order 83-2 requiring an audit or 

oversight to ensure compliance with the special orders. 

4. Special Order 86-3 

 On May 29, 1986, the CPD issued Special Order 86-3. Special Order 86-3 largely 

replicates its predecessor with some minor adjustments, most of which actually limited, rather 

than expanded, to policies governing disclosure of investigative materials to prosecutors and 

defense attorneys. For example, Special Order 86-3 more explicitly limits the creation of 

Investigative File Case Folders to homicides or felony investigations where charges have been 

approved, or an arrest warrant issued; it eliminates the requirement that the inventory sheet be 

forwarded when a criminal subpoena or discovery motion is received; it eliminates the 

requirement that handwritten notes or other investigative materials be submitted “promptly 

(normally at the end of each tour of duty)” and instead only states that such notes must be 

“submitted.” 

 In these ways, Special Order 86-3 actually deviated further from standard police practices 

than the special orders that came before it: 

• It still did not comply with standard police practice to require a single repository 

for all investigative information maintained by a lead investigator. 

• It permitted detectives to maintain their handwritten notes as personal files for 

longer periods of time, by removing the requirement that they turn in the notes and 

investigative materials “promptly (normally at the end of each tour of duty).” Thus, 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 183 of 433 PageID #:15604
30 

even if detectives retained their handwritten notes on their person, or in their locker 

for extended periods of time, it would not clearly violate the Order. In my 

experience, that level of discretion is a gross deviation from standard police practices, 

especially in light of the ingrained problem in CPD. 

• It still provided no guidance about what information a detective was required to 

include in a supplementary report beyond information deemed “relevant.” 

• Finally, it removed even the inadequate stop-gap measure of providing the 

inventory sheet to defense attorneys, leaving defense attorneys with no mechanism 

to determine whether they had received all the relevant investigative materials. 

Special Order 86-3 included a section VI, titled “Inspection.” That section requires 

“[e]xempt members of the Detective Division” to “conduct periodic, unscheduled inspections of 

the subject files to ensure compliance.” According to Stibich, however, he had no idea if, when, 

how often, or in what manner such inspections were conducted.75 Likewise, the City has 

produced no documentation that any such inspections were ever conducted. Hickey testified that 

no audits were done subsequent to Special Order 82-2 and detectives were not routinely 

disciplined for failure to comply with the special orders.76 Nor is there any evidence that 

detectives were trained on this new policy. In short, I have not been presented with any evidence 

that policymakers trained, reviewed, or supervised subordinates to ensure that Order 86-3 was 

implemented or followed. 

5. Standard Operating Procedures (SOP) 1988 

In 1988, Chief of Detectives John Townsend wrote standard operating procedures to 

govern the work of detectives. Chapter 18 deals with investigative files. Chapter 18 contains “no 

substantive changes of any kind” from Special Order 86-3.77 

6. Summary 

The policies implemented by the CPD were inadequate to remedy the “street files 

problem” and deviated from standard police practices regarding documenting and disclosing 

investigative materials. 

First, none of the policies required a single repository for all investigative information 

maintained by a lead detectives. In fact, in reviewing the materials provided, I identified at least 

three different files that would be created relating to any criminal investigation pursuant to the 

special orders. First, there would be a permanent retention file in the Records Division, 

containing only supplementary reports, general offense case reports and the arrest report filed 

under the accompanying RD number.78 Second, there would be a unit RD file: Hickey testified 

that this was a slim file kept in the homicide drawer at the Area to identify that there is a case 



76 Hickey Fields Dep. at 10, 43. Hickey Kluppelberg Deposition 213. (NF-L 001153) 

77 Hickey Rivera Deposition pages 250-51 (NF-L 000338-39) 

78 Hickey Kluppelberg Deposition [2015] 22-23, 95-96. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 184 of 433 PageID #:15605
31 

open.79 Like the permanent retention file, it would contain all the known official police reports: 

original case offense report, supplementary reports, and reports sent to the investigative unit 

from support units.80 Third, there would be the investigative file maintained by the area or any 

specialized unit.81 This file would contain documents that individual detectives assigned to 

investigate the case have determined should be in there.82 As noted above, none of the files had 

to have the same documents in them: In fact, by design, they did not.83 Likewise, Hickey 

admitted that the files did not even necessarily have the same information in them.84

Moreover, additional files would also be created by other units of the Chicago Police 

Department, because the policies only applied to the Detective Division. So, in addition to the 

multiple files above, Gang Crimes officers, other special unit investigators, and patrol officers, 

could each have additional sets of files related to a homicide investigation, and the special orders 

are silent as to those additional files. 

This was an apparent omission. In fact, Hickey testified that he raised the fact that 

Special Order 83-1 was only addressed to the Detective Division and that the Department might 

want to look beyond the detective division to see if the problem extended to other units.85 And at 

some point, Hickey suggested that perhaps Research and Development and Auditing Internal 

Controls Division should get involved because there may be department-wide implications to the 

use of street files.86 But there was no response from the chain of command to Hickey’s concerns 

and CPD never looked to see if the problem of street files went beyond the Detective Division. 

This failure to look beyond the detectives – notwithstanding the fact that they worked closely 

with other units in investigating crimes – was deficient and allowed yet more parallel files to be 

created in other parts of the Department. 

The problems created by such an unwieldy system are obvious: It creates the potential for 

information and documents to go missing because they are not centrally controlled. Moreover, 

because the files are designed to be different and to be retained in different locations, there is no 

way to ensure that the complete investigative file is produced during any criminal prosecution. 

 Second, the policies also left detectives with far too much discretion about what 

information to document in official reports and when to turn in investigative materials. This is 

particularly true because the status quo had previously been not to record or document 

information – at least not on official documents that would be maintained by CPD and disclosed 

to the prosecution and defense. As a result, to overcome this culture – and this citywide practice 



79 Hickey Kluppelberg Deposition 115-16 (NF-L 001055-56) 

80 Hickey Kluppelberg Deposition 115-16 (NF-L 001055-56); S.O. 86-3 

81 Hickey Kluppelberg Deposition 297-300 (NF-L 001238-41) 

82 Hickey Kluppelberg Deposition 297-300 (NF-L 001238-41) 

83 See for examples Hickey Kluppelberg Deposition [2015] describing documents that would go 

in the investigative file but not in the permanent retention file at 71-72, 81, 91, 94, 100, 103, 105, 

108-110 

84 Hickey Kluppelberg Deposition [2015] at 100 

85 Hickey Kluppelberg Deposition 207-208 (NF-L 001147-48) 

86 Hickey Kluppelberg Deposition 208 (NF-L 001148) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 185 of 433 PageID #:15606
32 

– CPD had to be explicit in its requirements and provide direct guidance about what did or did 

not have to be documented; it is not enough to leave it up to the individual officer. 

The most egregious example of the problems of officer discretion relate to the lack of a 

requirement to document elimination of suspect. Indeed, Hickey testified that it was not the 

policy of the CPD to require detectives to document suspects who were eliminated.87 To the 

contrary, it was permissible and consistent with the special orders not to document the identity or 

investigative steps taken to eliminate a suspect if a detective did not think that information was 

relevant or if the detective discounted it for some reason.88 This is a significant departure from 

standard police practice, which calls for officers to err on the side of documentation and 

disclosure of such information, which is often crucial to other investigators on a case and highly 

likely to contain exculpatory information. 

B. The City failed to provide proper training and oversight to ensure compliance 

with the special orders 

On a department-wide scale, there was no action taken whatsoever to ensure that the 

special orders were being followed. The only training provided was one three-hour session after 

83-1 was issued. But, as explained above, one three-hour training session was wholly insufficient 

to try to change a decades-long practice. In fact, Hickey testified that the years after Special 

Order 83-1, he learned that unit detectives were reverting back to carrying their own files on the 

street separate and apart from the file maintained by CPD.89 Nothing, however, was done about 

this. 

Hickey also explained that although he did a sampling prior to the special orders being 

issued, he did not do one at any time after Notice 82-2 and was not aware of anyone else 

conducting such an audit.90 On a more individual scale, Hickey testified that members of the 

police department were supposed to conduct inspections pursuant to Special Order 83-2 but 

Hickey could not identify any instances of audits or investigations.91 Similarly, Commander 

Stibich testified that supervisors were supposed to review files but he had no idea how often, 

when or the manner in which that review was conducted.92

In fact, it appears that there was no oversight to ensure that the special orders were being 

enforced and that the street files practice was eliminated. This is particularly troubling given the 

importance and scope of the problem and is certainly deficient. You cannot expect a departmentwide, decades-long practice to be eliminated by simply issuing an order that was read at roll call 

a few times. Based on my experience, this requires extensive and ongoing training (not a onetime session of a couple of hours), careful auditing and monitoring, and meaningful discipline 



87 Hickey Kluppelberg Deposition 237-38 (NF-L 001177-78) 

88 Hickey Kluppelberg Deposition 339 (NF-L 001280); Hickey Kluppelberg Deposition [2015] 

at 66-67. 

89 Hickey Kluppelberg Deposition 321, 327 (NF-L 001262, NF-L 001268) 

90 Hickey Kluppelberg Deposition 160-61, 166, 167 (NF-L 001100-01, NF-L 001106-07) 

91 Hickey Kluppelberg Deposition 375-76 (NF-L 001316-17) 

92 Stibich Testimony NF-L 007461-62 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 186 of 433 PageID #:15607
33 

when the new special orders were not followed. Based on my review of the record, almost none 

of this occurred. Accordingly, CPD leadership either knew or was deliberately ignorant of the 

fact that the street files problem continued unabated after issuance of the special orders. 

VI. The Basement files show that the directives were not properly implemented 

A. The basement files from the 1983-1989 time period show that the special orders 

were not followed 

 I reviewed the 89 basement files from 1983-1989 to evaluate whether the basement files, 

standing on their own (i.e. without comparing to a permanent retention file or defense file) 

demonstrated compliance with the 1982, 1983, and 1986 special orders. The files show that the 

special orders were not followed in several ways: 

1. Handwritten notes, not on General Progress Reports, are still routinely 

used 

As discussed above, the special orders directed officers to use GPRs to take notes, and 

were intended to eliminate the use of handwritten notes on loose sheets of paper without any 

context of who wrote the note and when. Reviewing the 89 basement files from 1983-1989 

demonstrates that detectives consistently used handwritten notes despite the direction in the 

special orders. 73 out of the 89 contained handwritten notes not on GPRs. 

2. To-From memos are still being used 

As discussed above, the special orders also directed officers to stop using to-from memos 

to communicate investigative information, and to instead include that information in GPRs and 

Supplemental Reports. The 89 basement files from 1983-1989, however, show that detectives 

continued using to-from memos: 38 out of the 89 files contained to-from memos not on official 

police forms. 

3. All relevant information in unofficial documents is not transcribed in 

official reports 

The special orders state that all relevant information must be transcribed into an official 

report, in an effort to ensure that the permanent retention file, which contains only official 

reports, provides a complete picture of the investigation. 

But, the case files I reviewed are replete with examples of handwritten pages and 

informal memos between detectives containing potentially exculpatory information. These 

handwritten notes contained critical investigative information, including: 1) Leads on different or 

additional avenues of investigation or suspects (Bates 048422); 2) Names or descriptions of 

additional witnesses found in at least 50% of the basement files); 3) References to other CPD or 

outside law enforcement involvement in the investigation (Bates 06139-41; 011669); and 4) 

Handwritten diagrams, scene and area maps, evidence locations (Bates 020928; 016773; 015652; 

031512). These citations are examples only, and not an exhaustive list of instances where these 

trends were seen. 

In the vast majority of the cases that I reviewed, there is no companion entry on official 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 187 of 433 PageID #:15608
34 

CPD forms that documents this critical information, leaving this potentially exculpatory 

information solely in handwritten notes or in informal memos contained in the Investigative 

Files. By not transcribing it into an official report, it is less likely to get into the permanent 

retention file, and as observed above, to criminal defendants. Some examples of these omissions 

include: 

• In custody detention log (G-266841A – Bates 05194-95) shows suspect 

detained in stationhouse from 6/27/01 @ 3:00 PM until 6/28/01 @ 10:55 PM 

– nearly 32 hours (time of last entry – nothing to show when he was booked or 

released). Log is written on a GPR – all in the same hand and appears to be 

done after the fact, all entries made at one time. 

• In handwritten note (M-587998 – Bates 48422) on a plain piece of paper 

provided by CPD Officer William Freeman on 1/9/90 @ 1930 hours, is the 

following: 

To whom this may concern Dalmar Milton in 141 N. Wolcott #301 

Andrew in 141 N. Wolcott #305 

an (sic) another boy that lives in 1850 #603 

Killed Fat Ed behine (sic) the boys club on Christmas night they 

beat him to death with a golf club. Someone saw it but they are 

afraid to come fort (sic). 

Thank you 

? ? ? 

The permanent retention files that I reviewed similarly demonstrate that the official reports 

that become part of the Permanent Retention File provide an incomplete picture of an 

investigation. 

If the special orders were being followed, this should not happen. Under the special orders, 

all relevant information learned during the investigation is supposed to be transcribed into an 

official report, and so the official reports contained in the permanent retention file should for all 

intents and purposes contain all of the same information (although not necessarily all of the same 

document) about the investigation, including any exculpatory and impeaching information 

developed during the investigation. 

 

a. Review of Permanent Retention Files 

I reviewed the investigative and permanent retention files (permanent retention files) for the 

years 1983-1989 and intends to rely on all the permanent retention files produced in that period 

to demonstrate the City’s failure to train, follow, or implement its special orders. 

I was provided with digital copies of 27 permanent retention files, corresponding to 27 

basement files from the time period 1983 - 1989. I examined, compared and contrasted the 27 

permanent retention files with their corresponding basement files (IF). See Attachment F 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 188 of 433 PageID #:15609
35 

Although all of the basement files had the required inventory sheet, only approximately 

15% of the permanent retention files contained the required copy, a violation of the special 

orders. 

In addition, for the 15% of cases where inventory sheets were included in the permanent 

retention files, they were often incomplete or the description of the documents were so generic or 

general so as to be unusable. Items in the Investigative File routinely missing from the permanent 

retention file version of the Investigative File inventory sheets included: 

Handwritten names, addresses, vehicle license plates, phone numbers, physical 

descriptions, dates, unknown abbreviations, symbols, other case numbers, and miscellaneous 

notes found throughout most of the Investigative Files. These types of items were found written 

across official forms, on plain paper, and on file folder covers. Most were not referenced or 

located in any permanent retention file inventories, and may have had value for discovery 

purposes. 

4. Inventories are Missing or Incomplete 

I also noted that documents were often added to the inventory sheet long after they were 

initially created. In some instances, some inventory sheet entries were not created until after an 

offender had been charged. In other files, the dates are either illegible, or do not appear at all. In 

other instances, there are stamped dates, but nothing shown as entered. In other instances, an 

item is shown as entered, but not date or individual entering. In other instances, a large quantity 

of GPRs and supplemental reports were entered all on the same date. Some limited examples: 

D-1922128 

F-048933 

F-380662 

M-587998 

G-268444 

The delay in creating an inventory sheet reveals three problems. One, it again 

demonstrates the amount of discretion that officers could exercise when deciding what to put into 

an Investigative File: if an inventory sheet is only created after an individual is charged, 

detectives can exercise discretion over what they deem relevant at the end of an investigation. 

Second, if the documents are not logged on the inventory sheet until after the charges are 

brought, that indicates that documents are being stored in other, undisclosed locations during the 

course of the investigations, which was precisely the problem the special orders should have 

addressed. Finally, if detectives obtain additional information after charges are brought, there is 

no mechanism in place to update the inventory sheet in the Records Division, or in the inventory 

sheet disclosed (albeit rarely) to criminal defendants. 

5. The basement files show that the “Investigative Files” did not serve as the 

central repository for investigative materials 

The files I reviewed demonstrate that the basement files were not the central repository 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 189 of 433 PageID #:15610
36 

for information. My review of the files revealed numerous cases where information that should 

be included was absent from the basement file, suggesting that it may have been lost or stored in 

separate files. Examples of such missing information include: 

• No explanation on photographs, such as when or where the photo was taken, who/what 

is depicted in the photograph or why the detectives believe it is relevant to the 

investigation. (e.g. Bates 07182; 006121; 008989; 011312; 046887-91). The missing 

information suggests that the paperwork, notes, or other investigative materials that led 

to the photograph were maintained separately from the basement files. 

• Missing reports including ballistic reports, AFIS reports, crime lab reports, CAD and 

911 reports. In some basement files there are reports indicating that the lab was unable 

to find evidence (i.e., fingerprints) that would tie the suspect to the murder (Bates 

0000047); or notations that the case has been cleared – do not resubmit (Bates 0000046); 

or no comparisons (Bates 006082). 

• Missing forms, such as missing property inventories and Major Crime Worksheets. For 

example, M-566742 contains no Major Crimes Worksheet and is representative of many 

of the basement files 

• Other missing forms or documents including missing medical records, missing property 

inventory forms, or missing search warrant affidavits, and missing search warrant 

returns. (e.g. F-229039; G-165272; G-176242; G-259321) 

• Some cases have investigatory computer generated phone records (Bates 006142-47), in 

others they are hand written by an unknown investigator but not included in official 

reports, suggesting that the original source for the phone records was stored separately or 

not properly retained. 

• Blank or missing chain of command homicide review forms (e.g., Bates 211174; 

065188) 

• Many basement files are missing crime scene photos, suggesting that the reports from 

Crime Scene technicians were not included in the basement file. For example, the 

investigation under M-566742 includes an Evidence Report at Bates 047630 that 

documents many different photographs taken of the crime scene. Those photographs do 

not appear in the basement file. 

In some instances, the basement file specifically referenced a piece of evidence, a 

statement, or other information, but the corresponding evidence or statement was not 

documented in the file. 

• References in handwritten notes or documents in file as to the involvement of other units 

or outside agencies, but not included in official reports, and involvement not described 

(e.g. FBI business card – Bates 006149; Letter (in Spanish) from Mexican Consulate – 

Bates 06139-41; Assistant U.S. Attorney business card – Bates 011669) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 190 of 433 PageID #:15611
37 

• No live lineup photos, where there are lineup reports. For example, at Bates 027279-

027281, lineup documents indicate 3 separate lineups 3 separate witnesses for the 

investigation under G-705434, but there are no photographs in the basement file. In 

another case, G-570120, there are lineup photos at Bates 023000-07, but no lineup 

documents appear in the basement file. 

• Reference to other units or outside agencies processing evidence, but no documentation 

in official reports, no results, and no chain of custody. 

• Cryptic handwritten notes with no explanations as to source, relevance, or why included. 

Notes such as “50,000.00 checking acct.” (e.g. Bates 0000091; 2 paragraphs 0000059) 

referring to individuals that may/may not have relevant information. Similarly, 

descriptions of vehicles (Bates 006096). 

• Numerous Xeroxed handwritten spacer/filler pages with A/4-VC; A/1-VC; A/3-VC 

which would indicate other sources for relevant documents that may, or may not, have 

been included (Bates 0000044; 020156; 011326; 011688). Other examples include listing 

detective’s names and unit numbers on Plain pages – or officers from other agencies - 

suggesting that information is coming from other, unidentified sources. (Bates 005586; 

005630; 005701; 006051; 006106). 

The basement files contain only a portion of the investigative materials that, based on my 

experience would typically be included in a comprehensive homicide investigation file.93 And, as 

the examples above demonstrate, in many instances, documents in these basement files make 

explicit reference to documents, notes, or information that are not included in the basement files. 

This is evidence that parallel files related to these investigations were maintained and 

contained additional investigative materials, regardless of what terminology is used to describe 

the files: If the City contends that the basement files are supposed to be Investigative Files as 

defined under the special orders, then, the files demonstrate that other, parallel files were 

maintained containing additional investigative material. If the City contends they are not 

Investigative Files as defined under the special orders, then the basement files are themselves 

examples showing that the parallel file system continued unabated after issuance of the special 

orders. 

Finally, these repeated and consistent failures to properly document and include all 

investigative information within the basement files, demonstrates the CPD’s top down pattern 

and practice of failing to seriously try to correct bad practices or overcome the harmful outcomes 

shown in prior relevant successful litigation against CPD. 



93 Attachment E provides background materials regarding what kinds of investigative 

documents should appear in a homicide investigation, including examples of checklists used 

during criminal investigations. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 191 of 433 PageID #:15612
38 

B. The basement files from the 1999-2006 show that the special orders were not 

followed and that the problem has continued unabated into the 2000s 

According to the spreadsheet provided by Plaintiff’s counsel, there were 340 files in the 

Area 1 Basement filing cabinets from the time period 1999-2006. Based on the spreadsheet, the 

same problems that I observed in the 1980s files were present in this second group of files. 

1. Handwritten notes not on GPRs: 209/340 (approximately 61%) files contained 

handwritten notes, not on GPRs, and without any context about who wrote the note 

and when, which was prohibited by the special orders 

2. To-from memos: 59/340 (approximately 17%) of the Investigative Files from this 

time period contain to-from memos, which were likewise prohibited by the special 

orders 

3. Inventories: 334/340 (approximately 98%) of the Investigative Files contained 

incomplete or missing inventories. 

Unsurprisingly, the street files problem did not solve itself. The City’s failure to meaningfully 

address the problem in the 1980s allowed it to continue unabated into the 2000s. And as 

described above, in Section IV(D), pages 19-23, the continued use of parallel files and failures to 

follow CPD policy resulted in repeated failures to disclose important and relevant information to 

criminal defendants throughout the 2000s. 

C. The basement files confirm that there was no training, auditing, or oversight to 

ensure compliance with CPD’s policies 

These consistent failures to follow the requirements of the special orders reveal that 

detectives were not properly trained on the special orders and that there was no proper 

supervision or oversight to ensure that these special orders were followed.94

Had there been any systematic audit or review of these files, these trends would be 

immediately apparent.95 But a review of the 89 basement files from 1983-1989 also shows no 

signs of an audit or review. Though the CPD had forms designed to facilitate oversight and 

supervision, those forms were routinely missing or blank in the files I examined: 

Homicide File (Chain of Command) Review (some Bates examples at 15511, 41049, 

49240, 65188): This form is designed to document that the chain of command 

responsible for overseeing the investigation and compliance with relevant departmental 

policies and procedures has actually done so. Most of the files that I reviewed either were 

missing the form, had only a single signature, or in the example had no signatures as all. 

That is, there is essentially no documentation of supervisory review in the basement files. 

This demonstrates a willful disregard among supervisors for ensuring that detectives were 

following the policies. 



94 See Section V(B) above, page 32 

95 See Section VI(A)-(B) above, pages 33-38 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 192 of 433 PageID #:15613
39 

Investigative Case File Control (some Bates examples at 5756, 6214, 8990, 1539): Over 

35 of these are missing from criminal defense files. This form is designed to maintain 

case integrity and chain of custody of investigative files. It is common during an 

investigation for a file to be routinely removed for a multitude of legitimate reasons 

(crime lab, consultation with other units, review by prosecutor, court appearances, etc.) 

The case file control form documents the file’s movements so that it is clear whether and 

when information may have been copied or removed. In most of the cases that I reviewed 

they are either missing, have so few entries as to be unbelievable, or have not entries at 

all – an impossibility. This is another critically important form for discovery purposes 

because it should reveal all the individuals that may have contributed to the file, 

including from other divisions or units. The failure to systematically utilize them 

properly, and the concurrent institutional failure to enforce compliance, indicates a 

pattern and practice of indifference to the policies for maintaining Investigative Files. 

Detective Division Personnel Form: This sheet is designed to quickly track and identify 

detective division employees, where they are assigned, working hours, and equipment. It 

does not necessarily account for officers from other units. Regardless, in the majority of 

the cases reviewed, this form is missing altogether. 

Case Assignment Slip (some Bates examples at 5573, 7077, 16653, 20863): The Case 

Assignment Slip is designed to document initial detective(s) assigned and conclusion 

status. These are key individuals to seek out in discovery for depositions. Again, enough 

of these forms are missing to demonstrate a clear pattern and practice of disregard for the 

policy. 

As discussed above, without ongoing monitoring through audits and other means to 

ensure that the new special orders were being followed and that prosecutors and criminal 

defendants were receiving complete disclosures, it was almost certain that the ingrained practice 

of using street files would continue. 

My review of records in this case and others shows that the continuation of the practice, 

including the failure to follow the special orders, was so rampant that it would have been 

confirmed through even a cursory auditing of files. As discussed above, 100% of the 

Investigative Files I reviewed contained evidence that the special orders were not being 

followed, and 90% of defense attorney files were missing information from the Investigative 

File; even superficial audits of small samples of records would have revealed these problems. 

The failure to audit or discipline for non-compliance with the policies signals that the old 

ways – the ways of “street files” that the CPD should have been trying to correct – are 

acceptable. It is not only that best practices require enforcement of special orders to give them 

teeth, but also, in my experience with Internal Affairs, given the circumstances here, strict 

adherence was necessary to create a new culture and practice so that detectives would not 

continue with the ingrained practice of keeping parallel files. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 193 of 433 PageID #:15614
40 

VII. The failure to turn over files in Nathson Fields’ case was a direct result of these 

practices and inadequate policies 

Nathson Fields was convicted of the double murder of Jerome Smith and Talman 

Hickman in 1986. Fields’ conviction was thrown out after a court granted his petition for postconviction relief, but he was re-tried in 2009 and acquitted. He then filed a civil rights lawsuit 

against the City of Chicago in 2010, and during discovery for the civil lawsuit, a file “of over a 

hundred pages of police reports concerning the Smith/Hickman murders were located in a 

nondescript file cabinet at the Area 1 police station, along with files relating to other murders.”96 

The original arrest, trial, conviction, appeals, re-trial, and eventual exoneration of 

Nathson Fields spans a 30-year time period. The volume of police reports, criminal and civil 

court records, and litigation filings pertaining to the matter form tens of thousands of pages. For 

my purposes, it is best summarized by the following: 

Nathson Fields and Earl Hawkins were convicted at a 1986 bench trial before Cook 

County Circuit Court Judge Thomas J. Maloney of the murders two years earlier of Jerome 

Smith and Talman Hickman, members of the Goon Squad, an offshoot of the Black Gangster 

Disciples street gang.97 Fields and Hawkins requested a jury at the sentencing hearing.98 At the 

sentencing hearing, prosecution witness Randy Langston recanted his trial testimony and 

admitted that he never saw the faces of the shooters.99 The jury concluded that both men were 

eligible for the death penalty and Maloney sentenced them to death.100

A year later, a federal prosecutor negotiated a deal under which Hawkins would be 

removed from death row in exchange for testifying against other gang members in unrelated 

cases.

101 Fields remained on death row. Then, in 1993, Judge Maloney was convicted on federal 

charges of, among other things, accepting a $10,000 bribe from a corrupt lawyer named William 

Swano to acquit Hawkins of murdering Smith and Hickman.102 When Maloney learned that he 

was under investigation by the FBI, he returned the money to Swano and proceeded to convict 

Hawkins, as well as his co-defendant Fields.103

In light of Maloney’s conviction, a state court judge ordered a new trial for Fields in 

1996.104 While the retrial was pending, a second key witness in the case named Gerald Morris 

recanted. Along with Randy Langston, Morris had testified at the 1986 trial that he had seen 

Fields and Hawkins shoot Smith and Hickman outside a public housing project on April 28, 

1984. But in their new affidavits Morris and Langston stated that police and prosecutors had 



96 Fields v. City of Chicago, Memorandum Opinion and Order, [Document # 483] page 2 

97 Ibid. p. 2-3 

98 Ibid p. 3-4 

99 Ibid p. 4 

100 Ibid p. 4 

101 Ibid p. 4-5 

102 Ibid p. 3 

103 Ibid p. 4 

104 Ibid p. 5 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 194 of 433 PageID #:15615
41 

coerced them to falsely identify Fields and Hawkins. According to the affidavits, Morris and 

Langston had no idea who killed Smith and Hickman because the killers had worn masks. 

Despite the recantations, rather than dropping the charges prosecutors made a deal with 

Hawkins under which he would testify against his former co-defendant. got Randy Langston and 

Gerald Morris105 to recant their recantations. Fields remained in custody until 2003 when he 

was released on bond.106

On-going appeals by the prosecution delayed the Fields retrial another six years,107 but 

when it finally occurred Judge Gaughan found Hawkins and the two other witnesses unworthy of 

belief. Fields was acquitted.108

I have familiarized myself with the underlying facts in the Fields case, and have reviewed 

the various sets of police files produced to Mr. Fields at different times during his criminal case 

and during this civil litigation, including (a) the permanent retention file (CITY-NF-07531-

07558), and the two new files disclosed to Mr. Fields in 2011 during this litigation: (b) the file 

produced by the City, which was located in a CPD warehouse (CITY-NF-07559-07652) 

(hereinafter the “warehouse file”), and (c) a file found in the filing cabinet in the basement of 

Area 1 (CITY-NF-001023-CITY-NF-001117) (hereinafter the “basement file”). 

The City has admitted that it “does not know where the [basement file] was maintained 

after June 1984 until it was located in Area 1 after the filing of this case in 2010.”109 In fact, Mr. 

Fields filed an earlier lawsuit in 1988 looking for additional files related to the Hickman/Smith 

murders, and the Chicago Police Department opened an internal investigation.110 But the 

investigator assigned to the case wrote a memorandum stating that, although he received the 

“complete investigative package which was recorded under RD number F-151922 which 

concerns the Talman HICKMAN and Jerome SMITH Homicides . . . it was noted that the ‘Street 

Files’ were not included in the investigative file.”111 Ultimately, this CPD investigation was 

“unable to establish the existence of any ‘Street Files’ connected with the HICKMAN & SMITH 

homicides.”112 

 

Then, in response to a 1991 subpoena requesting all documents related to the 

Smith/Hickman murders, Fred Miller, Commander of Area 1 stated ‘There are no documents on 

file at Detective Division One pertaining to the above subject.”113

Nonetheless, over 100 pages were located in 2011 in the basement file found at Area 1. 



105 Morris later recanted yet a third time and provided an extensive affidavit outlining the years 

of coercion by police and prosecutors to obtain his cooperation in testifying against Fields. 

106 Fields v. City of Chicago, Memorandum Opinion and Order, [Document # 483] page 5 

107 Ibid. 

108 Ibid p. 6 

109 City’s Third Amended Answer to Interrogatories 4 and 5, page 2. 

110 City’s Third Amended Answer to Interrogatories 4 and 5, page 8-9. 

111 City’s Third Amended Answer to Interrogatories 4 and 5, page 9. 

112 City’s Third Amended Answer to Interrogatories 4 and 5, page 9. 

113 City’s Third Amended Answer to Interrogatories 4 and 5, page 8. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 195 of 433 PageID #:15616
42 

Those files were disclosed to Mr. Fields for the first time in this litigation.114 It is clear, then, that 

the undisclosed Fields basement file is caused by, and additional evidence of, the street files 

problem, that is, a parallel file unaccounted for by CPD and not disclosed despite repeated, 

specific requests. 

The documents newly produced in the basement file, which were not contained in any of 

the earlier files, include handwritten notes, memos, and other documents identifying multiple 

alternate suspects and potential leads demonstrating that Nathson Fields was not involved in the 

Hickman and Smith homicides. In fact Nathson Fields name was never mentioned as a possible 

suspect in any of these documents. Below are some examples of documents in the basement file, 

which were withheld from Mr. Fields and which contained relevant investigative information: 

• CITY-NF-000972-1027: Identification photographs of alternate suspects and witnesses, 

with handwritten notes identifying the pictures 

• CITY-NF-001029: Undated handwritten notes regarding a check for a 9 mm handgun 

related to other homicides 

• CITY-NF-001030: Undated handwritten note regarding the wife of Talman Hickman, 

Margot Hickman 

• CITY-NF-001035; 001037: Undated handwritten notes regarding what appear to be 

descriptions of the perpetrators 

• CITY-NF-001038: Request for identification photos of three possible suspects 

• CITY-NF-001039-40: Undated handwritten note related to Lawrence and Marshall 

Edwards, possible alternate suspects, including a statement that a witness heard them 

talking about “killing Fuddy” because of a previous shooting. The notes also state that a 

witness saw them at about 9:00 in the morning talking, and Lawrence said he’d get a gun, 

and they would put on masks, and he wouldn’t live through the night, and then he “won’t 

be jumping on you anymore.” 

• CITY-NF-001041: Undated handwritten note regarding an anonymous call reporting that 

“Ronald” and “Donald,” who were “Stones” were the driver and passenger of the vehicle 

used to commit the crime 

• CITY-NF-001042: Undated handwritten note regarding comparisons of all 9mm guns 

that are suitable for comparison to identify the gun used during the shooting 

• CITY-NF-001043: Undated handwritten note referencing “Delbert Edwards” and his IR 

number (which is used to locate an individual’s criminal history) with no additional 

context. A criminal history report for Delbert Edwards is also included in the file at 

CITY-NF-001067. According to a Supplemental Report, Delbert Edwards was also shot 

at by members of the Goon Squad, and would have had a motive to retaliate, but officers 

claimed to have verified his alibi with his family members. (CITY-NF-001050-51) (See 

also, CITY-NF-001086-88 arrest report from the shooting at Edwards the night prior to 

the H/S homicides and the arrests of two Goon Squad members). 

• CITY-NF-001052: Notes from an anonymous tip that “Black P Stones” gang was 

involved in the crime which also provided a description and information regarding a 

suspect. A handwritten note states “Steve, need report by 11Jun84” 

• CITY-NF-001053- 001059: Report and rap sheet for an individual arrested with drugs 



114 Fields v. City of Chicago, Memorandum Opinion and Order, page 2. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 196 of 433 PageID #:15617
43 

within a few days of the homicide in the area of the homicide and in a similar car as the 

getaway car 

• CITY-NF-001061: Undated handwritten note regarding Simeon Johnson, aka Cameo, 

Joseph Fritz, and John Rogers, with contact information and identifying features. The 

note does not provide any additional context for how these individual relate to the 

investigation, but an April 29, 1984 General Progress Report appears to describe 

interviews of Fritz and Rogers, in which Fritz reported that a man named Simeon owns a 

blue Cadillac, similar to the one used in the crime. Fritz also reported that he “heard that 

stones wearing masks killed some goons.” (CITY-NF-001113). Officers apparently asked 

Rogers about his whereabouts the night of the murder, and Rogers reported visiting 

various family members. (CITY-NF-001113). 

• CITY-NF-001062: Undated handwritten note regarding mother of Ricky Baldwin, a man 

who was killed by a member of the Goon Squad (Jimmie Greene) in a previous shooting. 

The note suggests a possible motive for Hickman and Smith murders: namely that 

another Baldwin was seeking reprisal for Ricky Baldwin’s death. The note also 

references “Chico” and “Cameo” without further description. Several criminal histories 

and arrest reports related to various members of the Baldwin family appear throughout 

the file: CITY-NF-001065-66 (Paul Baldwin); CITY-NF-001071 (Shawn Baldwin); 

CITY-NF-001073 (Timothy Baldwin); Greg (aka Chico) cousin of Ricky Baldwin with 

description of Greg (CITY-NF-001108). 

• CITY-NF-001069-70: April 29, 1984 General Progress Report describes an anonymous 

call implicating Rodell Banks in the shooting; and an arrest card for Rodell Banks is also 

included in the file. 

• CITY-NF-001075: Undated to-from memo between detectives describing an interview 

with 14-year-old James Langston, who was playing ball across the street and said 

offenders were wearing skullcaps to conceal their identities. Identifies Ricky Baldwin as 

a passenger in the car used to carry out the killings. The memo also discusses an 

interview with Sandra Langston who described both offenders as having a light 

complexion. 

• CITY-NF-001076: Undated handwritten note regarding Carlos Willis and John “Bay 

Rogers” without additional context or explanation of their connection to the investigation. 

• CITY-NF-001077: Typed to-from memo between detectives describing anonymous call 

implicating Edward Stewart as the driver of the vehicle used in the murder, and stating 

that Stewart was with “Chico” and Darryl Baldwin. The memo also describes detectives’ 

efforts to locate Edward Stewart and Chico, and to identify Chico’s real name. 

• CITY-NF-001085: Undated handwritten note referencing “Chico” and “Poncho” and 

possible addresses, with no additional context or description. 

• CITY-NF-001100-06: photos of possible suspect Edward Stewart, arrest report showing 

an inquiry issued on day of H/S homicides, arrests reports and rap sheets. 

• CITY-NF-001107-09: Efforts to identify individuals with the name of “Chico.” Arrest 

cards list Damien Prince and Martel Ray (or “Mertel Rey”). A handwritten note states 

that “Chico” = Greg, cousin to a Baldwin 

• CITY-NF-001112: May 1, handwritten General Progress Report referencing Clifford 

Marshall and Lawrence Edwards, as possible suspects and discussing the Edwards’ 

brothers possible alibis. Also references Darryl Baldwin with “Chico” and efforts to 

verify their alibi. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 197 of 433 PageID #:15618
44 

• CITY-NF-001113: April 29, 1984.handwritten General Progress Report from Detective 

Minogue discussing what appears to be an interview of a possible witnesses or suspects 

Joseph Fritz and John Rogers. 

• CITY-NF-001114: arrest report for individual who associated with Martel Ray. 

• CITY-NF-001116: Undated handwritten note regarding an anonymous tip that said 

Edward Stewart was the driver of the vehicle used in the commission of the murders and 

that Darryl Baldwin and Chico were with him. Contact information for girlfriend of 

Baldwin- Olivia Wallace. (The basement file contains other information regarding 

Wallace, including her rap sheet CITY-NF-001109-001110) 

• CITY-NF-001117: Undated printout related to a Mark Brown with no additional context. 

His name also appears on pages CITY-NF-001063-64. 

As the list above reveals, the basement file demonstrates the same problems observed in the 

set of 89 basement files. There are numerous handwritten notes, not on GPRs, which are 

undated, unsigned, and provide no context. As these notes demonstrate, detectives often wrote 

names of alternate suspects or important witnesses on blank pages, with no additional context. 

Detectives also communicated important information about witnesses and alternate suspects in 

to-from memos between detectives. This information was not transcribed into the official 

reports. Finally, the basement file contains no inventory sheet. 

 The basement file is not the only file that was not turned over to Mr. Fields. As 

explained above, the City also produced for the first time a file containing investigative materials 

related to the Smith and Hickman murders that was located in the warehouse. Notably, this file 

did not include any of the handwritten notes or to-from memos between detectives. This is a 

prime example of the use of multiple, parallel files, in addition to the permanent retention file, 

which are stored separately, and make no reference to one another. 

 This file, too, suffers from the same systemic problems observed in the basement files as 

a whole: Although there is an inventory sheet in the warehouse file, it is incomplete. (CITY-NF7560-61). It lists only 8 pages of GPRs and makes no reference of the 100 pages that were in the 

basement file and in any event was not contained in any of the defense attorneys’ files or the 

permanent retention file. The warehouse file also includes relevant investigative information. 

There is a criminal history report for Henry Adams, who was potentially also involved in the 

murder (CITY-NF-07632), and a handwritten note documenting negative results from a request 

to compare the gun used in the Smith and Hickman homicide against a firearm used in another 

homicide. (CITY-NF-07613). 

The documents in the basement and warehouse files are highly relevant to the 

investigation, implicate multiple alternate suspects, and suggest potential witnesses, vehicles 

used in the crime, and items of physical evidence. These documents should have been produced 

to Mr. Fields before his original criminal trial in 1986 (and at every other point at which he 

engaged with the criminal justice system after that). These documents would have been produced 

under generally accepted police practices related to creating, retaining, and disclosing 

investigative materials. 

 Finally, these files suggest that there may be yet more investigative materials that have 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 198 of 433 PageID #:15619
45 

not been disclosed. For example, in the to-from memo relating to the interview with James 

Langston (CITY-NF 001075) the memo says “see our notes for more details.” Those notes do 

not appear in the files that have been disclosed to Mr. Fields. Similarly, a report of an 

anonymous tip includes a statement “Steve, need report by 11Jun84,” (CITY-NF-001052) but 

there is no report corresponding to that request in the files. The files that have now been located 

and disclosed provide no indication of how many additional files may exist, or where to locate 

them. This inability to determine where all relevant materials are stored is a direct result of the 

failure to follow standard police practice of creating a single, comprehensive file for an 

investigation. 

Concluding Statement 

I have provided my opinions based upon my training, experience, and after a careful 

evaluation of the totality of circumstances in this matter. I utilized all of the facts and data known 

to me, and applied generally accepted police management principles and methods. I have 

concluded that CPD had deficient policies related to creating, maintaining, and disclosing 

investigative materials, and further that there was a widespread practices of keeping multiple, 

parallel files for single investigation. As a result of those deficient policies and widespread 

practice, criminal defendants were routinely denied substantive and relevant investigative 

materials related to their criminal cases. The files withheld from Mr. Fields during his criminal 

trial were withheld as a result of the same set of practices and policies (or lack thereof), and 

contained relevant and important investigative materials that should have been disclosed under 

standard police procedures. 

In sum, it is my professional opinion to a reasonable degree of professional certainty in 

the law enforcement community, and based on longstanding and well-accepted law enforcement 

practices, that the defendants engaged in a pattern and practice of routinely failing to disclose 

material in criminal cases to defendants that should have been disclosed, These failures to 

disclose exculpatory and impeachable information was well outside the norm that law 

enforcement officials and institutions know needs to be disclosed. 

I reserve the right to supplement or modify this report and my opinions expressed in the 

report to the extent that additional information is presented to me and to the extent permitted by 

rules.

Pursuant to 28 U.S.C Section 1746, I declare under penalty of perjury that the 

foregoing is true and correct. 

Michael D. Brasfield 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 199 of 433 PageID #:15620
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT A 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 200 of 433 PageID #:15621
1 

Attachment A - Court Experience

Report of Plaintiff’s Expert – Michael D. Brasfield 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

Compliance with Federal Rule of Procedure 26 (a) (2) (B) 

Testimony at Trial or Deposition for Preceding Four Years

I have either testified at trial or deposition as an expert witness equally for defendants and 

plaintiffs in Federal, State, and Local Courts. These appearances have been in both civil and 

criminal matters. I have appeared in Federal District Courts in Fort Lauderdale, Miami, Seattle, 

Tacoma, Spokane, and Chicago. I have also appeared in State Courts in Florida, Pennsylvania, 

Arizona, Alaska, and Washington. These civil litigation cases have involved all types of police 

procedures and practices and have included the use of force; police pursuits; deadly force; incustody deaths, negligent selection, training, and retention; as well as class action and Federal 

“1983” civil rights cases. 

Under Federal Rule of Civil Procedure 26, I have listed the following specific cases that I have 

provided testimony at deposition or trial as an expert witness in the last four years: 

• In the United States District Court (Northern District of Illinois, Eastern Division) – 

James Kluppelberg v. City of Chicago – Cause No. 13-CV-3963 – For Plaintiff – 42 

USC, 1983 – Wrongful Conviction. 

• In the United States District Court (Eastern District of Washington) – Goehring v. City of 

Kennewick – Cause No. 4:14-CV-5104-RMP – For Defendant – Violation of Civil 

Rights. 

• In the United States District Court (Northern District of Illinois, Eastern Division) – Deon 

Patrick v. City of Chicago – Cause No. 14C-3658 – For Plaintiff – 42 USC, 1983 – 

Wrongful Conviction. 

• In the United States District Court (Northern District of Illinois, Eastern Division) – 

Percy Coleman v. City of Chicago – Cause No. 12C-10061 – For Plaintiff – 42 USC, 

1983 – Wrongful Death. 

• In the Superior Court for the State of Alaska (Anchorage) – Boshears v. State of Alaska –

Cause No. 3AN-13-07970CI – For Plaintiff – Negligence of Duty. 

• In the Court of Common Pleas of Allegheny County, Pennsylvania – Commonwealth of 

Pennsylvania v. Leon Ford – Cause No. CC201303273 – For Defendant - Multiple 

criminal charges. 

• In the United States District Court (Western District of Washington) – Theoharis v. 

Rongen – Cause No. 2:13-cv-01345-RAJ – For Plaintiff – 42 USC, 1983 – Excessive and 

Unreasonable Force and Unreasonable Search and Seizure. 

• In the United States District Court (Eastern District of Washington) - Thoma v. City of 

Spokane – Cause No. CV-12-156-EFS – For Defendant – 42 U.S.C. – 1983. 

• In the United States District Court (Eastern District of Washington) – Duncan v. Liberty 

Lake – Cause No. 2:2012cv00219 – For Defendant – Violation of Civil Rights. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 201 of 433 PageID #:15622
2 

• In the United States District Court (Northern District of Illinois, Eastern Division) – April 

Ortiz v. City of Chicago – Cause No. 04-CV-7423 – For Plaintiff – 42 USC, 1983 - 

Denial of Medical Care. 

• In the Superior Court of the State of Washington (Spokane County) – Glidden v. City of 

Spokane Valley, et al. – Cause No. 11-2-04437-2 – For Defendant – Police Shooting - 

Negligent training, supervision, retention. 

• In the United States District Court (Eastern District of Washington) – Creach v. Spokane 

County, et al. – Cause No. 2:2011cv00432 – For Defendant – 42:1983 Civil Rights Act. - 

Fatal shooting by police officer. 

In addition, I have provided my expert opinion, reviewed, consulted, or been retained in civil 

litigation related matters for plaintiffs and defense attorneys or governmental entities over 50 

times in the last 10 years in Riverside County (CA), Trinity County (CA), Prescott County (AZ), 

Chicago (IL), Garland (TX), Bradley County (TN), Hazard (KY), Clallam County (WA), 

Franklin County (WA), Reno (NV), Unalakleet (AK), Whatcom County (WA), Albany (OR), 

Jackson (MS), Seattle (WA), Columbia (SC), and Sweetwater County (WY). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 202 of 433 PageID #:15623
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT B 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 203 of 433 PageID #:15624
1 

Attachment B - Report of Material Reviewed

Report of Plaintiff’s Expert – Michael D. Brasfield 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

I have been provided and reviewed the following documents and materials concerning this case: 

General Case Material

• 437. Plaintiff’s Local Rule 56.1 Statement of Facts.pdf 

• 483. Memorandum Opinion and Order on Summary Judgment.pdf 

• 812. Memorandum Opinion and Order granting new tiral.pdf 

• City’s Third Amended Answer to Interrogatories 4 and 5.pdf 

• CITY-NF-000972-001117 Fields Street File produced 2011.pdf 

• City-NF-07531-07558 - Fields permanent retention file.pdf 

• City-NF-07559-07652 - Fields Area File.pdf 

• Letter from City re Production of permanent retention file and Area File.pdf 

• 2016.01.26 Document Production.pdf 

• 2016.01.29 Plaintiff’s Supplemental Monell Disclosures.pdf 

• AUSA discovery letter - Fields 01289-01296.pdf 

• Page from G483470 Michael McMillan [Crim.Def Files – Fields 044680-045057].pdf 

• Chicago Police Department Special Orders 

o Chicago Police Department Teletype 

o Detective Division Notice 82-2 

o Special Order 83-1 

o Special Order 83-2 

o Special Order 86-3 

o Standard Operating Procedure 1988 

• Jones v. City of Chicago, 856 F.2d 985, 988 (7th Circuit 1988) 

• Palmer v. City of Chicago, Case No. 82C 2349 

• James Hickey deposition, Rivera v. Guevara (5/6/14) 

• James Hickey deposition, Rivera v. Guevara (6/10/14) 

• James Hickey deposition, Kluppelberg – Part 1 (7/29/2014) 

• James Hickey deposition, Kluppelberg – Part 2 (7/31/2014) 

• James Hickey deposition, Kluppelberg (6/9/2015) 

• Kathleen Loughran deposition (6/6/2012) 

• Fields Spreadsheet.xlsx (spreadsheet) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 204 of 433 PageID #:15625
2 

Basement Files (1983-1989)

• E-010765 (SSN only).pdf (95 pages) – Cecil Robinson 

• E-399564 (SSN only).pdf (207 pages) - Serafin Flores 

• F-048933 (SSN only).pdf (129 pages) - Christino Garcia 

• F-380662 (SSN only).pdf (123 pages) - Lindsey Cannon 

• G-011889 (SSN only).pdf (75 pages) - Earl Stademeyer 

• G-014815 (SSN only).pdf (128 pages) - Guy Johns 

• G-108642 (SSN only).pdf (122 pages) - Roscoe Evans 

• G-148403 (SSN only).pdf (187 pages) - Derrick Johnson 

• G-159857 (SSN only).pdf (351 pages) - Jeffrey Boyd 

• G-165272.pdf (156 pages) - William Goodin 

• G-215280 (ACB 090389-090455) received 9.21.15.pdf (67 pages) - Maurice Green 

o G-215280 (SSN only).pdf (132 pages) - Maurice Green 

o G-215280A (SSN only).pdf (71 pages) - Maurice Green 

• G-248336 (SSN only).pdf (167 pages) - Ruben Avilez 

• G-257089 (SSN only).pdf (50 pages) - Freddy Brown 

• G-267826 (SSN only).pdf (115 pages) - James Walker 

• G-284291 (SSN only).pdf (90 pages) - Lucille Pye 

• G-321886 (SSN only).pdf (159 pages) - James Crockett 

• G-446754 (SSN only).pdf (48 pages) - Edward Terrett 

• G-456900 (SSN only).pdf (51 pages) - Larry Buchanan 

• G-468726 (SSN only).pdf (148 pages) - Albert Spraggins 

• J-381525 (redacted).pdf (85 pages) - Albert Buckles 

• J-418229 (redacted).pdf (204 pages) - Mervyn Wright 

• M-566742 (redacted).pdf (52 pages) - Fredy Roberson 

• M-568-343 (redacted).pdf (85 pages) - Steve Jones 

• M-569-727 (redacted).pdf (38 pages) - John Avery 

• M-580-592(redacted).pdf (147 pages) - David Duarte 

• M-587998(redacted).pdf (96 pages) - Tony Allen 

• M-590700 (SSN only).pdf (95 pages) - Ricky Icenberg 

• E-026792.pdf (142 pages) 

• E-221919 (SSN only).pdf (38 pages) 

• E-277036 (SSN only).pdf (122 pages) 

• E-348611(SSN only).pdf (41 pages) 

• E-395970 (SSN only).pdf (166 pages) 

• E-442815 (SSN only).pdf (153 pages) 

• E-475100 (SSN only).pdf (105 pages) 

• F-172852 (SSN only).pdf (46 pages) 

• F-177096 (SSN only).pdf (81 pages) 

• F-229020 (ACB 090456-090615).pdf (160 pages) 

• F-229039 (SSN only).pdf (26 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 205 of 433 PageID #:15626
3 

• F-277122 (SSN only).pdf (193 pages) 

• F-299912 (SSN only)-.pdf (100 pages) 

• F-308281 (SSN only).pdf (68 pages) 

• F-336114 (SSN only).pdf (156 pages) 

• F-430186 (SSN only).pdf (50 pages) 

• F-445484 (SSN only).pdf (93 pages) 

• F-492465 (SSN only).pdf (225 pages) 

• G-011265 (SSN only).pdf (82 pages) 

• G-027619 (SSN only).pdf (60 pages) 

• G-032161 (SSN only).pdf (35 pages) 

• G-049257 (SSN only).pdf (22 pages) 

• G-051225 (SSN only).pdf (70 pages) 

• G-056199 (SSN only).pdf (31 pages) 

• G-087375 (SSN only).pdf (428 pages) 

• G-106586 (SSN only).pdf (99 pages) 

• G-156178 (SSN only).pdf (72 pages) 

• G-176242 (SSN only).pdf (82 pages) 

• G-192900 (SSN Only).pdf (75 pages) 

• G-230261 (SSN only).pdf (91 pages) 

• G-235180 (SSN only).pdf (42 pages) 

• G-245282 (SSN only).pdf (90 pages) 

• G-265171 (SSN only).pdf (58 pages) 

• G-267631 (SSN only).pdf (49 pages) 

• G-267820 (SSN only).pdf (31 pages) 

• G-278643 (SSN only).pdf (115 pages) 

• G-283147 (SSN only).pdf (72 pages) 

• G-289217 (SSN only).pdf (40 pages) 

• G-303402 (SSN only).pdf (75 pages) 

• G-322101 (SSN Only).pdf (74 pages) 

• G-331216 (SSN only)-.pdf (93 pages) 

• G-354748 (SSN only).pdf (78 pages) 

• G-356930 (SSN only).pdf (88 pages) 

• G-385135 (SSN only).pdf (76 pages) 

• G-401782 (SSN only).pdf (59 pages) 

• G-405711 (SSN only).pdf (4 pages) 

• G-482955 (SSN only).pdf (296 pages) 

• G-483470 (SSN Only).pdf (109 pages) 

• G-501974 (SSN only).pdf (38 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 206 of 433 PageID #:15627
4 

• H-024109 (SSN only).pdf (126 pages) 

• H-024109A (SSN only).pdf (163 pages) 

• H-349049 (SSN only).pdf (63 pages) 

• H-435581 (SSN only).pdf (35 pages) 

• H-465-163 (SSN only).pdf (324 pages) 

• J-486857 (redacted).pdf (53 pages) 

• J-510242 (redacted).pdf (147 pages) 

• K-300724 (redacted).pdf (84 pages) 

• K-562024 (redacted).pdf (189 pages) 

• M-139566 (redacted).pdf (68 pages) 

• M-510-728 (redacted).pdf (49 pages) 

• M-534-290 (redacted).pdf (136 pages) 

• M-539-997 (redacted).pdf (64 pages) 

• M-544-975 (redacted).pdf (36 pages) 

Criminal Defense Files (1983 – 1989)

• E010765 Cecil Robinson [Criminal Defense Files- Fields 037006-037317].pdf (312 

pages) 

• E399564 Serafin Flores [Criminal Defense Files - Fields 037318-038152].pdf (835 

pages) 

• F048933 Christino Garcia [Criminal Defense Files - Fields 038153-038760].pdf (608 

pages) 

• F380662 Lindsey Cannon [Criminal Defense Files - Fields 038761-040854].pdf (2094 

pages) 

• G011889 Earl Stademeyer [Criminal Defense Files - Fields 040855-041128].pdf (274 

pages) 

• G014815 Guy Johns [Criminal Defense Files- Fields 047420-048462].pdf (1043 pages) 

• G108642 Roscoe Evans [Criminal Defense Files - Fields 041244-041624].pdf (381 

pages) 

• G148403 Derrick Johnson [Criminal Defense Files - Fields 041625-042235].pdf (611 

pages) 

• G159857 Jeffrey Boyd [Criminal Defense Files-Fields 017841-025177].pdf (7337 pages) 

• G165272 William Goodin [Criminal Defense Files – Fields 042341-042438].pdf (98 

pages) 

• G215280 Maurice Green [Criminal Defense Files - Fields 042439-042974].pdf (536 

pages) 

• G248336 Ruben Avilez [Criminal Defense Files - Fields 042975-043172].pdf (198 

pages) 

• G257089 Freddy Brown [Crim. Def Files - Fields 043173-043273].pdf (101 pages) 

• G267826 James Walker [Criminal Defense Files - Fields 042236-042340].pdf (105 

pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 207 of 433 PageID #:15628
5 

• G284291 Lucille Pye [Criminal Defense Files - Fields 043274-043381].pdf (108 pages) 

• G321886 James Crockett [Criminal Defense Files - Fields 043388-043654].pdf (267 

pages) 

• G446754 Edward Terrett [Criminal Defense Files - Fields 043655-043867].pdf (213 

pages) 

• G456900 Larry Buchanan [Criminal Defense Files - Fields 043868-044026].pdf (159 

pages) 

• G468726 Albert Spraggins [Criminal Defense Files - Fields 044027-044386].pdf (360 

pages) 

o G468726 Maurice Spraggins [Criminal Defense Files - Fields 044387-

044679].pdf (293 

o pages) 

• J381525 Albert Buckles [Criminal Defense Files - Fields 045066-045473].pdf (408 

pages) 

• J418229 Mervyn Wright [Criminal Defense Files - Fields 048463-049562].pdf (1100 

pages) 

• M566742 Fredy Roberson [Criminal Defense Files - Fields 045589-045823].pdf (235 

pages) 

• M568343 Steve Jones [Criminal Defense Files - Fields 049563-050435].pdf (873 pages) 

• M569727 John Avery [Criminal Defense Files - Fields 045824-046184].pdf (361 pages) 

• M580592 David Duarte [Criminal Defense Files - Fields 050436-051863].pdf (1428 

pages) 

• M587998 Tony Allen [Criminal Defense Files - Fields 046185-047419].pdf (1235 pages) 

• M590700 Ricky Icenberg [Criminal Defense Files - Fields 051864-052616].pdf (753 

pages) 

•

Permanent Retention Files (1983-1989)

• E010765 CITY-permanent retention file-00472.pdf (41 pages) - Cecil Robinson 

• E399564 CITY-permanent retention file-00720.pdf (69 pages) - Serafin Flores 

• F048933 CITY-permanent retention file-00856.pdf (30 pages) - Christino Garcia 

• F380662 CITY-permanent retention file-01040.pdf (40 pages) - Lindsey Cannon 

• G011889 CITY-permanent retention file-01212.pdf (27 pages) - Earl Stademeyer 

• G014815 CITY-permanent retention file-01239.pdf (51 pages) - Guy Johns 

• G108642 CITY-permanent retention file-01412.pdf (39 pages) - Roscoe Evans 

• G148403 CITY-permanent retention file-01452.pdf (40 pages) - Derrick Johnson 

• G159857 CITY-permanent retention file-01514.pdf (89 pages) - Jeffrey Boyd 

• G159857.pdf (62 pages) / CITY-NF-001682 - Jeffrey Boyd 

• G215280 CITY-permanent retention file-01706.pdf (41 pages) - Maurice Green 

• G248336 and G248696 CITY-permanent retention file-01846.pdf (48 pages) - Ruben 

Avilez 

• G257089 CITY-permanent retention file-01895.pdf (15 pages) - Freddy Brown 

• G267826 CITY-permanent retention file-01962.pdf (25 pages) - James Walker 

• G284291 CITY-permanent retention file-02017.pdf (21 pages) - Lucille Pye 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 208 of 433 PageID #:15629
6 

• G321886 CITY-permanent retention file-02079.pdf (50 pages) - James Crockett 

• G446754 CITY-permanent retention file-02317.pdf (17 pages) - Edward Terrett 

• G456900 CITY-permanent retention file-02335.pdf (11 pages) - Larry Buchanan 

• G468726 CITY-permanent retention file-02346.pdf (40 pages) - Albert Spraggins 

o G468726 CITY-permanent retention file-02386.pdf (2 pages) - Albert Spraggins 

• J381525 CITY-permanent retention file-02914.pdf (27 pages) - Albert Buckles 

• J418229 CITY-permanent retention file-02941.pdf (34 pages) - Mervyn Wright 

• M566742 CITY-permanent retention file-03327.pdf (20 pages) - Fredy Roberson 

• M568343 CITY-permanent retention file-03347.pdf (45 pages) - Steve Jones 

• M569727 CITY-permanent retention file-03392.pdf (18 pages) - John Avery 

• M580592 CITY-permanent retention file-03410.pdf (57 pages) - David Duarte 

• M587998 CITY-permanent retention file-04100.pdf (50 pages) - Tony Allen 

• M590700 CITY-permanent retention file-03467.pdf (48 pages) - Ricky Icenberg 

Basement Files (1999-2006) 

• D-192218 (SSN only).pdf (205 pages) - Steven Spears 

• D-579065 (SSN only).pdf (121 pages) - Jimmy Velasquez 

• G-032399 (SSN only).pdf (213 pages) - Diante Wiley 

• G-259321 (SSN only).pdf (86 pages) - Kevin Jackson 

• G-266841 (SSN only).pdf (24 pages) - Timothy Malone 

o G-266841A (SSN only) 2.pdf (125 pages) - Timothy Malone 

• G-268444 (SSN only).pdf (254 pages) - Isaiah Brady 

• G-326467 (SSN only).pdf (309 pages) - George Frison 

• G-406405 (SSN only).pdf (290 pages) - Santana McCree 

• G-570120 (SSN only).pdf (210 pages) - Crisino Bravo 

• G-705434 (SSN only).pdf (236 pages) - Norman McIntosh 

• HH-175723 (abc).pdf (169 pages) - Maurice Brown 

• HH-358668 (SSN only).pdf (288 pages) - Christopher Peoples 

• HH-749335 (abc).pdf (180 pages) - Devon Terrell 

• HJ-102484 (SSN only).pdf (273 pages) - Anthony Houston 

• HJ-366143 (abc).pdf (227 pages) - Leviante Adams 

• HJ-492443.pdf (def).pdf (453 pages) - Octavia Anima 

• HK-211174 (SSN only) .pdf (176 pages) - Lakesha Collins 

• HK-406407 (SSN only).pdf (207 pages) - Delvie Turpin 

• HK-416661 (SSN only).pdf (195 pages) - Donell Johnson 

• HK-449083 (SSN only).pdf (272 pages) - Jamell Murphy 

• HK-470751 (abc).pdf (235 pages) - Verna Colbert 

• HK-593970 (abc).pdf (277 pages) - Tharine Partee 

• HK-639684 (abc).pdf (350 pages) - Devon Terrell 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 209 of 433 PageID #:15630
7 

Criminal Defense Attorney Files (1999 - 2006)

• D192218 Steven Spears [Criminal Defense Files - Fields 000001-0000421] Redacted.pdf 

(421 pages) 

• D579065 Jimmy Velasquez [Criminal Defense Files - Fields 000422-001231] Redacted.pdf 

(810 pages) 

• G032399 Diante Wiley [Criminal Defense Files - Fields 001232-002099] Redacted.pdf 

(868 pages) 

• G259321 Kevin Jackson [Criminal Defense Files - Fields 002100-004383] Redacted.pdf 

(2284 pages) 

• G266841 Timothy Malone [Criminal Defense Files - Fields 004384-005802].pdf (1419 

pages) 

• G268444 Isaiah Brady [Criminal Defense Files - Fields 025178-027518].pdf (2341 pages) 

• G326467 George Frison [Criminal Defense Files - Fields 005803-006593] Redacted.pdf 

(791 pages) 

• G406405 Santana McCree [Criminal Defense Files - Fields 006594-007411] Redacted.pdf 

(818 pages) 

• G570120 Crisino Bravo [Criminal Defense Files - Fields 027519-027637].pdf (119 pages) 

• G705434 Norman McIntosh [Criminal Defense Files - Fields 007412-008058] 

Redacted.pdf (647 pages) 

• HH175723 Maurice Brown [Criminal Defense Files - Fields 008059-008565] Redacted.pdf 

(507 pages) 

• HH358668 Christopher Peoples [Criminal Defense Files - Fields 008566-008893] 

Redacted.pdf (328 pages) 

• HH749335 Devon Terrell [Criminal Defense Files - Fields 008894-009730] Redacted.pdf 

(837 pages) 

• HJ102484 Anthony Houston [Criminal Defense Files - Fields 027638-029307].pdf (1670 

pages) 

• HJ366143 Leviante Adams [Criminal Defense Files – Fields 009731-010034] Redacted.pdf 

(304 pages) 

• HJ492443 Octavia Anima [Criminal Defense Files - Fields 010035-013762] Redacted.pdf 

(3728 pages) 

• HK211174 Lakesha Collins [Criminal Defense Files - Fields 013763-014757] 

Redacted.pdf (995 pages) 

• HK406407 Delvie Turpin [Criminal Defense Files - Fields 029337-029344].pdf (8 pages) 

• HK416661 Donell Johnson [Criminal Defense Files - Fields 014758-015021] Redacted.pdf 

(264 pages) 

• HK449083 Jamell Murphy [Criminal Defense Files - Fields 052617-057745].pdf (5129 

pages) 

• HK470751 Verna Colbert [Criminal Defense Files - Fields 029345-036948].pdf (7604 

pages) 

• HK593970 Tharine Partee [Criminal Defense Files - Fields 015022-015371] Redacted.pdf 

(350 pages) 

• HK639684 Devon Terrell [Criminal Defense Files - Fields 015372-017742] Redacted.pdf 

(2371 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 210 of 433 PageID #:15631
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT C 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 211 of 433 PageID #:15632
Attachment C - Compensation

Report of Plaintiff’s Expert – Michael D. Brasfield 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

My compensation for work related to this case is $300 per hour, with a four-hour minimum. 

Deposition and trial testimony is billed at a flat rate of $1200 for up to four hours. After four 

hours, the hourly rate of $300 is charged. Time spent traveling and waiting to testify is 

considered billable time. Reasonable expenses may be charged with prior approval. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 212 of 433 PageID #:15633
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT D 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 213 of 433 PageID #:15634
1 

Attachment D - Resume

Report of Plaintiff’s Expert – Michael D. Brasfield 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

Education:

Bachelor of Arts, Police Administration - University of Washington, Seattle, WA 

Senior Management Institute for Police - Police Executive Research Forum, Washington, 

D.C. 

 

Professional Experience: 

2003-2009 Elected Sheriff of Jefferson County, Washington 

After retiring for a second time, and returning to the small rural county that I had chosen 

as my permanent retirement home, I ran for public office. This 1,815 square mile, 

predominantly rural, county has a full time resident population of only 26,000. The 

Jefferson County Sheriff’s Office, established in 1853, is one of the oldest law 

enforcement organizations in the state of Washington. The Sheriff’s Office budget for 

fiscal year 2008 was $4.5 million. The Office has 50 employees and a large network of 

volunteers and reserve deputies. I was re-elected to a 2nd term which began on January 1, 

2007 by an 80% majority. I retired from this office in March 2009. 

2001 – 2003 Consultant and Program Director - South Downtown Foundation 

Responsibility for administering several million dollars for improving public safety in the 

International District, SoDo, and Pioneer Square neighborhoods of Seattle. Coordinated 

efforts with the City of Seattle, the Seattle Police Department and various interest and 

civic groups in the area. 

1995-2001 Police Chief of Fort Lauderdale, Florida 

The 33 square mile city has a full time resident population of 165,000. An estimated 

additional 60,000 “snow bird” residents return to second homes in the city during the 6-

month winter season. Fort Lauderdale serves as the seat of government for a county of 

1.5 million and is in the heart of a diverse tri-county (Dade, Broward, and Palm Beach) 

population of 4 million. As one of the premier tourist destinations in South Florida, over 

12 million passengers come through the airport each year. The ocean port handles the 

second largest number of cruise ship sailings in the world. Fort Lauderdale serves as the 

governmental and business hub of the County. 

The City employed a workforce of 2,600 employees and operated with a budget of over 

$334 million. IAFF, FOP, and AFSCME Unions represent the fire, police, and general 

employees, respectively. The Fort Lauderdale Police Department had a budget of $60 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 214 of 433 PageID #:15635
2 

million and consisted of 500 sworn positions and 300 civilian positions. In 2000 the 

department received 600,000 calls for service, dispatched over 200,000 of those calls, 

made over 20,000 arrests, and issued over 65,000 traffic citations. The Department is 

now nationally recognized as an innovative leader in the field of community policing and 

was one of only a handful of cities nationwide to be selected as a Community Policing 

Demonstration Site by the Department of Justice. Oversaw and operated the only 

municipal jail in the state of Florida. 

A small sampling of initiatives undertaken over the 6 years includes: 

• First large municipal police agency in Florida to receive accreditation 

• Automobile anti-theft tactics that have reduced auto thefts by nearly 35% in one 

year 

• Aggressive property crime reduction efforts in the area of strengthened pawn shop 

record sharing and accountability 

• Partnerships with State Probation and Parole staff in “Ride Along Programs” with 

our patrol officers to remove violators from the community 

• Establishment of “Citizens on Patrol” in specially marked vehicles to enhance 

public safety 

• Aggressive enforcement of traffic and “quality of life” ordinances to help 

neighborhoods 

• Establishment of a Nuisance Abatement Board to address drug and prostitution 

activity 

• Significant reduction in alarm false dispatches to allow increased proactive patrol 

• Innovative anti-prostitution and anti-gang programs 

• Federal “Weed & Seed” designation, which has allowed us to partner with a wide 

range of community and governmental entities 

• Thirteen sessions of the Citizen Police Academy - a 3 month, 35-hour program 

• Summer COPJAM activities for at risk youth 

• Truancy and curfew programs which have dramatically reduced the rate of 

property crimes 

In 1997 undertook a city financed $10 million technology enhancement initiative for the 

Department. Half of it was for a new state of the art Computer Aided Dispatch (CAD) 

and Record Management System (RMS), and the other half for network servers, 

individual personal computers, Geographical Information System (GIS), Automated 

Fingerprint Identification System (AFIS), internet access, bar coding for property control 

and evidence, and the largest law enforcement deployment of handheld, pen based, 

Motorola Forte’ computers for patrol officers. 

During my 6-year tenure, we successfully competed and received nearly $8 million in 

Federal and State grants. More than forty percent of the grant funds have gone into nontraditional community and social service support programs, in lieu of police personnel 

and hardware. 

During my tenure there was a dramatic improvement in the relationship between our 

unions and management. We successfully negotiated two (3 year) contracts without 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 215 of 433 PageID #:15636
3 

incident or rancor. Although there has been an increase in professional expectations of 

accountability for our employees, disciplinary appeals to arbitration had been all but 

eliminated. 

1990-1995 Assistant Chief - Seattle Police Department 

An appointive, exempt position reporting directly to the Chief of Police - acted as the 

Executive Assistant Chief of the Department and commanded the Support Bureau. The 

Police Department employed over 1,875 personnel and had an annual budget of $120 

million. 

Responsible for and oversaw the activity of nine uniquely different divisions including: 

Training; Internal Investigations; Crime Prevention: Intelligence; Communications; 

Personnel; Records & Evidence; Data Processing; and Fiscal, Property, & Fleet 

Management. As the Executive Assistant Chief, was responsible for the day-to-day 

operation of the agency including authority for hiring, discipline, and administrative 

decisions. In addition, acted as primary management labor relations and contract 

negotiator with 12 labor unions. This bureau employed approximately 100 sworn and 

450 civilians. Served as the Seattle Police Department’s jail liaison executive, as well as 

jail contract negotiator. Routinely served as acting Chief of Police. 

1986-1990 Major 

An appointive, exempt position - command of SPD Inspectional Services Division, 

reported directly to the Chief of Police. Coordinated and implemented strategic planning 

for the entire Department and conducted periodic performance inspections of 

Departmental units. Oversaw the preparation of the Department’s budget, as well as the 

formulation of departmental rules, policies, and procedures. Acted as liaison with elected 

officials and community groups. 

1984-1985 Captain 

Command of SPD North Precinct. Responsible for Patrol operations in an area of the city 

that encompassed a population of 200,000 people and a uniformed force of 130 

officers. The precinct contained over a dozen unique communities including the 

University of Washington. Routinely served as acting Patrol Major overseeing all four 

patrol precincts - 550 sworn personnel. 

1982-1983 Captain 

Command of SPD Internal Investigations Section, reported directly to the Chief of 

Police. Responsible for overseeing the investigation of alleged misconduct of nearly 

2,000 sworn and civilian members of the Department. 

1980-1981 Captain 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 216 of 433 PageID #:15637
4 

Command of SPD West Precinct. Responsible for Patrol Operations in the downtown 

core of the city. Major league sports facilities, waterfront maritime industries, 

transportation, and financial, retail and business headquarters serving a daytime 

population of 300,000 -command of 150 sworn officers. 

1978-1979 Lieutenant 

Commander of Basic Recruit Training. Responsible for the operation and administration 

of the recruit training for SPD as well as the contract recruit training with the Washington 

State Criminal Justice Training Commission for over 100 law enforcement agencies 

state-wide. Average recruit population on campus of 140 in 4 concurrent classes, as well 

as a multi-agency training staff. Also served for a brief period as a downtown watch 

commander in the downtown business area. 

1975 – 1978 Sergeant 

Served as supervisor in the following: Patrol - uniformed patrol operations; Internal 

Investigations Section - investigation of citizen, departmental, and criminal allegations of 

police misconduct; Special Patrol Unit - plain clothes tactical response to priority crime 

problems, deployment at unusual occurrences, dignitary protection. 

1972 – 1975 Detective 

Served in the following: Accident Investigation Section - plain clothes follow-up 

investigation of hit-run, serious injury and fatality motor vehicle accidents; Burglary 

Section - investigated serious crimes directed against property; Vice Section - 

investigated organized crime, prostitution, pornography, liquor, and gambling activities, 

and engaged in extended undercover assignments. 

1968-1971 Patrol Officer 

Started with Mercer Island (WA) P.D. in 1968, and then began career with Seattle P.D. in 

1969. 

Training (small sampling): 

• Police Liability and the Management of Police Discipline - Americans for 

Effective Law Enforcement 

• Police Technology and Efficiency - International Association of Chiefs of Police 

• Total Quality Management - The Institute for Quality Service 

• Assessment Center Operations and Management - Federal Bureau of Investigation 

• Executive Development - Federal Bureau of Investigation 

• Incident Command System – National Incident Management System – Through 

Level 4 

• Gambling Enforcement and Supervision - Washington State Gambling 

Commission 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 217 of 433 PageID #:15638
5 

• Labor Relations and Negotiations - Federal Bureau of Investigation and 

Washington Association of Cities 

• Hazardous Materials Incident Management - National Highway Transportation 

Safety Board 

• Dignitary Protection Management and Supervision - U.S. Secret Service 

• Supervision of Auto Theft Investigation - National Auto Theft Bureau 

• Police Traffic Supervision - Northwestern Traffic Institute 

• Municipal Budget Management - Office of Management and Budget 

• Training for Trainers - Washington State Criminal Justice Training Commission 

• Managing Computer Operations - Department of Administrative Services 

• Investment in Excellence - The Pacific Institute 

• Organized and White Collar Crime - The University of Washington 

• Management of Computer Fraud Investigations – USWEST 

• National Center for Missing and Exploited Children - Alexandria, VA 

Law Enforcement Committees & Membership: 

National:

• International Association of Chiefs of Police – Honorary Life Member 

• Police Executive Research Forum – Subscribing Member 

• National Sheriffs’ Association – Life Member 

• American Bar Association – Associate Member 

• American Correctional Association – Member 

• American Jail Association – Member 

• Crisis Intervention Team International – Member 

State:

• Appointed by the Governor and served as the only law enforcement member of 

the Washington State Sentencing Guidelines Commission (August 2003 – 2008) 

• Appointed to, and served as the chair of the Washington State Board on Law 

Enforcement Training Standards and Education (March 2003 – 2008) 

• Homicide Investigation Tracking System (HITS) Advisory Board (May 2003 – 

2006) 

• Executive Board member of the Washington State Sheriffs’ Association (May 

2006 – 2008) 

• Washington Association of Sheriffs and Police Chiefs – Honorary Life Member 

Local:

• Past chair of Jefferson County Domestic Violence/Sexual Assault Program 

• Member of the Peninsula College Criminal Education Program Board 

• Executive Board of Olympic Peninsula Narcotics Enforcement Task Force 

• Executive Board of JeffCom 911 Communications System 

• Jefferson County Law & Justice Council 

• Olympic Law Enforcement Executives Association 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 218 of 433 PageID #:15639
6 

Achievements (sampling): 

• Past Co-Chair of Private Sector Liaison Committee - International Association of 

Chiefs of Police 

• Coordinator for successful federal grant application on Community 

Policing Program (N.I.J.) 

• National Institute of Justice Symposium on Closed Circuit Television for 

deterrence and investigation of crime - Washington, DC 

• National Institute of Justice Symposium on Metro Area Drug Strategies - 

Washington, DC 

• Coordinator for federal grant application on Narcotics Strategies in Public 

Housing 

• Coordinator for federal grant application on Targeting Young Adult Gang Leaders 

• Federal Bureau of Investigation - National Law Enforcement Budget Advisory 

Group - Appointed by the Director of the F.B.I. 

• Broward County Chiefs’ Association - President and Steering & Training 

Committees 

• Southeast Florida Drug Task Force - Board of Directors 

• Metropolitan Broward County Organized Crime Intelligence Unit - Board of 

Directors 

• Florida Police Chiefs’ Association - Ethics Committee 

• Visiting management assessor for cities of New Orleans (LA), Columbus (OH), 

Portland, (OR), San Francisco (CA), Bremerton (WA) 

• Contract consultant (KOBA Associates) for peer review of NIJ grant work on the 

establishment of Computer Crimes Units 

• Contract consultant (Federal Housing & Urban Development Grant) to visit and 

analyze 6 major U.S. cities (Boston, Baltimore, Memphis, Oxnard, Cleveland & 

Seattle) police agencies and community policing in public housing 

• Subject matter and best practices expert on law enforcement personnel selection, 

screening, and back grounding – USIS Investigative Solutions Conference 

• Developed statewide law enforcement employment screening and back grounding 

model for the Washington Association of Sheriffs and Police Chiefs 

• Oversight responsibility for acquisition of Computer Aided Dispatch and Mobile 

Digital Terminal System 

• Oversight responsibility for acquisition of Comprehensive Shared Records 

Management System 

• Oversight responsibility for acquisition of Jail Booking Video Imaging System 

• Oversight responsibility for management of computerized Patrol Deployment 

Model 

• Responsibility for design and construction oversight, acceptance and start-up of 

new police precinct facility 

• Evaluation of Detective Decentralization Program and Detective Case 

Management System 

• Acquisition of Geo-based Automated Mapping System 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 219 of 433 PageID #:15640
7 

Selected Publications: 

• Contributor - National Institute of Justice - Off-Duty Police Employment 

Practices 

• Citation - Federal Bureau of Investigation article on joint Police-Community 

Partnerships 

• Author of national and state articles - alarm reduction issues and strategies 

• Author of several historical articles - homicides of police officers

Prior Law Enforcement & Community Service: 

• Major City Chiefs - Human Resources sub-committee 

• Washington State Chiefs & Sheriffs - Information Technology sub-committee 

• Mayor’s Task Force on Street People and the Homeless 

• Selection and oversight committee for Police Department Management Study 

consultant contract 

• Selection and oversight committee for Police-Citizen Complaint Process 

consultant contract 

• Executive Member - South Florida Regional Law, Safety, and Justice Committee 

• Automated Fingerprint Identification System / Jails - On-site benchmark testing & 

nationwide visitation team 

• Health Service and Police Community Based Alcohol Triage Program 

• King County Executive - Jail Advisory Committee (JCWG) 

• City of Seattle - Deferred Compensation Plan provider selection and oversight 

• Evaluation and Selection Committee - RFP responses for design of new municipal 

campus 

• Seattle Police Department - reorganization committee that resulted 

in Departmental restructuring 

• Explorer Scout Law Enforcement Program 

• United Way of Broward County - Board of Directors 

• Broward County Commission on Substance Abuse - Chair, Board of Directors 

• Broward County Juvenile Justice Advisory Board 

• Broward County Substance Abuse Policy Advisory Board 

• Broward Workshop - Criminal Justice Committee 

• Florida Department of Law Enforcement - UCR Advisory Committee 

• Alarm Association of Florida / Law Enforcement - Board of Directors (1996-

1997) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 220 of 433 PageID #:15641
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT E 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 221 of 433 PageID #:15642
1 

Attachment E 

Bibliography of Background Source Materials 

 Following is a list of source materials that describe generally accepted policing practices, 

including at the relevant time period. The practices described include but are not limited to 

record-keeping, file maintenance, report writing, conducting homicide investigations, witness 

interrogations, supervision, etc. 

 This list of reference materials is not intended to be exhaustive and is supplemented by 

my extensive experience with police practices, including my familiarity with the policies used by 

other police departments nationwide, as well as industry standards established by organizations 

like the International Association of Chiefs of Police. 

Reference Materials Generally 

Death Investigation: A Guide for the Scene Investigator 

U.S. Department of Justice /Office of Justice Programs / National Institute of Justice 

Crime Scene Investigation: A Guide for Law Enforcement 

U.S. Department of Justice /Office of Justice Programs / National Institute of Justice 

Homicide Guide 

International Association of Chiefs of Police 

Promoting Effective Homicide Investigations 

Police Executive Research Foundation 

Homicide Investigation Standard Operating Procedures 

John M. Howell – Police Executive Forum 

Homicide Process Mapping – Best Practices for Increasing Homicide Clearances : A Project of 

the U.S. Department of Justice, Office of Justice Programs, Bureau of Justice 

Assistance 

Practical Homicide Investigation Checklist and Field Guide, Second Edition 

Vernon J. Geberth 

Techniques of Crime Scene Investigation (now in 8th edition) 

Barry A.J. Fisher 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 222 of 433 PageID #:15643
2 

Homicide investigation; practical information for coroners, police officers, and other 

investigators 

Snyder, LeMoyne 

Practical Cold Case Homicide Investigations Procedural Manual 

Richard H. Walton 

Death Investigation: Systems and Procedures 

Randy Hanzlick 

Forensic Pathology – Practical Aspects of Criminal and Forensic Investigations 

Dominick DiMaio & Vincent J. M. DiMaio 

Death Scene Investigation: A Field Guide 

Scott A. Wagner 

Death Investigator’s Handbook – Volumes 1 & 2 

Louis N. Eliopulos 

Cold Case Homicides: Practical Investigative Techniques 

Richard H. Walton 

Homicide Scene Investigation – A Manual For Public Prosecutors 

http://www.justiceacademy.org/iShare/Library-Training/Homicide-Scene-Manual.pdf 

Death Scene Checklist Sheet 

http://www.insidethetape.com/Jan-2011-EATH%20SCENE%20CHECKLIST%20SHEET.PDF

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 223 of 433 PageID #:15644
3 

References that pre-date the implementation of CPD’s policies 

Dr. Henry Faulds (1843-1930). A towering figure in the history of forensic sciences, it was 

Faulds who first recognized the value of fingerprints to criminal identification. The Faulds 

scrapbooks include research notes, original drawings and studies of fingerprint patterns and 

typology, as well as correspondence with individuals and crime fighting organizations around the 

world, dating from the (late 1870’s) until shortly before the doctor's death in 1930. 

International Association for Identification (www.theiai.org) founded in the (1915). 

• Sparks from the Anvil 1933-1937 

• IAI Newsletter 1940-1951 

• ID News Aug 1951 - 1987 

• Journal of Forensic Identification (JFI) 1988 - 2013 

Locard, E. L’Enquete Criminelle et les Methodes Scientifique. Paris: Ernest Flammarion, (1920). 

Homicide investigation; Frankel, Harold A. (1931) 

Criminology – Robert H. Gault Northwestern University (1932) 

La police scientifique. les homicides.--Les vols.--Les incendies criminels.--Les faux.--La fausse 

monnaie. Bischoff, Marc (1938) 

Homicide investigation; practical information for coroners, police officers, and other 

investigators, by Snyder, LeMoyne (1944, 1950, 1959, 1967, 1977) 

Law of Belligerent Occupation - The Judge Advocate General's School (1945) 

Techniques of Crime Scene Investigation (now in 8th edition) originally published in (1949) 

Techniques of Crime Scene Investigation is a classic book on how to use forensic science to 

investigate crimes. The text was first published in Swedish in 1949 by Chief Superintendent 

Arne Svensson, director of the Laboratory, Criminal Investigation Department, and 

Superintendent Otto Wendel, Criminal Investigation Department, Stockholm, Sweden. In 1955 it 

was printed in English as Crime Detection and then revised into a second, expanded American 

Edition under the title Techniques of Crime Scene Investigation in 1965. In 1981 I was invited to 

revise it in a third edition and subsequently into fourth, fifth, sixth, seventh and eighth editions. 

Kirk, P. L. Crime Investigation. New York: Interscience, John Wiley & Sons (1953). 

The detection of secret homicide; a study of the medico-legal system of investigation of sudden 

and unexplained deaths. Havard, John D. J. (1960) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 224 of 433 PageID #:15645
4 

Institute on Homicide Investigation Techniques / presented by the Southwestern Law 

Enforcement Institute, Dallas, Texas; general editor: Robert A. Wilson. (1961) 

Practical homicide investigation. With an introd. by William P. Maheady. (1961) 

“We have learned the lesson of history, ancient and modern, that a system of criminal law 

enforcement which comes to depend on the ‘confession’ will, in the long run, be less 

reliable and more subject to abuses than a system which depends on extrinsic evidence 

independently secured through skillful investigation.” Escobedo v. Illinois, 378 U.S. 478, 

488–489 (1964) 

Thorwald, J. Crime and Science. Harcourrt, Brace & World, Inc.: New York, [LC Cat. no. 67-

20323]. (1966) 

Police Detective Function (W.S.U.) by V. A. Leonard (1970) 

Murder investigation. Oughton, Frederick (1971) 

Fox, Richard H. and Carl L. Cunningham. Crime Scene Search and Physical Evidence 

Handbook. 

Washington, D.C.: U.S. Department of Justice, National Institute of Justice, (1973). 

Homicide: investigative techniques, by Daniel J. Hughes. (1974) 

Kirk, P.L. Crime Investigation, 2nd Edition. New York: John Wiley & Sons, (1974). 

Police: the investigation of violence / Keith Simpson (1978) 

Smyth, F. Cause of Death: The Story of Forensic Science. Van Nostrand Rheinhold Company: 

New York, [ISBN 0-442-20041-2]. (1980) 

Zonderman, J. Beyond the Crime Lab: The New Science of Investigation. John Wiley & Sons: 

New York, [ISBN 0-471-62296-6]. (1980) 

Homicide investigation standards textbook / Joseph C. DeLadurantey, Daniel R. Sullivan. (1980) 

Saferstein, R. Forensic Science Handbook, Volumes I, II, III. Englewood Cliffs, N.J.: PrenticeHall, (1982/1988/1993). 

DeForest, P.R., R.E. Gaensslen, and H.C. Lee. Forensic Science: An Introduction to 

Criminalistics. New York: McGraw-Hill, Inc., (1983). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 225 of 433 PageID #:15646
5 

Rosenfield, I.; Ziff, E. van Loon, B. DNA for Beginners. Writers and Readers Publishing, Inc. 

[ISBN 0-86316-023-9, pkb.]. (1983) 

Practical homicide investigation: tactics, procedures, and forensic techniques / Vernon J. 

Geberth. (1983) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 226 of 433 PageID #:15647
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT F 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 227 of 433 PageID #:15648
1 

Attachment F 

For the first group of basement files, in the time period from 1983 to 1989, I compared a 

total of 28 criminal defense files1

 to 27 corresponding basement files and 27 corresponding 

permanent retention files. For the second group of basement files, in the time period from 1999 

to 2006, I compared a total of 23 criminal defense files to 23 basement files.2

The following listing provides a case-by-case account of what documents are included in 

basement files but are missing from criminal defense files. I did not make any inferences about 

what documents were turned over to criminal defendants – I based my conclusions on 

observations about actual differences between files. For each homicide investigation, each set of 

files—whether the basement file, the criminal defense file, or the permanent retention file is 

labeled with a CPD Records Division (“RD”) Number and a criminal defendant’s name. 



1

 These 28 files concerned 27 separate cases. Plaintiff located two defense attorney files for the 

1985 investigation assigned RD G-468726, one for defendant Albert Spraggins, and one for 

defendant Maurice Spraggins 

2

 There were no permanent retention files for the second timeframe, 1999-2006 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 228 of 433 PageID #:15649
2 

Table of Contents 

Group One / 1983-1989 Files 

Cecil Robinson (RD# E-010765 / IF Bates ACB 0000001-95) .................................................................... 4

Serafin Flores (RD# E-399564 / IF Bates ACB 005572-005778)	

Christino Garcia (RD# F-048933 / IF Bates ACB 006037-006165)	

Lindsey Cannon (RD# F-380662 / IF Bates ACB 007074-007196)


Earl Stademeyer (RD# G-011889 / IF Bates ACB 008910-008984)


Guy Johns (RD# G-014815 / IF Bates ACB 008985-009112)


Roscoe Evans (RD# G-108642 / IF Bates ACB 010440-010561)


Derrick Johnson (RD# G-148403 / IF Bates ACB 011173-011359)

James Walker (RD# G-159857 / IF Bates ACB 011627-011977)

William Goodin (RD# G-165272 / IF Bates ACB 089308-089463)

Maurice Green (RD# G-215280 & G-215280A / IF Bates ACB 090389-090455 & 013368-013499 & 

013500-013570)

Ruben Avilez (RD# G-248336 & G-248696 (PR) / IF Bates ACB 014301-014467)


Freddy Brown (RD# G-257089 / IF Bates ACB 014789-014838)


James Walker (RD# G-267826 / IF Bates ACB 015390-01544)

Lucille Pye (RD# G-284291 / IF Bates ACB 016197-016286)

James Crockett (RD# G-321886 / IF Bates ACB 016649-016807)

Edward Terrett (RD# G-446754 / IF Bates ACB 020109-020156)

Larry Buchanan (RD# G-456900 / IF Bates ACB 020809-020859)

Albert & Maurice Spraggins (RD# G-468726 / IF Bates ACB 020860-021007)

Albert Buckles (RD# J-381525 / IF Bates ACB 046796-046880)

Mervyn Wright (RD# J-418229 / IF Bates ACB 046881-047084)

Fredy Roberson (RD# M-566742 / IF Bates ACB 047626-047677)

Steve Jones (RD# M-568343 / IF Bates ACB 048058-048142)

John Avery (RD# M-569727 / IF Bates ACB 048143-048180)

David Duarte (RD# M-580592 / IF Bates ACB 048181-048327)

Tony Allen (RD# M-587998 / IF Bates ACB 048328-048423)

Ricky Icenberg (RD# M-590700 / IF Bates ACB 047678-047772)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 229 of 433 PageID #:15650
3 

Group Two / 1999 – 2006 Files

Steven Spears (RD# D-192218 / IF Bates ACB 003679-003883)

Jimmy Velasquez (RD# D-579065 / IF Bates ACB 004922-005042)

Diante Wiley (RD# G-032399 / IF Bates ACB 009208-009420)

Kevin Jackson (RD# G-259321 / IF Bates ACB 014839-014924)

Timothy Malone (RD# G-266841 & G-266841A / IF Bates ACB 015161-015184 & 015185-015309)

Isaiah Brady (RD# G-268444 / IF Bates ACB 015505-015758)	

George Frison (RD# G-326467 / IF Bates ACB 017072-017380)	

Santana McCree (RD# G-406405 / IF Bates ACB 018900-019189)	

Crisino Bravo (RD# G-570120 / IF Bates ACB 023263-023472)


Norman McIntosh (RD# G-705434 / IF Bates ACB 027079-027314)


Maurice Brown (RD# HH-175723 / IF Bates ACB 049234-049402)


Christopher Peoples (RD# HH-358668 / IF Bates ACB 031268-031555)

Devon Terrell (RD# HH-749335 / IF Bates ACB 056505-056684)

Anthony Houston (RD# HJ-102484 / IF Bates ACB 031556-031828)

Leviante Adams (RD# HJ-366143 / IF Bates ACB 060612-060838)

Octavia Anima (RD# HJ-492443 / IF Bates ACB 081966-082418)

Lakesha Collins (RD# HK-211174 / IF Bates ACB 038163-038338)

Delvie Turpin (RD# HK-406407 / IF Bates ACB 040843-041049)


Donell Johnson (RD# HK-416661 / IF Bates ACB 041050-041244)


Jamell Murphy (RD# HK-449083 / IF Bates ACB 041754-042025)


Verna Colbert (RD# HK-470751 / IF Bates ACB 062432-062666)

Tharine Partee (RD# HK-593970 / IF Bates ACB 063855-064131)

Devon Terrell (RD# HK-639684 / IF Bates ACB 064839-065188)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 230 of 433 PageID #:15651
4 

Group One / 1983-1989 Files 

Examination – Comparison – Contrasting of 27 Homicide Case Records 

(27 Basement Files / 28 Criminal Defense Files / 27 Permanent Retention Files) 

Cecil Robinson (RD# E-010765 / IF Bates ACB 0000001-95) 

• Basement File – 95 pages 

• Missing from Criminal Defense File – Handwritten note (0002); Investigative file 

inventory (0003-4); Arrest report (0038-39); Handwritten note (0044); General offense 

case report (0057-58); Handwritten notes (0059); General offense case report (0060-61); 

Handwritten note (0076); Letter from an attorney with handwritten note on it (0082); 

Handwritten notes, business cards, booking photo (0091-95) 

• Missing from 41-page Permanent Retention File – Investigative file inventory (0003-04); 

Handwritten notes (0002, 0044, 0059,0071, 0076,0079, 0091); To-from memos (0063 & 

0081) 

Serafin Flores (RD# E-399564 / IF Bates ACB 005572-005778) 

• Basement File – 207 pages 

• Missing from Criminal Defense File – Handwritten notes (5572); Case assignment slip 

(5573); Subpoena duces tecum (5578); Felony minute sheet (5581); Handwritten note 

(5586); Court attendance reports (5589-90 & 93); Prisoner hold with handwritten 

information (5599); SRs-Felony minutes- Handwritten note-Court attendance report 

(5601-11); Supplemental Report (5618-19); Court attendance report (5622); Handwritten 

note (5627); Handwritten/Stamped wanted notice (5633); Arrest & disposition forms 

(5636 & 44); Supplemental Reports (5656-63); Handwritten duplicate note (5664); 

Investigative file control card & envelope (5756-57); Supplemental Report (5675-84); 

Handwritten note (5686); Supplemental Report (5693-99); Supplemental Report (5709-

19); Individual photos with typed and handwritten information (5759-78) 

• Missing from 69-page Permanent Retention File – Handwritten notes (5586, 5608, 5623, 

5650-5652, 5664, 5686, 5759, 5765-5776); To-from memo (5599) 

Christino Garcia (RD# F-048933 / IF Bates ACB 006037-006165) 

• Basement File – 129 pages 

• Missing from Criminal Defense File – Handwritten note (6051); Handwritten note 

(6053); Daily hot sheet (6078); Xerox copy of greeting card (6118-19); Photos (6120-21); 

Driver’s license (6122); Attorney’s name and address (6123); Investigative file control 

cards (6124-25); Computer printout related to vehicle (6126-38); Envelope & letter from 

Mexican consulate (6139-41); Phone records (6142-47); Handwritten note, FBI business 

card, typewritten note (6148-50); Miscellaneous vehicle documents (6151-64); 

Investigative file control card (6165) 

• Missing from 30-page Permanent Retention File – Investigative file inventory (6038-39); 

Handwritten notes (6051, 6083, 6085, 6096, 6115); To-from memos (6072; 6150) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 231 of 433 PageID #:15652
5 

Lindsey Cannon (RD# F-380662 / IF Bates ACB 007074-007196) 

• Basement File – 123 pages 

• Missing from Criminal Defense File – Investigative file inventory (7075-76); Case 

assignment slip (7077); Back of property inventory (7087); Receipt for exhibits (7123); 

Arrest report (7137); Arrest report (7141); Criminal arrests (7142); General offense 

report (7143-44); Portion of report form (7158); Plain page with handwritten notes 

(7160); Criminal arrests (7171-7172); Arrest reports (7173-78); GPRs (7179-80); Blank 

printed envelope (7181); Photos & ID notes (7182-95); Investigative control card (7196) 

• Missing from 40-page Permanent Retention File – Investigative file inventory (7075); 

Handwritten notes (7135 & 7160); GPRs (7114-15, 7146, 7179-80) 

Earl Stademeyer (RD# G-011889 / IF Bates ACB 008910-008984) 

• Basement File – 75 pages 

• Missing from Criminal Defense File – Investigative file inventory (8911-12); 

Investigative file control card (8913); Lab report (8941-42); Handwritten notes (8952); 

Property inventory sheets (8971-78) 

• Missing from 27-page Permanent Retention File – Investigative file inventory (8911-12); 

Handwritten notes ()8917 & 8952); To-from memos (8951, 8953, 8968, 8969); GPRs 

(8925-26 & 8962); Supplemental Report (8963) 

Guy Johns (RD# G-014815 / IF Bates ACB 008985-009112) 

• Basement File – 128 pages 

• Missing from Criminal Defense File – Investigative file inventory (8986-87); Photograph 

(8989); Investigative file control card (8990); Handwritten note (8992); Lab report (9007-

09); Handwritten note (9067 & 9091); Autopsy diagrams (9092-93) 

• Missing from 51-page Permanent Retention File – Investigative file inventory (8986-87); 

Handwritten notes (9006, 9065, 9067, 9089, 9091, 9101, 9103, 9105); GPRs (9064, 9081, 

9083, 9104) 

Roscoe Evans (RD# G-108642 / IF Bates ACB 010440-010561) 

• Basement File – 122 pages 

• Missing from Criminal Defense File – Investigative file inventory (10441-42); 

Investigative file control card (10443); Court attendance report (10453); Latent 

fingerprint form (10459); Request for ballistics exam (10462-63); Crime lab receipt for 

exhibits (10464); Evidence report (10465 & 69); Receipt for exhibits (10471 & 73); 

Autopsy diagram (10486); Handwritten note (10499); Handwritten note (10529 & 37) 

• Missing from 39-page Permanent Retention File – Investigative file inventory (10441-

42); Handwritten notes (10446, 10470, 10475, 10494-97, 10529, 10537, 10548-55); Tofrom memos (10462, 10463, 10493); GPRs (10507 & 10510) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 232 of 433 PageID #:15653
6 

Derrick Johnson (RD# G-148403 / IF Bates ACB 011173-011359) 

• Basement File – 187 pages 

• Missing from Criminal Defense File – Handwritten notes (11174); Investigative file 

inventory (11177); Latent fingerprint request (11248 & 259 & 281 & 294 & 324 & 327 & 

330); Handwritten notes (11258 & 276 & 290 & 326 & 334 & 348); Photos (11312); ID 

section arrest sheet (11347); Photos (11356-59); 

• Missing from 40-page Permanent Retention File – Investigative file inventory (11177-

79); Handwritten notes (11174, 11176, 11192, 11208, 11210, 11212, 11234, 11244, 

11246, 11253, 11256, 11258, 11268, 11278, 11283, 11287, 11290, 11293, 11304, 11309, 

11322, 11326, 11332, 11334, 11348); To-from memo (11292) 

James Walker (RD# G-159857 / IF Bates ACB 011627-011977) 

• Basement File – 351 pages 

• Missing from Criminal Defense File – Photos & ID information (11630-640); Photos & 

ID information (11645-651); Photo (11654); Handwritten note (11657-58); Handwritten 

notes on backs of various forms, such as case assignment sheets, AUSA business card, 

field contact cards, and police reports (11660-79 and 680-84); Handwritten notes 

(11686); Evidence report (11687); Handwritten notes (11689-90); Vehicle evidence 

photo (11719); Arrest report (11728); Investigative file inventory (11731 & 11734); 

Handwritten note (11749); GPRs (11750-51); GPR handwritten (11758-59); Latent 

fingerprint request & handwritten note (11765-66); Page with official stamp “Issued on 

Inquiry – Name Check Only” and date (11777); Cook county court complaint (11780-

81); Arrest report (11782-84); Handwritten note (11785); Arrest report (11786-89); 

Property inventory sheets (11804-10); Search warrant inventory sheet (11811); Crime lab 

evidence report (11812); Case report (11816-18); Supplemental Report (11829); Latent 

fingerprint request (11830); Offense reports (11831-32); Juvenile crimes arrest report 

(11834-35); Inventory sheets (11837-38); Offense report (11847-48); Inventory sheet 

(11850); Supplemental Report (11874); GPR handwritten (11879); GPRs with scattered 

handwritten notes (11905); Detective watch assignment sheets (11913 & 915 & 917); 

GPRs with scattered handwritten notes (11935-37); GPRs with scattered handwritten 

notes (11939-43); GPR with scattered handwritten notes (11945-50); GPRs with scattered 

handwritten notes including on back (11953-61); GPR with scattered handwritten notes 

including on back (11963-67); GPR with scattered handwritten notes (11969-70) 

• Missing from 151-page (89+62) Permanent Retention Files – GPRs (15413-15432); 

handwritten notes (ACB 015424; ACB 015481); Inv. File Control (15393); Body 

Diagram (15405); Witness Statements (15450-15468); Form 101 (15469); Wanted Card 

(15480); Release of Person in Custody (15484); Complaint (15485); Arrest Report 

(15486-15487); Copy of Envelope (15492); Request for ID Photos (15504); photographs 

(15397-15401; 15394-15396; 15408-15410; 15470-15476; 15493-15503); 15477-15479; 

15482-15483) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 233 of 433 PageID #:15654
7 

William Goodin (RD# G-165272 / IF Bates ACB 089308-089463) 

• Basement File – 156 pages 

• Missing from 98-page Criminal Defense File – Handwritten GPR (89326-28); To-from 

typewritten memo, with handwritten note (89330-31); Medical eligibility record (89332); 

To-from memo requesting telephone records (89333); Printout of telephone records 

(89334-52); Felony minute sheet (89353); Arrest warrant (89359); Handwritten GPR, 

apparently with 2 authors (89362): Multiple copies of same CPD daily bulletin (89368-

81); Supplemental Reports (89382-87); Material submitted for daily bulletin (89388); 

Multiple Supplemental Reports (89389-405); Supplemental Report (89411-12); Partial 

Supplemental Report (89414); Handwritten GPR (89417-20); Supplemental Reports 

(89426-28); Hospitalization report (89429); Autopsy diagram (89435); Property 

inventory sheet (89445); Handwritten notes on plain sheet of paper (89452); Handwritten 

GPRs with numerous scattered notes (89453-89455); Arrest report (89456); Investigative 

file inventory (89462); Front of case investigative file folder (89463) 

• Permanent Retention File – None provided 

Maurice Green (RD# G-215280 & G-215280A / IF Bates ACB 090389-090455 & 013368-

013499 & 013500-013570) 

• Basement (3) Files – 270 pages (67 + 132 + 71) 

• Missing from Criminal Defense File – Felony minute sheet (13390); Phone message, 2 

sides (11391-92); Arrest information card (11393); Property inventory sheet (13396); 

Arrest information card, 2 sides (13398-99); Grand jury material (13400-03); GPRs with 

scattered handwritten notes (13404-06); GPR with 2 handwritten names and info 

(13408); To-from handwritten note (13414); Handwritten note (13501); Investigative file 

inventory (13502-03); Investigative file control card (13504); Handwritten note (13546) 

• Missing from 41-page Permanent Retention File – Investigative file inventory (13502-

03); Handwritten notes (13391-92, 13405-06, 13501); To-from memos (13399, 13414, 

13533) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 234 of 433 PageID #:15655
8 

Ruben Avilez (RD# G-248336 & G-248696 (PR) / IF Bates ACB 014301-014467) 

• Basement File – 167 pages 

• Missing from Criminal Defense File – Handwritten notes (14302 & 05); Hold prisoner 

past court call (14303); Arrest report (14304); To-from and handwritten note (14306-07); 

LEADS & DL print outs & handwritten telephone number (14308-17); Request for ID 

records (14318); Arrest records (14319); LEADS & name search print outs (14320-

14332); To-from memo and handwritten note (14333-14334); To-from memo (14359); 

Computer screen shot (14360); Supplemental Report (14367-68); To-from memo 

(14379); Hold prisoner past court call (14380); Arrest report (14381); Supplemental 

Report (14413-14); Handwritten notes (14425); Hand drawn scene (14427); LEADS print 

out with handwritten notes (14428-14429); Computer screen shot with handwritten note 

(14430); Arrest report with handwritten note (14431); Computer print outs and screen 

shot (14432-14434); Arrest Report (14435); Computer print outs (14436-38); 

Handwritten note (14441); Hold prisoner past court roll call (14444); Arrest records 

(14445); Handwritten notes (14446); Deceptive practice report (14453-54); Arrest 

records, page stamped ‘Wanted’, handwritten and typed notes; computer screen shots 

(14455-60); Arrest report (14461); Arrest records (14462); Page stamped ‘Wanted’ 

(14463); Photo (14464); Arrest report (14467) 

• Missing from 48-page Permanent Retention File – Handwritten notes (14302, 14334, 

14425, 14441, 14446, 14457); To-from memos (14303, 14305, 14306-07, 14333, 14359, 

14379-80, 14444) 

Freddy Brown (RD# G-257089 / IF Bates ACB 014789-014838) 

• Basement File – 50 pages 

• Missing from Criminal Defense File – Investigative file inventory (14790); Investigative 

file control card (14791); Crime lab report (14792-93); Evidence report (14796); Arrest 

report (14797-98); Autopsy diagram (14802); Crime lab evidence report (14804); GPR 

handwritten with additional side notes throughout (14806-19); Evidence inventory 

(14838) 

• Missing from 15-page Permanent Retention File – Investigative file inventory (14790) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 235 of 433 PageID #:15656
9 

James Walker (RD# G-267826 / IF Bates ACB 015390-01544) 

• Basement File – 115 pages 

• Missing from Criminal Defense File – Folder with Case info (15390); Investigative file 

inventory (15391-92); Investigative file control card (15393); Property inventory sheet 

(15394 & 96); Post-mortem exam report & toxicology report (15397-401); Autopsy 

diagram (15405); Property inventory sheets (15408-09); GPR handwritten with numerous 

side notes (15413-424); GPR handwritten with numerous side notes (15425-432); Felony 

minute sheet (15469); Evidence report (15470); Property inventory sheet (15471); 

Property inventory sheets (15473-74); Arrest reports sheet (15477-80); Handwritten note 

(15481); Teletype print outs (15482-83); Release of person in custody (15484); Cook 

county court complaint (15485); Arrest report (15486-87); Intra-department mail tracking 

envelope (15492); Xerox copy of handwritten name (15496); Photos (15497-503); 

Request for ID photos (15504); 

• Missing from 25-page Permanent Retention File – Investigative file inventory (15391-

92); Handwritten notes (15424 & 15481) 

Lucille Pye (RD# G-284291 / IF Bates ACB 016197-016286) 

• Basement File – 90 pages 

• Missing from Criminal Defense File – Investigative file inventory (16198-99); 

Investigative file control card (16200); Arrest records report (16206); Property inventory 

sheets (16207-09); Autopsy diagram (16218); GPRs handwritten with notes (16220-23); 

Felony minute sheet (16224); Photo and id note (16242-43); ID section sheet (16246); 

Arrest report (16247); Release of person in custody (16249); Photo with id note (16250-

51); Arrest report (16253-56); Photo with id note (16257-58); GPR handwritten with 

notes (16259-62); Arrest records report (16263-67); Arrest report (16268-69); 

Handwritten notes (16270); Handwritten note (16272); GPR (16274); Supplemental 

Report (16275-76); GPR (16283-84); General offense report (16285-86) 

• Missing from 21-page Permanent Retention File – Investigative file inventory (16198-

99); Handwritten notes (16270) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 236 of 433 PageID #:15657
10 

James Crockett (RD# G-321886 / IF Bates ACB 016649-016807) 

• Basement File – 159 pages 

• Missing from Criminal Defense File – Folder cover with numerous stamps and 

handwritten notes (16649); Investigative file inventory (16650-52); Case assignment slip 

(16653); Arrest record report (16654); Post-mortem report & toxicology report (16658-

62); Fingerprint examination report (16663); Towed vehicle report (16664); To-from 

memo (16667); Supplemental Report (16668-70); Supplemental Report (16675-77); 

Supplemental Report (16682-83); Juvenile information summary (16684-85); GPR 

(16686); Nickname index card and handwritten note (16723-24); GPR handwritten with 

numerous side notes (16726); Autopsy diagram (16727); Crime lab evidence report with 

handwritten note (16728-29); Crime lab evidence report (16730); General offense report 

(16732-33); GPRs (16734-40); Supplemental Reports (16741-49); GPRs (16750-53); 

Supplemental Reports (16754-57); Property inventory sheets & handwritten notes 

(16758-61); Supplemental Report (16762-66); Arrest information cards (16767-68); 

General offense report (16769-70); GPRs with notes and drawings (16771-76); 

Investigative file control card (16777); Blank printed envelope (16778); Photos and 

handwritten notes (16779-97); Material submitted for use in daily bulletin (16799-

16804); Stop orders (16805-07) 

• Missing from 50-page Permanent Retention File – Investigative file inventory 16650-52); 

Handwritten notes (16724, 16740, 16751, 16753, 16780-97); To-from memo (16667) 

Edward Terrett (RD# G-446754 / IF Bates ACB 020109-020156) 

• Basement File – 48 pages 

• Missing from Criminal Defense File – Investigative file inventory (20110); Investigative 

file control card (20111); Arrest information card (20113); General offense report 

(20114-15); Supplemental Reports (20118-23); General offense report (20126-27); 

Property inventory sheet (20132); Autopsy diagram (20147); Handwritten note (20156) 

• Missing from 17-page Permanent Retention File – Investigative file inventory (20110); 

Handwritten notes (20136 & 20156) 

Larry Buchanan (RD# G-456900 / IF Bates ACB 020809-020859) 

• Basement File – 51 pages 

• Missing from Criminal Defense File – Investigative file inventory (20810); Crime lab 

receipt for evidence (20814); Handwritten note (20815); Crime lab evidence report & 

handwritten note (20820-21); Crime lab report (20830-31); Autopsy diagram (20832); 

Property inventory sheets (20835-36); Copy of ‘Miranda warnings’ along with numerous 

handwritten notes (20837); Crime lab evidence report (20853); Felony minute sheet 

(20855); Crime scene evidence inventory (20855); GPRs with scattered handwritten 

notes (20856-58); Investigative file control card (20859) 

• Missing from 11-page Permanent Retention File – Investigative file inventory (20810); 

Handwritten notes (20815 & 20837) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 237 of 433 PageID #:15658
11 

Albert & Maurice Spraggins (RD# G-468726 / IF Bates ACB 020860-021007) 

• Basement File – 148 pages 

• Missing from Criminal Defense File – Handwritten notes (20861 & 20864); Investigative 

file inventory (20862); Case assignment slip (20863); Photos & handwritten notes 

(20865-68); Investigative file control card (20869); Court attendance reports (20870-72); 

Computer criminal history report with numerous handwritten notes (20873); 

Supplemental Report (20874-75); Court attendance report (20876); Supplemental Reports 

(20879-83); ASA form with typed info (20884); Arrest report (20886); Arrest records 

report (20887); Arrest control set slip (20888); Computer print outs with handwritten 

notes (20889-91); Arrest info card (20892); Supplemental Report (20893-94); LEADS 

request and teletype to LASO (20895); Handwritten note (20896); LEADS request and 

teletype to LAPD (20897); Handwritten note (20898); To-from memo for all CPD 

watches (20899); Supplemental Report (20900-901); Crime lab evidence report (20902); 

Property inventory sheets (20904-06); Telephone message slip with handwritten notes 

(20907); Handwritten notes (20908-10); Arrest report with handwritten notes (20911-13); 

Photo & handwritten note (2014-15); To-from memo for all CPD watches (20916); 

Arrest report (20918); LEADS request to Davenport PD (20919); Handwritten note 

(20920); Crime lab evidence report (20921); Arrest records report (20922); To-from 

memo with handwritten notes (20924); GPRs with numerous scattered handwritten notes 

and diagrams (20925-37); Post-mortem & toxicology report (20938-42); Autopsy 

diagram (20965); GPRs with numerous scattered handwritten notes (20966-67); 

Supplemental Report (20981-82); Crime lab evidence report (21004); Property inventory 

sheet (21005-06); 

• Missing from 42-page Permanent Retention File – Investigative file inventory (20862-

64); Handwritten notes (20861, 20866, 20868, 20896, 20898, 20907-09, 20920, 20928); 

To-from memos (20899, 20916, 20924) 

Albert Buckles (RD# J-381525 / IF Bates ACB 046796-046880) 

• Basement File – 85 pages 

• Missing from Criminal Defense File – Investigative file inventory (46797); Property 

inventory sheet (46837); GPR handwritten notes (46839-42); Handwritten crime scene 

drawing (46843); Firearms receipt & worksheet (46844); Plain page with handwritten 

number (46845); Autopsy diagram (46846); Preliminary fired evidence report (46847); 

Plain page with handwritten information (46848); Property inventory sheet (46849-51); 

Plain page with handwritten number (46853); Plain page with handwritten information 

(46855); Blank printed letterhead/envelope (46856); CHESS to-from memo (46857); 

Case supplementary report (46858-65); CHESS to-from memo (46866); Original case 

incident report (46867-68); Case supplementary report (46869-74); GPR (46875-77); 

Case supplementary report (46878-80) 

• Files missing from 27-page Permanent Retention File – Investigative file inventory 

(46797); Handwritten notes (46798-802) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 238 of 433 PageID #:15659
12 

Mervyn Wright (RD# J-418229 / IF Bates ACB 046881-047084) 

• Basement File – 204 pages 

• Missing from Criminal Defense File – Investigative file inventory (46883-85); Plain page 

with handwritten number (46886); Photos (46887-91); First page of post-mortem report 

(46920); Request for latent fingerprint comparison (46926); Arrest records report (46932-

33); GPR (46934); Illegible photo & handwritten name (46935-36); Investigative 

handwritten notes on plain paper (46937); Illegible pages from address book (46938-39); 

GPR with handwritten notes (46940); Plain page with handwritten note (46941); GPRs 

with handwritten notes, some unsigned (46942-45); Plain page with handwritten notes 

(46946); Field contact card (46949); Plain page with handwritten notes (46950); Field 

contact care (46951); Plain page with handwritten notes (46952); GPRs (46954-55); BioScience lab report on GSupplemental Report (47012); Plain page with handwritten 

number (47013); Criminal records (47058-59) 

• Missing from 34-page Permanent Retention File – Investigative file inventory (46883-

85); Handwritten notes (46882, 46886, 46927, 46931, 46937-39, 46950, 46952, 46973, 

47013, 47053); To-from memos (46948, 47049, 47051) 

Fredy Roberson (RD# M-566742 / IF Bates ACB 047626-047677) 

• Basement File – 52 pages 

• Missing from Criminal Defense File – Investigative file inventory (47627); Subpoena 

duces tecum (47628); Part of general offense report (47632); Arrest records report 

(47660); Plain page with handwritten notes (47662); Plain page with hand drawn crime 

scene (47666); Crime lab report (47673); Blank printed envelope (47677); 

• Missing from 20-page Permanent Retention File – Investigative file inventory (047627); 

Handwritten notes (47662 & 47666) 

Steve Jones (RD# M-568343 / IF Bates ACB 048058-048142) 

• Basement File – 85 pages 

• Missing from Criminal Defense File – Investigative file inventory (48059-60); 

Supplemental Report (48130-31); General offense report (48132-33); Arrest records 

report (48135); Photos with handwritten notes (48137-42) 

• Missing from 45-page Permanent Retention File – Investigative file inventory (48059-

60); Handwritten notes (48062, 48064, 48140, 48142) 

John Avery (RD# M-569727 / IF Bates ACB 048143-048180) 

• Basement File – 38 pages 

• Missing from Criminal Defense File – Investigative file inventory (48144); Crime lab 

evidence report (48145); Property inventory sheet (48146 & 48149); Request for firearm 

examination (48159); Arrest records report (48179); Blank printed envelope (48180) 

• Missing from 18-page Permanent Retention File – Investigative file inventory (48144); 

To-from memos (48159, 48167, 48176) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 239 of 433 PageID #:15660
13 

David Duarte (RD# M-580592 / IF Bates ACB 048181-048327) 

• Basement File – 147 pages 

• Missing from Criminal Defense File – Plain page with hand drawn crime scene (48204); 

Plain page with handwritten names and other information (48216); Blank printed 

envelope (48316); Photos and handwritten notes (48317-20); CB & Soundex records 

printouts (48321-22); Plain page with handwritten note (48323); DMV printout (48324); 

Soundex records printouts (48325-26); Plain page with handwritten notes (48327) 

• Missing from 57-page Permanent Retention File – Investigative file inventory (48182-

83); Handwritten notes (48204, 48216, 48233, 48235, 48237, 48323, 48327); To-from 

memo (48187) 

Tony Allen (RD# M-587998 / IF Bates ACB 048328-048423) 

• Basement File – 96 pages 

• Missing from Criminal Defense File – Investigative file inventory (48329-30); Part of 

general offense report (48333); Plain page with numerous handwritten notes (48345); 

Plain page with numerous handwritten notes (48364); Plain page with handwritten name 

& address (48386); Subpoena duces tecum (48406-07); Illinois ID card, front & back 

(48419-48420); Plain page with typewritten note (48421); Plain page with handwritten 

note that id’s killers other than man charged (48422) 

• Missing from 50-page Permanent Retention File – Investigative file inventory (48329); 

Handwritten notes (48345, 48364, 48386, 48422); To-from memo (48388) 

Ricky Icenberg (RD# M-590700 / IF Bates ACB 047678-047772) 

• Basement File – 95 pages 

• Missing from Criminal Defense File – Investigative file inventory (47679-80); 

Handwritten notes (47694); Handwritten note (47696); Handwritten notes (47751); 

Subpoena duces tecum (47765); Photos and handwritten notes (47767-72) 

• Missing from 48-page Permanent Retention File – Investigative file inventory (47679-

80); Handwritten notes (47694, 47696, 47698, 47751, 47768); To-from memo (47681) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 240 of 433 PageID #:15661
14 

Group Two / 1999 – 2006 Files 

Examination – Comparison – Contrasting of 23 Homicide Case Records 

(23 Basement Files / 23 Criminal Defense) 

Steven Spears (RD# D-192218 / IF Bates ACB 003679-003883) 

• Basement File – 205 pages 

• Missing from Criminal Defense File – Investigative file inventory (3680), Arrest records 

(3740-54), Booking photo (3768), Handwritten note (3844), Central booking & Criminal 

history (3842-43), Law Enforcement Agencies Data System LEADS printout (3848-51), 

Evidence identification photos (3859-83) 

Jimmy Velasquez (RD# D-579065 / IF Bates ACB 004922-005042) 

• Basement File – 121 pages 

• Missing from Criminal Defense File – Investigative file inventory (4923-25), Property 

inventory/Search warrant sheets (4931-38), Crime scene drawing (5007), Handwritten 

notes (5009-10), Handwritten notes & LEADS (5022-25) 

Diante Wiley (RD# G-032399 / IF Bates ACB 009208-009420) 

• Basement File – 213 pages 

• Missing from Criminal Defense File – Investigative file inventory (9209-9210); 

Investigative file control card (9215); Photos (9216-19); Daily major incident log (9220); 

Death of child to-from memo (9264); Report of post-mortem (9265-9277); ID section 

page (9282); Circuit court complaint (9283); Juvenile summary report (9284-86 & 88); 

Various ID section reports (9289-9296); Recorded voice transmission request (9297); 

Event history log (9298-302); Felony minute sheet (9333); ID section report (9334); 

Juvenile summary report (9365-66); Juvenile summary report (9369); Juvenile summary 

reports (9409-13) 

Kevin Jackson (RD# G-259321 / IF Bates ACB 014839-014924) 

• Basement File – 86 pages 

• Missing from Criminal Defense File – Just a few administrative documents 

Timothy Malone (RD# G-266841 & G-266841A / IF Bates ACB 015161-015184 & 015185-

015309) 

• Basement (2) Files – 149 pages (24 + 125) 

• Missing from Criminal Defense File – Inventory file (15162-64); GPR with multiple 

scattered handwritten notes (15179-80); Supplemental Report (15183-84); Inventory file 

(15186); Information submitted for daily bulletin (15191-92); Xeroxed copies of id cards 

& handwritten notes (15193); GPR with numerous handwritten notes (15194-95); Crime 

scene processing report & handwritten note (15199-200); Handwritten note (15263); 

GPR with handwritten notes & questions (15268); Handwritten note (15270); GPR and 

handwritten side notes (15281) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 241 of 433 PageID #:15662
15 

Isaiah Brady (RD# G-268444 / IF Bates ACB 015505-015758) 

• Basement File – 254 pages 

• Missing from Criminal Defense File – Inventory file (15506); Homicide file review form 

(15511); Investigative file control form (15584); Daily major incident log (15585); 

Computer screen shots with multiple handwritten notes (15591-92);GPRs with 

handwritten notes (15601 & 603); Property inventory sheets (15606-09); Case 

supplementary report (15623); Case name check report (15641); GPRs with handwritten 

notes & scene drawings (15642-671); Computer screen shots (15672-74); Criminal 

history report (15675-79); Name check query & report (15686-87); Computer screen shot 

with hand written notes (15688); LEADS reports with handwritten note (15689-700); 

Computer screen shots (15701-02); Birth certificates (15703-04); Property inventory 

sheets (15728-35 & 15740) 

George Frison (RD# G-326467 / IF Bates ACB 017072-017380) 

• Basement File – 309 pages 

• Missing from Criminal Defense File – Inventory file (17073-75); Investigative file 

control card (17077); Crime scene photos (17079-116); Crime scene photos (17118-51); 

Request for evidence id photos (17152); Crime scene processing report (17153); 

Handwritten notes (17154-55); Case supplementary report (17157-61); Felony minute 

sheet (17178); Computer screen shot (17182); Name search result (17183); Case inquiry 

(17184); Handwritten notes (17185); Computer screen shots (17186-87); Felony minute 

sheet (17195); Computer screen shot (17198); Arrest report (17201); Crime scene 

processing report (17232); Property inventory sheets (17241 & 17256); Crime scene 

processing report (17265); State crime evidence report (17266); Computer screen shots 

& handwritten notes (17267-17275); Xerox copy of auto service invoice (17277); Illinois 

state evidence submittal sheet (17278); Wisconsin DOC travel permit (17279-81); 

Consent to search (17282); GPRs (17300-302); GPR (17317-18); GPR (1736061); 

Handwritten note (17374); Xerox copy of auto service receipt (17376) 

Santana McCree (RD# G-406405 / IF Bates ACB 018900-019189) 

• Basement File – 290 pages 

• Missing from Criminal Defense File – Page from inventory file (18902); Crime scene 

photos identification packet label (18942); Investigative file control card (19026); Legal 

affairs records request (19028); Illinois torture inquiry and relief commission Subpoena 

Duces Tecum (19029-30); Vehicle tow report (19051-52) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 242 of 433 PageID #:15663
16 

Crisino Bravo (RD# G-570120 / IF Bates ACB 023263-023472) 

• Basement File – 210 pages 

• Missing from Criminal Defense File – Investigative file inventory (23264); Crime scene 

photos (23268-99); Lineup photos (23300-07); Crime scene photos (23309-2336); Lineup 

photos (23337-46); Crime scene photos (23347-49); Daily major incident log (23350); 

Investigative file control card (23351); Felony minute sheet (23366); Arrest report 

(23369); Handwritten note (23370); Crime scene processing report (23379); Property 

inventory sheet (23382); Illinois state police evidence submission (23386-87); Property 

inventory sheet (23388 & 92); GPR (23402); GPRs with numerous scattered handwritten 

notes (23412-17); GPR with numerous handwritten notes (23421); GPR with numerous 

handwritten notes (23427-28); GPR with numerous handwritten notes (23432); General 

offense report (23446-47); Case supplementary report (23456); Case supplementary 

report (23460-66); Property inventory sheet (23467); Supplemental Report (23468); 

Crime scene processing report (23469); Illinois state police crime lab inventory (23470-

71) 

Norman McIntosh (RD# G-705434 / IF Bates ACB 027079-027314) 

• Basement File – 236 pages 

• Missing from Criminal Defense File – Investigative file inventory (207080-82); Crime 

scene photos (27085-104); Crime scene photos (27106-132); Major incident log (27133-

34); Investigative file control card (27135); Computer screen shots with handwritten note 

(27135-37); Illinois state police crime lab findings (27139-48); Case supplementary 

reports (27149-77); Case supplementary report (27183-87); Case supplementary report 

(27193-97); General offense report with handwritten notes (27204-05); Handwritten note 

(27222); GPRs with numerous scattered handwritten notes (27231-33); GPRs with 

handwritten notes (27246-47); Felony minute sheet (27250); Xerox copy of state id card 

(27255); Computer screen shots (27256-57); Lineup worksheet with numerous 

handwritten notes (27280); Circuit juvenile court lineup authorization (27283); CPD 

letter of sympathy (27284) 

Maurice Brown (RD# HH-175723 / IF Bates ACB 049234-049402) 

• Basement File – 169 pages 

• Missing from Criminal Defense File – Investigative file inventory (49235-236); 

Homicide file review card (49240); Investigative file control card (49243); Crime scene 

polaroid (49245); Crime photo packet label – duplicate (49264); Daily major incident log 

(49266-67); Illinois state police crime lab evidence & findings (49306-07); Computer 

screen shot (49308); Arrest report (49350); Handwritten notes (49385 & 87); Property 

inventory sheet (49394-95); Property inventory sheets (49397 & 99) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 243 of 433 PageID #:15664
17 

Christopher Peoples (RD# HH-358668 / IF Bates ACB 031268-031555) 

• Basement File – 288 pages 

• Missing from Criminal Defense File – Crime scene photos (31270-93); Legal affairs 

subpoena (31294-95); Investigative file inventory (31307-09); Case supplementary report 

(31311-22); Xerox copy of register receipts and numerous handwritten notes (31325-26); 

Page of handwritten notes (31327); Computer screen shot (31328); GPR (31329); 

Handwritten notes (31330); Xerox copy of attorney’s business card (31331); Xerox copy 

of front and back of attorney’s id card and handwritten notes (31332); Criminal history 

report (31333-38); Arrest report (31339); Felony minute sheet (31340); Case 

supplementary report (31342-56); Supplemental Report (31357); GPRs with scattered 

handwritten notes (31358-61); Fugitive poster (31362); Warrant documents (31363-

31364); Court complaint transmittal (31365); Minneapolis PD criminal history records 

(31366-72); Illinois DOC records (31373); Xerox copy of attorney id (31374); Computer 

screen shot (31375); Criminal history report (31376-81); Pawn shop receipt (31382); 

Blank property inventory sheets (31383-86); Handwritten statement (31387-90); Typed 

statement (31391); LEADS responses (31394-97); LEADS responses (31399-405); 

Felony minutes (31406); Arrest report (31407); Computer screen shots with handwritten 

note (31408-09); Criminal history report (31410-18); GPRs with numerous handwritten 

notes (31419-27); Crime scene processing report (31428); GPR (31429); Case 

supplementary reports (31430-53); Supplementary report (31455); Case supplementary 

reports (31456-81); General offense report (31482-83); Computer screen shot with 

handwritten notes (31484); Arrest report (31485-87); Computer screen shot (31488); 

Felony minute sheet (31489); GPRs with numerous scattered handwritten notes, Xerox 

copies of attorney id, photo (31491-99); GPRs with numerous scattered handwritten notes 

and drawings (31500-17); Handwritten statement (31518-24); Photos & handwritten 

notes (31525-29); Handwritten statement (31530-35); Photos & handwritten notes 

(31536-38); Property inventory sheets (31539-52); Crime scene processing report 

(31553-54); Blank homicide file review form with handwritten notes at margin (31555) 

Devon Terrell (RD# HH-749335 / IF Bates ACB 056505-056684) 

• Basement File – 180 pages 

• Missing from Criminal Defense File – Investigative file control card (56507); Daily 

major incident log (56508); Handwritten note (56509); Investigative file inventory 

(56510); Telephone calls records (56512-17); Computer printout pages (56518-19); 

Telephone invoice (56520-23); Illinois state police lab report (56524); To-from memo 

(56532); To-from memo (56546); Handwritten note (56564); Computer screen shot 

(56579); Crime scene processing report (56580); To-from memo with handwritten notes 

(56581); Handwritten note (56610); Supervisors report of medical absence form (56616) 

Anthony Houston (RD# HJ-102484 / IF Bates ACB 031556-031828) 

• Basement File – 273 pages 

• Missing from Criminal Defense File – Just a few administrative items 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 244 of 433 PageID #:15665
18 

Leviante Adams (RD# HJ-366143 / IF Bates ACB 060612-060838) 

• Basement File – 227 pages 

• Missing from Criminal Defense File – Subject & crime scene photos (60615-61); 

Investigative file control card (60662); Investigative file inventory (60663-64); Drawing 

and numerous handwritten notes (60702); Handwritten statement (60720-23); Event 

history printout (60733-38); Handwritten notes (60764); GPR with numerous handwritten 

notes (60765); ID photo (60803); Criminal history report (60804-05); LEADS report 

(60806-07); Computer screen shot with handwritten note (60808); LEADS reports 

(60809-20); Computer screen shot with handwritten note (60821-22); Computer records 

printouts (60823-32) 

Octavia Anima (RD# HJ-492443 / IF Bates ACB 081966-082418) 

• Basement File – 453 pages 

• Missing from Criminal Defense File – Investigative file control card (81968); FOIA 

request (81991-92); Daily major incident log (81993-96); Handwritten note (82052); 

Criminal history report (82173-77); LEADS report (82178-81); Arrest report (82182); 

Computer screen shot (82183); Criminal history report (82184-88); LEADS report 

(82189-91) Arrest report (82192); Computer screen shot (82193); Criminal history report 

(82194); LEADS report (82195-96); Handwritten statement (82197-201); Photos & 

handwritten notes (82202-06); Handwritten statement (82207-12); Photos & handwritten 

notes (82213-17); Handwritten statement (82218-25); Photos & handwritten notes 

(82226-30); Computer screen shot (82231); Criminal history report (82232-33); LEADS 

report (82234-47); Handwritten statement (82248-53); Photos & handwritten notes 

(82254-64); Handwritten statement (82265-69); Photos & handwritten notes (82270-77) 

Lakesha Collins (RD# HK-211174 / IF Bates ACB 038163-038338) 

• Basement File – 176 pages 

• Missing from Criminal Defense File – Investigative file control card (38165); 

Investigative file inventory (38166-67); Illinois state police lab report (38171-75); GPRs 

with numerous scattered handwritten notes & Xerox of food receipt (38177-89); GPRs 

with numerous scattered handwritten notes & drawing (38202-14); Illinois state police 

supplemental lab report (38216-17); Request for info – office of legal affairs (38219); 

Illinois state police lab report (38232); Case supplementary report (38265-86) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 245 of 433 PageID #:15666
19 

Delvie Turpin (RD# HK-406407 / IF Bates ACB 040843-041049) 

• Basement File – 207 pages 

• Missing from Criminal Defense File – Crime scene photos (40847-82); Daily major 

incident log (40883-85); Investigative file inventory (40886-87); Illinois state police lab 

report (40888-89); Subpoena duces tecum (40890-91); Case supplementary report 

(40892-98); Felony minutes form (40899); Arrest report (40900); Photo with signatures 

(40905); Photo with signatures (40910); Photo with signatures (40918); Photo with 

signatures (40923); Xerox copy of id card with handwritten notes (40928); Crime scene 

processing report (40929-30); Crime scene processing report (40956); Post-mortem & 

toxicology report (40962-68); GPRs with numerous scattered handwritten notes (40992-

41005); Computer screen shots (41006-07); Criminal history report (41008-16); Material 

submitted for daily bulletin (41017); Arrest report (41018); LEADS report with 

handwritten notes (41019); CLEAR gang arrest report (41020-22); Illinois state police 

evidence submission report (41023-24); Major crime scene report (41025-28); Illinois 

state police lab report (41029); Crime scene processing report (41030); Autopsy diagram 

(41031); Neighborhood crime scene drawing (41032); GPR empty, but signed (41033); 

Blank property inventory form (41034 & 36 & 38 & 40); CPD daily bulletin (41041-43); 

Supplementary report (41044); General offense reports (41045-48); Homicide file review 

form, blank but with handwriting around outside (41049) 

Donell Johnson (RD# HK-416661 / IF Bates ACB 041050-041244) 

• Basement File – 195 pages 

• Missing from Criminal Defense File – Investigative file control card (41052); Crime 

scene photos (41055-98); Felony minutes form (41106); Handwritten note (41140); 

Handwritten note (41188); Pages from post-mortem report (41199-100); To-from memos, 

with handwritten note & reference to “our friend’s name” (41237-44) 

Jamell Murphy (RD# HK-449083 / IF Bates ACB 041754-042025) 

• Basement File – 272 pages 

• Missing from Criminal Defense File – Investigative file control card (41755); Photo form 

(41756); Crime scene photo series label (41763); Major incident notification (41767-69); 

Daily major incident log (41770-71); Investigative file inventory (41773-74); Lineup 

check list (41777); Photos with initials & signatures (41799-800); Photos with initials & 

signatures (41812-16); Photos (41854-56); Law enforcement report (41876-81); DL 

name search (41882); Felony screening (41883-88); Felony minutes form (41922); 

Moving of arrestee (41924); Supplemental Report (41928-29); GPR (42002); Homicide 

file review form, blank (42025) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 246 of 433 PageID #:15667
20 

Verna Colbert (RD# HK-470751 / IF Bates ACB 062432-062666) 

• Basement File – 235 pages 

• Missing from Criminal Defense File – Investigative file control card (62434); To-from 

memo with handwritten notes (62436); Handwritten note (62437); To-from memo 

(62438); Daily major incident log (62439-40); Investigative file inventory (62441-43); 

Illinois state police crime lab report (62444-45); To-from memo (62446); Illinois state 

police crime lab report (62447-49); Subpoena duces tecum (62450); Illinois state police 

crime lab report (62451); Criminal history report (62563-64); Portion of criminal history 

report (62572); Portion of criminal history report (62598); Homicide file review form, 

blank (62639) 

Tharine Partee (RD# HK-593970 / IF Bates ACB 063855-064131) 

• Basement File – 277 pages 

• Missing from Criminal Defense File – Daily major incident log (63941-42); Investigative 

file inventory (63944-45) 

Devon Terrell (RD# HK-639684 / IF Bates ACB 064839-065188) 

• Basement File – 350 pages 

• Missing from Criminal Defense File – Investigative file control form (64841); Computer 

screen shots (64932-37); Major incident notification detail (64941-43); Criminal history 

report (64952-58); Criminal history report (64959-61); Arrest report (64962); 

Investigative file inventory (64980-82); To-from memos (64983-84); Original case 

incident report (64985-87); Arrest report (65007); Felony minute sheet (65077); LEADS 

report (65080-81); CLEAR etrack report (65082-85); LEADS report (65086-87); Photo 

with handwritten note (65093); LEADS report (65094) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 247 of 433 PageID #:15668
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Nathson E. Fields v. City of Chicago, et al. 

Cause: 1:10-cv-01168 

 

ATTACHMENT G 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 248 of 433 PageID #:15669
1 

Table of Contents 

Row 1 RD# E-010765 (Year 1983) (Area 4) ............................................................ 1-2 

Row 2 RD# E-026792 (Year 1983) (Area 1) ............................................................ 1-2 

Row 3 RD# E-221919 (Year 1983) (Area 1) ............................................................ 1-2 

Row 4 RD# E-277036 (Year 1983) (Area 4) ............................................................ 1-2 

Row 5 RD# E-348611 (Year 1983) (Area 4) ............................................................ 1-2 

Row 6 RD# E-395970 (Year 1983) (Area 4) ............................................................ 1-2 

Row 7 RD# E-399564 (Year 1983) (Area 4) ............................................................ 1-2 

Row 8 RD# E-442815 (Year 1983) (Area 1) ............................................................ 3-4 

Row 9 RD# E-475100 (Year 1983) (Area 1) ............................................................ 3-4 

Row 10 RD# F-048933 (Year 1984) (Area 4) ............................................................ 3-4 

Row 11 RD# F-172852 (Year 1984) (Area 3) ............................................................ 3-4 

Row 12 RD# F-177096 (Year 1984) (Area 4) ............................................................ 3-4 

Row 13 RD# F-229020 (Year 1984) (Area 3) ............................................................ 3-4 

Row 14 RD# F-229039 (Year 1984) (Area 1) ............................................................ 3-4 

Row 15 RD# F-277122 (Year 1984) (Area 1) ............................................................ 5-6 

Row 16 RD# F-299912 (Year 1984) (Area 3) ............................................................ 5-6 

Row 17 RD# F-308281 (Year 1984) (Area 3) ............................................................ 5-6 

Row 18 RD# F-336114 (Year 1984) (Area 3) ............................................................ 5-6 

Row 19 RD# F-380662 (Year 1984) (Area 4) ............................................................ 5-6 

Row 20 RD# F-430186 (Year 1984) (Area 1) ............................................................ 5-6 

Row 21 RD# F-445484 (Year 1984) (Area 4) ............................................................ 7-8 

Row 22 RD# F-492465 (Year 1984) (Area 3) ............................................................ 7-8 

Row 23 RD# G-011265 (Year 1985) (Area 1) ............................................................ 7-8 

Row 24 RD# G-011889 (Year 1985) (Area 1) ............................................................ 7-8 

Row 25 RD# G-014815 (Year 1985) (Area 1) ............................................................ 7-8 

Row 26 RD# G-027619 (Year 1985) (Area 1) ............................................................ 7-8 

Row 27 RD# G-032161 (Year 1985) (Area 1) ............................................................ 7-8 

Row 28 RD# G-049257 (Year 1985) (Area 1) ............................................................ 7-8 

Row 29 RD# G-051225 (Year 1985) (Area 1) .......................................................... 9-10 

Row 30 RD# G-056199 (Year 1985) (Area 1) .......................................................... 9-10 

Row 31 RD# G-087375 (Year 1985) (Area 1) .......................................................... 9-10 

Row 32 RD# G-106586 (Year 1985) (Area 1) .......................................................... 9-10 

Row 33 RD# G-108642 (Year 1985) (Area 1) .......................................................... 9-10 

Row 34 RD# G-148403 (Year 1985) (Area 1) ........................................................ 11-12 

Row 35 RD# G-156178 (Year 1985) (Area 1) ........................................................ 11-12 

Row 36 RD# G-159857 (Year 1985) (Area 3) ........................................................ 11-12 

Row 37 RD# G-165272 (Year 1985) (Area 1) ........................................................ 11-12 

Row 38 RD# G-176242 (Year 1985) (Area 1) ........................................................ 11-12 

Row 39 RD# G-192900 (Year 1985) (Area 1) ........................................................ 13-14 

Row 40 RD# G-215280 (Year 1985) (Area 1) ........................................................ 13-14 

Row 41 RD# G-230261 (Year 1985) (Area 1) ........................................................ 13-14 

Row 42 RD# G-235180 (Year 1985) (Area 1) ........................................................ 13-14 

Row 43 RD# G-245282 (Year 1985) (Area 1) ........................................................ 13-14 

Row 44 RD# G-248336 (Year 1985) (Area 4) ........................................................ 13-14 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 249 of 433 PageID #:15670
2 

Row 45 RD# G-257089 (Year 1985) (Area 1) ........................................................ 13-14 

Row 46 RD# G-265171 (Year 1985) (Area 1) ........................................................ 13-14 

Row 47 RD# G-267631 (Year 1985) (Area 3) ........................................................ 13-14 

Row 48 RD# G-267820 (Year 1985) (Area 1) ........................................................ 13-14 

Row 49 RD# G-267826 (Year 1985) (Area 1) ........................................................ 15-16 

Row 50 RD# G-278643 (Year 1985) (Area 1) ........................................................ 15-16 

Row 51 RD# G-283147 (Year 1985) (Area 4) ........................................................ 15-16 

Row 52 RD# G-284291 (Year 1985) (Area 1) ........................................................ 15-16 

Row 53 RD# G-289217 (Year 1985) (Area 1) ........................................................ 15-16 

Row 54 RD# G-303402 (Year 1985) (Area 1) ........................................................ 15-16 

Row 55 RD# G-321886 (Year 1985) (Area 4) ........................................................ 15-16 

Row 56 RD# G-322101 (Year 1985) (Area 1) ........................................................ 15-16 

Row 57 RD# G-331216 (Year 1985) (Area 1) ........................................................ 15-16 

Row 58 RD# G-354748 (Year 1985) (Area 1) ........................................................ 15-16 

Row 59 RD# G-356930 (Year 1985) (Area 1) ........................................................ 15-16 

Row 60 RD# G-385135 (Year 1985) (Area 1) ........................................................ 17-18 

Row 61 RD# G-401782 (Year 1985) (Area 1) ........................................................ 17-18 

Row 62 RD# G-405711 (Year 1985) (Area 1) ........................................................ 17-18 

Row 63 RD# G-446754 (Year 1985) (Area 1) ........................................................ 17-18 

Row 64 RD# G-456900 (Year 1985) (Area 1) ........................................................ 17-18 

Row 65 RD# G-468726 (Year 1985) (Area 1) ........................................................ 17-18 

Row 80 RD# G-468726 (Year 1985) (Area 1) ........................................................ 17-18 

Row 66 RD# G-482955 (Year 1985) (Area 3) ........................................................ 19-20 

Row 67 RD# G-483470 (Year 1985) (Area 1) ........................................................ 19-20 

Row 68 RD# G-501974 (Year 1985) (Area 1) ........................................................ 19-20 

Row 69 RD# H-024109 (Year 1986) (Area 4) ........................................................ 19-20 

Row 70 RD# H-349049 (Year 1986) (Area 4) ........................................................ 19-20 

Row 71 RD# H-435581 (Year 1986) (Area 4) ........................................................ 19-20 

Row 72 RD# H-465163 (Year 1986) (Area 2) ........................................................ 21-22 

Row 73 RD# J-381525 (Year 1987) (Area 4) ........................................................ 21-22 

Row 74 RD# J-418229 (Year 1987) (Area 1) ........................................................ 21-22 

Row 75 RD# J-486857 (Year 1987) (Area 4) ........................................................ 21-22 

Row 76 RD# J-510242 (Year 1987) (Area 4) ........................................................ 21-22 

Row 77 RD# K-300724 (Year 1988) (Area 4) ........................................................ 21-22 

Row 78 RD# K-562024 (Year 1988) (Area 4) ........................................................ 23-24 

Row 79 RD# M-139566 (Year 1989) (Area 4) ........................................................ 23-24 

Row 80 RD# M-510728 (Year 1989) (Area 4) ........................................................ 25-26 

Row 81 RD# M-534290 (Year 1989) (Area 4) ........................................................ 25-26 

Row 82 RD# M-539997 (Year 1989) (Area 4) ........................................................ 27-28 

Row 83 RD# M-544975 (Year 1989) (Area 4) ........................................................ 27-28 

Row 84 RD# M-566742 (Year 1989) (Area 4) ........................................................ 27-28 

Row 85 RD# M-568343 (Year 1989) (Area 4) ........................................................ 27-28 

Row 86 RD# M-569727 (Year 1989) (Area 4) ........................................................ 29-30 

Row 87 RD# M-580592 (Year 1989) (Area 4) ........................................................ 29-30 

Row 88 RD# M-587998 (Year 1989) (Area 4) ........................................................ 29-30 

Row 89 RD# M-590700 (Year 1989) (Area 4) ........................................................ 29-30 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 250 of 433 PageID #:15671
3 

Row 90 RD# D-322218 (Year 1999) (Area 4) ........................................................ 29-30 

Row 91 RD# D-192218 (Year 1999) (Area 4) ........................................................ 29-30 

Row 92 RD# D-579065 (Year 1999) (Area 4) ........................................................ 29-30 

Row 93 RD# D-131199 (Year 1999) (Area 4) ........................................................ 29-30 

Row 94 RD# D-145734 (Year 1999) (Area 4) ........................................................ 29-30 

Row 95 RD# D-146057 (Year 1999) (Area 4) ........................................................ 29-30 

Row 96 RD# D-454658 (Year 1999) (Area 4) ........................................................ 29-30 

Row 97 RD# D-724882 (Year 1999) (Area 4) ........................................................ 29-30 

Row 98 RD# F-475-960 (Year 2000) (Area 4) ........................................................ 29-30 

Row 99 RD# F-405-633 (Year 2000) (Area 4) ........................................................ 29-30 

Row 100 RD# F-731010 (Year 2000) (Area 4) ........................................................ 31-32 

Row 101 RD# F-746059 (Year 2000) (Area 1) ........................................................ 31-32 

Row 102 RD# G-032399 (Year 2001) (Area 1) ........................................................ 31-32 

Row 103 RD# G-082465 (Year 2001) (Area 1) ........................................................ 31-32 

Row 104 RD# G-108432 (Year 2001) (Area 1) ........................................................ 31-32 

Row 105 RD# G-118582 (Year 2001) (Area 1) ........................................................ 31-32 

Row 106 RD# G-128509 (Year 2001) (Area 1) ........................................................ 31-32 

Row 107 RD# G-142325 (Year 2001) (Area 4) ........................................................ 31-32 

Row 108 RD# G-152113 (Year 2001) (Area 1) ........................................................ 31-32 

Row 109 RD# G-168213 (Year 2001) (Area 1) ........................................................ 31-32 

Row 110 RD# G-187460 (Year 2001) (Area 4) ........................................................ 31-32 

Row 111 RD# G-188311 (Year 2001) (Area 1) ........................................................ 31-32 

Row 112 RD# G-188820 (Year 2001) (Area 1) ........................................................ 31-32 

Row 113 RD# G-190057 (Year 2001) (Area 1) ........................................................ 31-32 

Row 114 RD# G-221780 (Year 2001) (Area 1) ........................................................ 31-32 

Row 115 RD# G-226841 (Year 2001) (Area 1) ........................................................ 31-32 

Row 116 RD# G-248938 (Year 2001) (Area 1) ........................................................ 31-32 

Row 117 RD# G-259321 (Year 2001) (Area 1) ........................................................ 31-32 

Row 118 RD# G-261213 (Year 2001) (Area 1) ........................................................ 31-32 

Row 119 RD# G-266841 (Year 2001) (Area 1) ........................................................ 31-32 

Row 120 RD# G-268444 (Year 2001) (Area 1) ........................................................ 31-32 

Row 121 RD# G-276602 (Year 2001) (Area 1) ........................................................ 31-32 

Row 122 RD# G-311269 (Year 2001) (Area 1) ........................................................ 31-32 

Row 123 RD# G-322669 (Year 2001) (Area 1) ........................................................ 31-32 

Row 124 RD# G-326467 (Year 2001) (Area 1) ........................................................ 33-34 

Row 125 RD# G-330755 (Year 2001) (Area 1) ........................................................ 33-34 

Row 126 RD# G-356804 (Year 2001) (Area 1) ........................................................ 33-34 

Row 127 RD# G-380402 (Year 2001) (Area 4) ........................................................ 33-34 

Row 128 RD# G-389122 (Year 2001) (Area 1) ........................................................ 33-34 

Row 129 RD# G-390651 (Year 2001) (Area 1) ........................................................ 33-34 

Row 130 RD# G-397986 (Year 2001) (Area 1) ........................................................ 33-34 

Row 131 RD# G-399481 (Year 2001) (Area 1) ........................................................ 33-34 

Row 132 RD# G-406405 (Year 2001) (Area 1) ........................................................ 33-34 

Row 133 RD# G-419125 (Year 2001) (Area 1) ........................................................ 33-34 

Row 134 RD# G-425608 (Year 2001) (Area 1) ........................................................ 33-34 

Row 135 RD# G-434632 (Year 2001) (Area 1) ........................................................ 33-34 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 251 of 433 PageID #:15672
4 

Row 136 RD# G-443474 (Year 2001) (Area 4) ........................................................ 33-34 

Row 137 RD# G-447444 (Year 2001) (Area 1) ........................................................ 33-34 

Row 138 RD# G-450601 (Year 2001) (Area 1) ........................................................ 33-34 

Row 139 RD# G-451387 (Year 2001) (Area 1) ........................................................ 33-34 

Row 140 RD# G-456492 (Year 2001) (Area 1) ........................................................ 33-34 

Row 141 RD# G-491442 (Year 2001) (Area 1) ........................................................ 33-34 

Row 142 RD# G-497018 (Year 2001) (Area 1) ........................................................ 33-34 

Row 143 RD# G-506663 (Year 2001) (Area 4) ........................................................ 33-34 

Row 144 RD# G-541859 (Year 2001) (Area 1) ........................................................ 33-34 

Row 145 RD# G-543889 (Year 2001) (Area 1) ........................................................ 33-34 

Row 146 RD# G-547890 (Year 2001) (Area 1) ........................................................ 33-34 

Row 147 RD# G-554146 (Year 2001) (Area 1) ........................................................ 33-34 

Row 148 RD# G-556311 (Year 2001) (Area 4) ........................................................ 33-34 

Row 149 RD# G-567131 (Year 2001) (Area 1) ........................................................ 33-34 

Row 150 RD# G-570120 (Year 2001) (Area 1) ........................................................ 35-36 

Row 151 RD# G-575283 (Year 2001) (Area 1) ........................................................ 35-36 

Row 152 RD# G-578724 (Year 2001) (Area 1) ........................................................ 35-36 

Row 153 RD# G-592219 (Year 2001) (Area 1) ........................................................ 35-36 

Row 154 RD# G-602617 (Year 2001) (Area 1) ........................................................ 35-36 

Row 155 RD# G-630073 (Year 2001) (Area 1) ........................................................ 35-36 

Row 156 RD# G-630295 (Year 2001) (Area 1) ........................................................ 35-36 

Row 157 RD# G-632707 (Year 2001) (Area 1) ........................................................ 35-36 

Row 158 RD# G-648246 (Year 2001) (Area 1) ........................................................ 35-36 

Row 159 RD# G-655145 (Year 2001) (Area 1) ........................................................ 35-36 

Row 160 RD# G-656885 (Year 2001) (Area 1) ........................................................ 35-36 

Row 161 RD# G-670379 (Year 2001) (Area 1) ........................................................ 35-36 

Row 162 RD# G-678089 (Year 2001) (Area 1) ........................................................ 35-36 

Row 163 RD# G-686446 (Year 2001) (Area 1) ........................................................ 35-36 

Row 164 RD# G-688481 (Year 2001) (Area 1) ........................................................ 35-36 

Row 165 RD# G-691809 (Year 2001) (Area 1) ........................................................ 35-36 

Row 166 RD# G-694725 (Year 2001) (Area 4) ........................................................ 35-36 

Row 167 RD# G-694885 (Year 2001) (Area 1) ........................................................ 35-36 

Row 168 RD# G-701363 (Year 2001) (Area 4) ........................................................ 35-36 

Row 169 RD# G-705434 (Year 2001) (Area 1) ........................................................ 35-36 

Row 170 RD# G-708133 (Year 2001) (Area 1) ........................................................ 35-36 

Row 171 RD# G-722334 (Year 2001) (Area 1) ........................................................ 35-36 

Row 172 RD# G-751124 (Year 2001) (Area 1) ........................................................ 35-36 

Row 173 RD# G-759169 (Year 2001) (Area 1) ........................................................ 35-36 

Row 174 RD# G-763-171 (Year 2001) (Area 4) ........................................................ 37-38 

Row 175 RD# G-776686 (Year 2001) (Area 1) ........................................................ 37-38 

Row 176 RD# HH-101153 (Year 2002) (Area 1) ........................................................ 37-38 

Row 177 RD# HH-105486 (Year 2002) (Area 1) ........................................................ 37-38 

Row 178 RD# HH-112360 (Year 2002) (Area Unknown) .......................................... 37-38 

Row 179 RD# HH-112848 (Year 2002) (Area 1) ........................................................ 37-38 

Row 180 RD# HH-123814 (Year 2002) (Area 1) ........................................................ 37-38 

Row 181 RD# HH-131667 (Year 2002) (Area 1) ........................................................ 37-38 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 252 of 433 PageID #:15673
5 

Row 182 RD# HH-138499 (Year 2002) (Area 1) ........................................................ 37-38 

Row 183 RD# HH-154152 (Year 2002) (Area 1) ........................................................ 37-38 

Row 184 RD# HH-158954 (Year 2002) (Area 1) ........................................................ 37-38 

Row 185 RD# HH-175723 (Year 2002) (Area 1) ........................................................ 37-38 

Row 186 RD# HH-249096 (Year 2002) (Area 1) ........................................................ 37-38 

Row 187 RD# HH-257532 (Year 2002) (Area 1) ........................................................ 39-40 

Row 188 RD# HH-263021 (Year 2002) (Area 1) ........................................................ 39-40 

Row 189 RD# HH-270572 (Year 2002) (Area 1) ........................................................ 39-40 

Row 190 RD# HH-279592 (Year 2002) (Area 1) ........................................................ 39-40 

Row 191 RD# HH-280024 (Year 2002) (Area 1) ........................................................ 39-40 

Row 192 RD# HH-280696 (Year 2002) (Area 1) ........................................................ 39-40 

Row 193 RD# HH-285733 (Year 2002) (Area 1) ........................................................ 39-40 

Row 194 RD# HH-296357 (Year 2002) (Area 1) ........................................................ 39-40 

Row 195 RD# HH-301377 (Year 2002) (Area 1) ........................................................ 39-40 

Row 196 RD# HH-316330 (Year 2002) (Area 1) ........................................................ 39-40 

Row 197 RD# HH-321998 (Year 2002) (Area 1) ........................................................ 39-40 

Row 198 RD# HH-347787 (Year 2002) (Area 1) ........................................................ 39-40 

Row 199 RD# HH-358668 (Year 2002) (Area 1) ........................................................ 39-40 

Row 200 RD# HH-361418 (Year 2002) (Area 1) ........................................................ 41-42 

Row 201 RD# HH-367441 (Year 2002) (Area 1) ........................................................ 41-42 

Row 202 RD# HH-367666 (Year 2002) (Area 1) ........................................................ 41-42 

Row 203 RD# HH-377524 (Year 2002) (Area 1) ........................................................ 41-42 

Row 204 RD# HH-414131 (Year 2002) (Area 1) ........................................................ 41-42 

Row 205 RD# HH-447119 (Year 2002) (Area 1) ........................................................ 41-42 

Row 206 RD# HH-447396 (Year 2002) (Area 1) ........................................................ 41-42 

Row 207 RD# HH-500856 (Year 2002) (Area 4) ........................................................ 41-42 

Row 208 RD# HH-505945 (Year 2002) (Area 1) ........................................................ 41-42 

Row 209 RD# HH-522403 (Year 2002) (Area 1) ........................................................ 41-42 

Row 210 RD# HH-524796 (Year 2002) (Area 1) ........................................................ 41-42 

Row 211 RD# HH-525230 (Year 2002) (Area 1) ........................................................ 41-42 

Row 212 RD# HH-529070 (Year 2002) (Area 1) ........................................................ 41-42 

Row 213 RD# HH-546846 (Year 2002) (Area 1) ........................................................ 41-42 

Row 214 RD# HH-551686 (Year 2002) (Area 1) ........................................................ 41-42 

Row 215 RD# HH-572150 (Year 2002) (Area 1) ........................................................ 41-42 

Row 216 RD# HH-576930 (Year 2002) (Area 1) ........................................................ 41-42 

Row 217 RD# HH-609705 (Year 2002) (Area 1) ........................................................ 41-42 

Row 218 RD# HH-614198 (Year 2002) (Area 1) ........................................................ 41-42 

Row 219 RD# HH-617694 (Year 2002) (Area 1) ........................................................ 41-42 

Row 220 RD# HH-618363 (Year 2002) (Area 1) ........................................................ 43-44 

Row 221 RD# HH-635313 (Year 2002) (Area 1) ........................................................ 43-44 

Row 222 RD# HH-660094 (Year 2002) (Area 1) ........................................................ 43-44 

Row 223 RD# HH-690739 (Year 2002) (Area 1) ........................................................ 43-44 

Row 224 RD# HH-749335 (Year 2002) (Area 1) ........................................................ 43-44 

Row 225 RD# HH-767627 (Year 2002) (Area 1) ........................................................ 43-44 

Row 226 RD# HH-783159 (Year 2002) (Area Unknown) .......................................... 43-44 

Row 227 RD# HH-811146 (Year 2002) (Area 1) ........................................................ 43-44 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 253 of 433 PageID #:15674
6 

Row 228 RD# HH-818229 (Year 2002) (Area 1) ........................................................ 43-44 

Row 229 RD# HH-823907 (Year 2002) (Area 1) ........................................................ 43-44 

Row 230 RD# HH-842054 (Year 2002) (Area 1) ........................................................ 43-44 

Row 231 RD# HH-844492 (Year 2002) (Area 1) ........................................................ 43-44 

Row 232 RD# HH-858534 (Year 2002) (Area 1) ........................................................ 43-44 

Row 233 RD# HH-858682 (Year 2002) (Area 1) ........................................................ 43-44 

Row 234 RD# HH-860642 (Year 2002) (Area 1) ........................................................ 43-44 

Row 235 RD# HH-860835 (Year 2002) (Area 1) ........................................................ 43-44 

Row 236 RD# HJ-102484 (Year 2002) (Area 1) ........................................................ 43-44 

Row 237 RD# HJ-117531 (Year 2003) (Area 1) ........................................................ 43-44 

Row 238 RD# HJ-117559 (Year 2003) (Area 1) ........................................................ 43-44 

Row 239 RD# HJ-143625 (Year 2003) (Area 1) ........................................................ 43-44 

Row 240 RD# HJ-145451 (Year 2003) (Area 1) ........................................................ 43-44 

Row 241 RD# HJ-158056 (Year 2003) (Area 1) ........................................................ 43-44 

Row 242 RD# HJ-169496 (Year 2003) (Area 1) ........................................................ 43-44 

Row 243 RD# HJ-211373 (Year 2003) (Area 1) ........................................................ 43-44 

Row 244 RD# HJ-211691 (Year 2003) (Area 1) ........................................................ 45-46 

Row 245 RD# HJ-228346 (Year 2003) (Area 1) ........................................................ 45-46 

Row 246 RD# HJ-239255 (Year 2003) (Area 1) ........................................................ 45-46 

Row 247 RD# HJ-243231 (Year 2003) (Area 1) ........................................................ 45-46 

Row 248 RD# HJ-256409 (Year 2003) (Area 1) ........................................................ 45-46 

Row 249 RD# HJ-257094 (Year 2003) (Area 1) ........................................................ 45-46 

Row 250 RD# HJ-274500 (Year 2003) (Area 4) ........................................................ 45-46 

Row 251 RD# HJ-284434 (Year 2003) (Area 1) ........................................................ 45-46 

Row 252 RD# HJ-307187 (Year 2003) (Area 1) ........................................................ 45-46 

Row 253 RD# HJ-307851 (Year 2003) (Area 1) ........................................................ 45-46 

Row 254 RD# HJ-310383 (Year 2003) (Area 1) ........................................................ 45-46 

Row 255 RD# HJ-320635 (Year 2003) (Area 1) ........................................................ 45-46 

Row 256 RD# HJ-324514 (Year 2003) (Area 1) ........................................................ 45-46 

Row 257 RD# HJ-366143 (Year 2003) (Area 1) ........................................................ 45-46 

Row 258 RD# HJ-376892 (Year 2003) (Area 1) ........................................................ 45-46 

Row 259 RD# HJ-399272 (Year 2003) (Area 1) ........................................................ 45-46 

Row 260 RD# HJ-400029 (Year 2003) (Area 1) ........................................................ 45-46 

Row 261 RD# HJ-410134 (Year 2003) (Area 1) ........................................................ 45-46 

Row 262 RD# HJ-440488 (Year 2003) (Area 1) ........................................................ 45-46 

Row 263 RD# HJ-492443 (Year 2003) (Area 1) ........................................................ 45-46 

Row 264 RD# HJ-499310 (Year 2003) (Area 4) ........................................................ 47-48 

Row 265 RD# HJ-505759 (Year 2003) (Area 1) ........................................................ 47-48 

Row 266 RD# HJ-518923 (Year 2003) (Area 1) ........................................................ 47-48 

Row 267 RD# HJ-527506 (Year 2003) (Area 1) ........................................................ 47-48 

Row 268 RD# HJ-545448 (Year 2003) (Area 1) ........................................................ 47-48 

Row 269 RD# HJ-547936 (Year 2003) (Area 1) ........................................................ 47-48 

Row 270 RD# HJ-591782 (Year 2003) (Area 1) ........................................................ 47-48 

Row 271 RD# HJ-623228 (Year 2003) (Area 1) ........................................................ 47-48 

Row 272 RD# HJ-640575 (Year 2003) (Area 1) ........................................................ 47-48 

Row 273 RD# HJ-647205 (Year 2003) (Area 1) ........................................................ 47-48 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 254 of 433 PageID #:15675
7 

Row 274 RD# HJ-661717 (Year 2003) (Area 1) ........................................................ 47-48 

Row 275 RD# HJ-664136 (Year 2003) (Area 1) ........................................................ 47-48 

Row 276 RD# HJ-664232 (Year 2003) (Area 1) ........................................................ 47-48 

Row 277 RD# HJ-671123 (Year 2003) (Area Unknown) .......................................... 47-48 

Row 278 RD# HJ-673789 (Year 2003) (Area 1) ........................................................ 47-48 

Row 279 RD# HJ-676387 (Year 2003) (Area 1) ........................................................ 47-48 

Row 280 RD# HJ-678090 (Year 2003) (Area 1) ........................................................ 47-48 

Row 281 RD# HJ-687964 (Year 2003) (Area 1) ........................................................ 47-48 

Row 282 RD# HJ-689560 (Year 2003) (Area 1) ........................................................ 47-48 

Row 283 RD# HJ-733462 (Year 2003) (Area 1) ........................................................ 47-48 

Row 284 RD# HJ-734895 (Year 2003) (Area 1) ........................................................ 47-48 

Row 285 RD# HJ-737306 (Year 2003) (Area 1) ........................................................ 47-48 

Row 286 RD# HJ-745468 (Year 2003) (Area 1) ........................................................ 47-48 

Row 287 RD# HJ-757826 (Year 2003) (Area 4) ........................................................ 47-48 

Row 288 RD# HJ-776575 (Year 2003) (Area 1) ........................................................ 49-50 

Row 289 RD# HJ-793204 (Year 2003) (Area 1) ........................................................ 49-50 

Row 290 RD# HJ-795462 (Year 2003) (Area 1) ........................................................ 49-50 

Row 291 RD# HJ-796729 (Year 2003) (Area 1) ........................................................ 49-50 

Row 292 RD# HJ-831700 (Year 2003) (Area 1) ........................................................ 49-50 

Row 293 RD# HJ-834810 (Year 2003) (Area 2) ........................................................ 49-50 

Row 294 RD# HJ-845688 (Year 2003) (Area 4) ........................................................ 49-50 

Row 295 RD# HK-000106 (Year 2004) (Area 1) ........................................................ 49-50 

Row 296 RD# HK-106793 (Year 2004) (Area 1) ........................................................ 49-50 

Row 297 RD# HK-142414 (Year 2004) (Area 1) ........................................................ 49-50 

Row 298 RD# HK-148852 (Year 2004) (Area 1) ........................................................ 49-50 

Row 299 RD# HK-158502 (Year 2004) (Area 1) ........................................................ 49-50 

Row 300 RD# HK-165467 (Year 2004) (Area 1) ........................................................ 49-50 

Row 301 RD# HK-195199 (Year 2004) (Area 1) ........................................................ 49-50 

Row 302 RD# HK-196935 (Year 2004) (Area 1) ........................................................ 49-50 

Row 303 RD# HK-211174 (Year 2004) (Area 1) ........................................................ 49-50 

Row 304 RD# HK-222787 (Year 2004) (Area 1) ........................................................ 49-50 

Row 305 RD# HK-223040 (Year 2004) (Area 1) ........................................................ 49-50 

Row 306 RD# HK-224777 (Year 2004) (Area 1) ........................................................ 49-50 

Row 307 RD# HK-238041 (Year 2004) (Area 1) ........................................................ 49-50 

Row 308 RD# HK-238478 (Year 2004) (Area 1) ........................................................ 49-50 

Row 309 RD# HK-245772 (Year 2004) (Area 1) ........................................................ 49-50 

Row 310 RD# HK-253794 (Year 2004) (Area 1) ........................................................ 49-50 

Row 311 RD# HK-284640 (Year 2004) (Area 1) ........................................................ 49-50 

Row 312 RD# HK-316879 (Year 2004) (Area 1) ........................................................ 49-50 

Row 313 RD# HK-359543 (Year 2004) (Area 1) ........................................................ 49-50 

Row 314 RD# HK-377605 (Year 2004) (Area 1) ........................................................ 49-50 

Row 315 RD# HK-378604 (Year 2005) (Area 1) ........................................................ 49-50 

Row 316 RD# HK-404487 (Year 2004) (Area 1) ........................................................ 51-52 

Row 317 RD# HK406407 (Year 2004) (Area 1) ........................................................ 51-52 

Row 318 RD# HK416661 (Year 2004) (Area 1) ........................................................ 51-52 

Row 319 RD# HK431410 (Year 2004) (Area 1) ........................................................ 51-52 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 255 of 433 PageID #:15676
8 

Row 320 RD# HK440539 (Year 2004) (Area 1) ........................................................ 51-52 

Row 321 RD# HK-449083 (Year 2004) (Area 1) ........................................................ 51-52 

Row 322 RD# HK-457513 (Year 2004) (Area 1) ........................................................ 51-52 

Row 323 RD# HK-457942 (Year 2004) (Area 1) ........................................................ 51-52 

Row 324 RD# HK-459545 (Year 2004) (Area 1) ........................................................ 51-52 

Row 325 RD# HK-465885 (Year 2004) (Area 1) ........................................................ 51-52 

Row 326 RD# HK-470751 (Year 2004) (Area 1) ........................................................ 51-52 

Row 327 RD# HK-479167 (Year 2004) (Area 1) ........................................................ 51-52 

Row 328 RD# HK-483176 (Year 2004) (Area 1) ........................................................ 51-52 

Row 329 RD# HK-487688 (Year 2004) (Area 1) ........................................................ 51-52 

Row 330 RD# HK-500451 (Year 2004) (Area 1) ........................................................ 51-52 

Row 331 RD# HK-526394 (Year 2004) (Area 1) ........................................................ 51-52 

Row 332 RD# HK-526818 (Year 2004) (Area 1) ........................................................ 51-52 

Row 333 RD# HK-528598 (Year 2004) (Area 1) ........................................................ 51-52 

Row 334 RD# HK-539094 (Year 2004) (Area 1) ........................................................ 51-52 

Row 335 RD# HK-558373 (Year 2004) (Area 1) ........................................................ 51-52 

Row 336 RD# HK-564062 (Year 2004) (Area 1) ........................................................ 51-52 

Row 337 RD# HK-564454 (Year 2004) (Area 1) ........................................................ 51-52 

Row 338 RD# HK-593970 (Year 2004) (Area 1) ........................................................ 51-52 

Row 339 RD# HK-598867 (Year 2004) (Area 1) ........................................................ 51-52 

Row 340 RD# HK-628944 (Year 2004) (Area 1) ........................................................ 51-52 

Row 341 RD# HK-639684 (Year 2004) (Area 1) ........................................................ 53-54 

Row 342 RD# HK-647145 (Year 2004) (Area 1) ........................................................ 53-54 

Row 343 RD# HK-663121 (Year 2004) (Area 1) ........................................................ 53-54 

Row 344 RD# HK-669797 (Year 2004) (Area 1) ........................................................ 53-54 

Row 345 RD# HK-683108 (Year 2004) (Area 1) ........................................................ 53-54 

Row 346 RD# HK-701076 (Year 2004) (Area 1) ........................................................ 53-54 

Row 347 RD# HK-746784 (Year 2004) (Area 1) ........................................................ 53-54 

Row 348 RD# HK-763869 (Year 2004) (Area 1) ........................................................ 53-54 

Row 349 RD# HK-776079 (Year 2004) (Area 1) ........................................................ 53-54 

Row 350 RD# HK-788723 (Year 2004) (Area 1) ........................................................ 53-54 

Row 351 RD# HK-792194 (Year 2004) (Area 1) ........................................................ 53-54 

Row 352 RD# HK-798753 (Year 2004) (Area 1) ........................................................ 53-54 

Row 353 RD# HK-811031 (Year 2004) (Area 1) ........................................................ 53-54 

Row 354 RD# HK-811135 (Year 2004) (Area 1) ........................................................ 53-54 

Row 355 RD# HK-823687 (Year 2004) (Area 4) ........................................................ 53-54 

Row 356 RD# HL-202732 (Year 2005) (Area 1) ........................................................ 53-54 

Row 357 RD# HL-219488 (Year 2005) (Area 1) ........................................................ 53-54 

Row 358 RD# HL-227322 (Year 2005) (Area 1) ........................................................ 53-54 

Row 359 RD# HL-236577 (Year 2005) (Area 1) ........................................................ 53-54 

Row 360 RD# HL-242938 (Year 2005) (Area 1) ........................................................ 53-54 

Row 361 RD# HL-260858 (Year 2005) (Area 1) ........................................................ 53-54 

Row 362 RD# HL-291491 (Year 2005) (Area 1) ........................................................ 53-54 

Row 363 RD# HL-307618 (Year 2005) (Area 1) ........................................................ 53-54 

Row 364 RD# HL-326591 (Year 2005) (Area 1) ........................................................ 53-54 

Row 365 RD# HL-336784 (Year 2005) (Area 1) ........................................................ 53-54 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 256 of 433 PageID #:15677
9 

Row 366 RD# HL-355032 (Year 2005) (Area 1) ........................................................ 53-54 

Row 367 RD# HL-361793 (Year 2005) (Area 1) ........................................................ 55-56 

Row 368 RD# HL-370043 (Year 2005) (Area 1) ........................................................ 55-56 

Row 369 RD# HL-371164 (Year 2005) (Area 1) ........................................................ 55-56 

Row 370 RD# HL-373670 (Year 2005) (Area 1) ........................................................ 55-56 

Row 371 RD# HL-385610 (Year 2005) (Area 1) ........................................................ 55-56 

Row 372 RD# HL-387017 (Year 2005) (Area 1) ........................................................ 55-56 

Row 373 RD# HL-393632 (Year 2005) (Area 1) ........................................................ 55-56 

Row 374 RD# HL-399677 (Year 2005) (Area 1) ........................................................ 55-56 

Row 375 RD# HL-407548 (Year 2005) (Area 1) ........................................................ 55-56 

Row 376 RD# HL-448514 (Year 2005) (Area 1) ........................................................ 55-56 

Row 377 RD# HL-484055 (Year 2005) (Area 1) ........................................................ 55-56 

Row 378 RD# HL-484812 (Year 2005) (Area 1) ........................................................ 55-56 

Row 379 RD# HL-486965 (Year 2005) (Area 1) ........................................................ 55-56 

Row 380 RD# HL-489874 (Year 2005) (Area 1) ........................................................ 55-56 

Row 381 RD# HL-504078 (Year 2005) (Area 1) ........................................................ 55-56 

Row 382 RD# HL-509628 (Year 2005) (Area 1) ........................................................ 55-56 

Row 383 RD# HL-516150 (Year 2005) (Area 1) ........................................................ 55-56 

Row 384 RD# HL-519786 (Year 2005) (Area 1) ........................................................ 55-56 

Row 385 RD# HL-526827 (Year 2005) (Area 1) ........................................................ 55-56 

Row 386 RD# HL-527629 (Year 2005) (Area 1) ........................................................ 55-56 

Row 387 RD# HL-534365 (Year 2005) (Area 1) ........................................................ 57-58 

Row 388 RD# HL-543584 (Year 2005) (Area 1) ........................................................ 57-58 

Row 389 RD# HL-543691 (Year 2005) (Area 1) ........................................................ 57-58 

Row 390 RD# HL-555606 (Year 2005) (Area 1) ........................................................ 57-58 

Row 391 RD# HL-567137 (Year 2005) (Area 1) ........................................................ 57-58 

Row 392 RD# HL-573690 (Year 2005) (Area 1) ........................................................ 57-58 

Row 393 RD# HL-604727 (Year 2005) (Area 1) ........................................................ 57-58 

Row 394 RD# HL-612170 (Year 2005) (Area 1) ........................................................ 57-58 

Row 395 RD# HL-617116 (Year 2005) (Area 4) ........................................................ 57-58 

Row 396 RD# HL-619201 (Year 2005) (Area 4) ........................................................ 57-58 

Row 397 RD# HL-628024 (Year 2005) (Area 1) ........................................................ 57-58 

Row 398 RD# HL-641342 (Year 2005) (Area 1) ........................................................ 57-58 

Row 399 RD# HL-656289 (Year 2005) (Area 1) ........................................................ 57-58 

Row 400 RD# HL-662200 (Year 2005) (Area 1) ........................................................ 57-58 

Row 401 RD# HL-669557 (Year 2005) (Area 1) ........................................................ 57-58 

Row 402 RD# HL-673823 (Year 2005) (Area 1) ........................................................ 57-58 

Row 403 RD# HL-710670 (Year 2005) (Area 1) ........................................................ 57-58 

Row 404 RD# HL-722490 (Year 2005) (Area 1) ........................................................ 57-58 

Row 405 RD# HL-808159 (Year 2005) (Area 1) ........................................................ 59-60 

Row 406 RD# HM-100890 (Year 2006) (Area 1) ........................................................ 59-60 

Row 407 RD# HM-148888 (Year 2006) (Area 1) ........................................................ 59-60 

Row 408 RD# HM-182777 (Year 2006) (Area 1) ........................................................ 59-60 

Row 409 RD# HM-199438 (Year 2006) (Area 1) ........................................................ 59-60 

Row 410 RD# HM-208287 (Year 2006) (Area 1) ........................................................ 59-60 

Row 411 RD# HM-231046 (Year 2006) (Area 1) ........................................................ 59-60 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 257 of 433 PageID #:15678
10 

Row 412 RD# HM-232296 (Year 2006) (Area 1) ........................................................ 59-60 

Row 413 RD# HM-264904 (Year 2006) (Area 1) ........................................................ 59-60 

Row 414 RD# HM-278309 (Year 2006) (Area 1) ........................................................ 59-60 

Row 415 RD# HM-304212 (Year 2006) (Area 1) ........................................................ 59-60 

Row 416 RD# HM-307550 (Year 2006) (Area 1) ........................................................ 59-60 

Row 417 RD# HM-318752 (Year 2006) (Area 1) ........................................................ 59-60 

Row 418 RD# HM-341097 (Year 2006) (Area 1) ........................................................ 61-62 

Row 419 RD# HM-353304 (Year 2006) (Area 1) ........................................................ 61-62 

Row 420 RD# HM-366735 (Year 2006) (Area 1) ........................................................ 61-62 

Row 421 RD# HM-367019 (Year 2006) (Area 1) ........................................................ 61-62 

Row 422 RD# HM-372012 (Year 2006) (Area 1) ........................................................ 61-62 

Row 423 RD# HM-414793 (Year 2006) (Area 1) ........................................................ 61-62 

Row 424 RD# HM-419168 (Year 2006) (Area 1) ........................................................ 61-62 

Row 425 RD# HM-445290 (Year 2006) (Area 1) ........................................................ 61-62 

Row 426 RD# HM-449389 (Year 2006) (Area 1) ........................................................ 61-62 

Row 427 RD# HM-478600 (Year 2006) (Area 1) ........................................................ 61-62 

Row 428 RD# HM-492478 (Year 2006) (Area 1) ........................................................ 61-62 

Row 429 RD# HM-501773 (Year 2006) (Area 1) ........................................................ 61-62 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 258 of 433 PageID #:15679
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

1 E-010765 1983 4 Cecil Robinson YES YES

Area Central Basement 

000000002-04; Area 

Central Basement 

000000038-39 Area 

Central Basement 

000000044; Area 

Central Basement 

000000057-61; Area 

Central Basement 

000000076; Area 

Central Basement 

000000082 Area 

Central Basement 

000000091-95

NO N/A NO N/A YES

Area Central Basement 

0000002; Area Central 

Basement 0000044; 

Area Central Basement 

0000059; Area Central 

Basement 0000071; 

Area Central Basement 

0000076; Area Central 

Basement 0000079; 

Area Central Basement 

0000091 

NO N/A YES Area Central Basement 0000003-04 NO 9 Handwritten notes in file, 0 listed on Inventory YES

Area Central Basement 

0000002; Area Central 

Basement 0000044; Area 

Central Basement 0000059; 

Area Central Basement 

0000071; Area Central 

Basement 0000076; Area 

Central Basement 0000079; 

Area Central Basement 

0000091 

YES

Area Central 

Basement 0000063; 

Area Central 

Basement 0000081

2 E-026792 1983 1

Derrick Kees 

William Doyle

JL Houston

Edgar Cooksey

Jackie Clay

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES CITY-NF-13115-13117 NO

14 Handwritten notes in file, 2 listed on 

Inventory

17 To-from memos in file, 5 listed on Inventory

YES

CITY-NF-13114; CITY-NF13120-13121; CITY-NF13126; CITY-NF-13128; CITY-NF-13130; CITY-NF13132; CITY-NF-13135; CITY-NF-13137; CITY-NF13176; CITY-NF-13178; 

CITY-NF013191-13193; 

CITY-NF-13195; CITY-NF13211

YES

CITY-NF-13129; CITY-NF-13131; CITY-NF-13155-

13156; CITY-NF13161-13164; CITYNF-13170; CITY-NF13171; CITY-NF13184-13189; CITYNF-13202; CITY-NF13218; CITY-NF13220; CITY-NF13223-13225

3 E-221919 1983 1 Peter Saunders NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A YES

ACB 005210; ACB 005215; ACB 005220; ACB 005222; 

ACB 005224

YES

ACB 005214; ACB 

005218-5219; ACB 

005225-5226

4 E-277036 1983 4 Ramiro Rodriguez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 005244-5245 NO 7 Handwritten notes in file, 0 listed on Inventory YES

ACB 005307; ACB 005339-

5340; ACB 005346-5352; 

ACB 005354; ACB 005356-

5358

YES ACB 005309

5 E-348611 1983 4 George Davis NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 005404-5405 NO Supp Report/Line Up Report (ACB 005367- 5368) NO N/A NO N/A

6 E-395970 1983 4 Edwardo Celedon NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 005408-5409 NO

14 GPRs in file, 4 listed on Inventory

13 Handwritten notes in file, 0 listed on 

Inventory 

3 To-from memos, 1 listed on Inventory

YES

ACB 005442-5443; ACB 

005455; ACB 005460-5461; 

ACB 005525-5526; ACB 

005552; ACB 005559-5560

YES

ACB 005410; ACB 

005414; ACB 005463; ACB 005474; ACB 005527; ACB 005554; ACB 

005562

7 E-399564 1983 4 Serafin Flores Rafael Rodriguez YES YES

ACB 005572-73; ACB 

005578; ACB 005581; 

ACB 005586; ACB 

005589-90; ACB 

005593; ACB 005599; 

ACB 005601-11; ACB 

005618-19; ACB 

005622; ACB 005627; 

ACB 005633; ACB 

005644; ACB 005636; 

ACB 005756-57; ACB 

005656-563; ACB 

005675-84; ACB 

005693-699; ACB 005709-719; ACB 

005759-78; ACB 

005686

YES YES NO N/A YES

*ACB 005586*ACB 005608*ACB 005627*ACB 005686

NO N/A YES ACB 005574-77 NO

23 GPRs in file, 19 listed on Inventory 

9 Handwritten notes in file, 0 listed on 

Inventory 

1 To-from memo, 0 listed in Inventory 

YES

ACB 005586; ACB 005608; 

ACB 005623; ACB 00 5650-

5652; ACB 005664; ACB 

005686; ACB 005759; ACB 

005765-5776

YES ACB 005599

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

1 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 259 of 433 PageID #:15680
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

1 E-010765 1983 4 Cecil Robinson2 E-026792 1983 1

Derrick Kees 

William Doyle

JL Houston

Edgar Cooksey

Jackie Clay

3 E-221919 1983 1 Peter Saunders4 E-277036 1983 4 Ramiro Rodriguez5 E-348611 1983 4 George Davis6 E-395970 1983 4 Edwardo Celedon7 E-399564 1983 4 Serafin Flores Rafael Rodriguez

IDENTIFYING INFORMATION

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

YES NO N/A YES 

Area Central Basement 0000065; 

Area Central Basement 0000069-70; 

Area Central Basement 0000078

YES

Area Central Basement 

0000002; Area Central 

Basement 0000044; Area 

Central Basement 0000059; 

Area Central Basement 

0000071; Area Central 

Basement 0000076; Area 

Central Basement 0000079; 

Area Central Basement 

0000091 

YES

Area Central 

Basement 0000063; 

Area Central 

Basement 0000081

Area Central Basement 0000050-54; Area Central Basement 0000075; Area Central Basement 

0000086-89; Area Central Basement 0000066; Area Central Basement 0000080

Area Central Basement 0000073; Area Central Basement 0000083

Area Central Basement 0000084; Area Central Basement 0000094-95; Area Central Basement 

0000043-45; Area Central Basement 0000067; 

Body Diagram (Area Central Basement 0000026)

Arrest Report (Area Central Basement 0000038; Area Central Basement 0000040; Area Central 

Basement 0000068)

Issued Stamp (Area Central Basement 0000039)

Witness Statement (Area Central Basement 0000041-42)

Request for Latent Fingerprint Comparison (Area Central Basement 0000046; Area Central 

Basement 0000064; Area Central Basement 0000072)

Fingerprint Result (Area Central Basement 0000047)

Lab Report (Area Central Basement 0000048; Area Central Basement 0000055-56)

Latent Fingerprint Exam. Report (Area Central Basement 0000049; Area Central Basement 

0000077)

Case Report (Area Central Basement 0000057-58; Area Central Basement 0000060-61)

Major Crime Worksheet (Area Central Basement 0000062)

Attorney Letter (Area Central Basement 0000082)

Business Card (Area Central Basement 0000092-93)

YES NO N/A YES 

CITY-NF-13125-13127; CITY-NF13167-13168; CITY-NF-13172-

13183; CITY-NF-13194; CITY-NF13208-13210; CITY-NF-13216-

13219

YES

CITY-NF-13114; CITY-NF13120-13121; CITY-NF13126; CITY-NF-13128; CITY-NF-13130; CITY-NF13132; CITY-NF-13135; CITY-NF-13137; CITY-NF13176; CITY-NF-13178; 

CITY-NF013191-13193; 

CITY-NF-13195; CITY-NF13211

YES

CITY-NF-13129; CITY-NF-13131; CITY-NF-13155-

13156; CITY-NF13161-13164; CITYNF-13170; CITY-NF13171; CITY-NF13184-13189; CITYNF-13202; CITY-NF13218; CITY-NF13220; CITY-NF13223-13225

CITY-NF-13196-13201; CITY-NF-13228-13229; CITY-NF-13206-13207; CITY-NF-13230-

13231; CITY-NF-13232

Case Assignment Slip (CITY-NF-13112)

Inv. File Control (CITY-NF-13119)

Form 101 (CITY-NF-13133; CITY-NF-13227)

Major Crime Worksheet (CITY-NF-13134; CITY-NF-13204-13205)

Case Report (CITY-NF-13136; CITY-NF-13138-13141; CITY-NF-13147-13149; CITY-NF-13152-

13153)

Supp Report (CITY-NF-13142-13146; CITY-NF-13150-13151)

Grand Jury Subp (CITY-NF-13154; CITY-NF-13226)

Major Gang Incident Report (CITY-NF-13157-13158; CITY-NF-13221-13222)

Shoot/Serious Incident Report (CITY-NF-13159-13160)

Secretary of State Letter (CITY-NF-13165-13166)

Polygraph Case Report (CITY-NF-13190)

Release of Person in Custody (CITY-NF-13215)

YES N/A N/A YES ACB 005217 YES

ACB 005210; ACB 005215; ACB 005220; ACB 005222; 

ACB 005224

YES

ACB 005214; ACB 

005218-5219; ACB 

005225-5226

ACB 005207; ACB 005208; ACB 005209; ACB 005221; ACB 005223

Copy of Envelope (ACB 005206)

Business Card (ACB 005211-5212)

Inv. File Control (ACB 005213)

Chicago Patrolmen's Assoc. (ACB 005216; ACB 005238-5239)

Supp Report (ACB 005240-5242)

YES NO N/A YES ACB 005317-5338 YES

ACB 005307; ACB 005339-

5340; ACB 005346-5352; 

ACB 005354; ACB 005356-

5358

YES ACB 005309

ACB 005287-5292; ACB 005311; ACB 005306; ACB 005345-5352; ACB 005355-5358; ACB 

005360; ACB 005359; ACB 005361; ACB 005362-5364; ACB 005280; ACB 005285; ACB 

005293-5296; ACB 005302-5305; ACB 005343

Supp Report (ACB 005246-5255; ACB 005274-5277)

Case Report with Handwritten notes (ACB 005278-5279)

Letter to FBI (ACB 005281-5282)

Daily Major Incident Log (ACB 005283-5284)

Stop Order (ACB 005286)

Arrest Report (ACB 005297)

Form 101 (ACB 005298)

Fingerprint Sheet (ACB 005299-5301; ACB 005310)

Commanding Officer Notice Form (ACB 005308)

Clear Data Warehouse (ACB 005312)

Witness Statement (ACB 005313-5316)

Copy of Envelope (ACB 005344)

Business Card (ACB 005353)

YES YES YES NO N/A NO N/A NO N/A Form 101 (ACB 005366) Supp Reports (ACB 005367-5368)

YES NO N/A YES 

ACB 005415; ACB 005441; ACB 

005452-5453; ACB 005457-5459; 

ACB 005475; ACB 005524; ACB 

005549-5550; ACB 005556-5558

YES

ACB 005442-5443; ACB 

005455; ACB 005460-5461; 

ACB 005525-5526; ACB 

005552; ACB 005559-5560

YES

ACB 005410; ACB 

005414; ACB 005463; 

ACB 005474; ACB 

005527; ACB 005554; 

ACB 005562

ACB 005430-5435; ACB 005507-5512; ACB 005447; ACB 005451; ACB 005534; ACB 005547-

5548; ACB 005448; ACB 005528; ACB 005535-5537; ACB 005426; ACB 005456; ACB 005498; 

ACB 005555; ACB 005570; Case Assignment Slip (ACB 005407); Arrest Report (ACB 005412; 

ACB 005470); Form 101 (ACB 005413; ACB 005425; ACB 005437; ACB 005471; ACB 005473; 

ACB 005494-5495; ACB 005497; ACB 005516); Extradition Order (ACB 005416; ACB 005476); 

AT&T Bill (ACB 005417-5424); Stop Order (ACB 005427-5429; ACB 005446; ACB 005450; 

ACB 005502-5505; ACB 005532; ACB 005546); Grand Jury Subp (ACB 005436; ACB 005496; 

ACB 005515); Material Submitted for Daily Bulletin (ACB 005438; ACB 005517); Arrest Warrant 

(ACB 005439; ACB 005522); Complaint (ACB 005440; ACB 005523); Latent Fingerprint Exam. 

Report (ACB 005444; ACB 005530); Receipt for Exhibits (ACB 005445; ACB 005531); Body 

Diagram (ACB 005449; ACB 005545); Arrest Information Card (ACB 005454; ACB 005551); 

Major Crime Worksheet (ACB 005462; ACB 005553; ACB 005561); Emergency Room Record 

(ACB 005464; ACB 005563); Illinois Bell Records (ACB 005482-5489); Wanted Card (ACB 

005499); Inv. File Control (ACB 005571)

YES YES YES YES 

ACB 005582; ACB 005594-5598; 

ACB 005665-5669; ACB 005701-

5705; ACB 005748-5755

YES

ACB 005586; ACB 005608; 

ACB 005623; ACB 00 5650-

5652; ACB 005664; ACB 

005686; ACB 005759; ACB 

005765-5776

YES ACB 005599

ACB 005612-5617; ACB 005629-5630; ACB 005647-5649; ACB 005653-5655; ACB 005732-

5734; ACB 005600; ACB 005620-5621; ACB 005670-5671; ACB 005758-5778; ACB 005585; 

ACB 005597; ACB 005632; ACB 005635-5644; ACB 005691; ACB 005737

Case Assignment Slip (ACB 005573)

Form 101 (ACB 005581; ACB 005603)

Fingerprint Sheet (ACB 005583-5584; ACB 005634)

Towed Vehicle Disposition (ACB 005587-5588; ACB 005591)Latent Fingerprint Exam. Report (ACB 005592; ACB 005628)

Stop Order (ACB 005624-5627; ACB 005631; ACB 005672-5674; ACB 005735; ACB 005746)

Wanted Card (ACB 005633)

Arrest Warrant (ACB 005685; ACB 005687; ACB 005689-5690)

Complaint (ACB 005688)

Vehicle Tow Report (ACB 005700)

Body Diagram (ACB 005706)

Report (cut off) (ACB 005707)

Arrest Report (ACB 005720-5731; ACB 005736; ACB 005747)

Inv. File Control (ACB 005756)

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

2 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 260 of 433 PageID #:15681
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

8 E-442815 1983 1 Kevin Truitt NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A YES

ACB 005798; ACB 005852-

5855; ACB 005887-5892; 

ACB 005910-5924

YES

ACB 005838-5839; 

ACB 005880; ACB 

005925

9 E-475100 1983 1 Joseph Walker NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A YES

ACB 005948-5963; ACB 

005967; ACB 005976-5977; ACB 005980; ACB 005986-

5988; ACB 006003; ACB 

006007; ACB 006010; ACB 006015; ACB 006017; ACB 

006021

YES

ACB 005989-5997; 

ACB 006000; ACB 

006004-6005; ACB 

006009; ACB 006011; ACB 006023; ACB 006027; ACB 

006029

10 F-048933 1984 4 Christino Garcia YES YES

ACB 006051; ACB 

006053; ACB 

006078;ACB 006118-

19; ACB 006122-25; 

ACB 006083; ACB 

006096; ACB 006115; 

ACB 006120-21; ACB 

006126-65;

YES YES NO N/A YES

ACB 006051; ACB 

006053; ACB 006083; 

ACB 006096; ACB 

006115; ACB 006148

YES ACB 006150 YES ACB 006038 -6039 NO

6 Handwritten notes in file, 0 listed on 

Inventory 

2 To-from memos in file, 0 listed on Inventory

YES

ACB 006051; ACB 006083; ACB 006085; ACB 006096; 

ACB 006115

YES ACB 006072, ACB 006150

11 F-172852 1984 3 Jose Rodriguez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 006168 NO

Arrest Info Card (6186)

3 Court Attendance sheets in file, 1 listed on 

Inventory

YES ACB 006206-08 NO N/A

12 F-177096 1984 4 Byron Hammons NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 006213 NO 19 pages of GPRs/Handwritten notes in file, 13 pages of Notes/GPRs on inventory YES ACB 006222; ACB 006253; ACB 006255; ACB 006284 NO N/A13 F-229020 1984 3 James Grant NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 090457 - 90459 NO

18 GPRs in file, 17 listed on Inventory

21 Handwritten notes in file, 14 listed on 

Inventory

2 To-from memos in file, 0 listed on Inventory

YES

ACB 090482-90483; ACB 

090491; ACB 090506; ACB 

090517; ACB 090545-

90548; ACB 090550-90553; 

ACB 090571-90573; ACB 

090579-90580; ACB 

090588; ACB 090590; ACB 090592; ACB 090598; ACB 

090614-90615

YES ACB 090595

14 F-229039 1984 1 Richard Phillips NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A NO N/A NO N/A

3 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 261 of 433 PageID #:15682
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

8 E-442815 1983 1 Kevin Truitt9 E-475100 1983 1 Joseph Walker

10 F-048933 1984 4 Christino Garcia11 F-172852 1984 3 Jose Rodriguez12 F-177096 1984 4 Byron Hammons13 F-229020 1984 3 James Grant14 F-229039 1984 1 Richard Phillips

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES N/A N/A NO N/A YES

ACB 005798; ACB 005852-

5855; ACB 005887-5892; 

ACB 005910-5924

YES

ACB 005838-5839; 

ACB 005880; ACB 

005925

ACB 005879; ACB 005893-5896; ACB 005900-5923; ACB 005863; ACB 005865-5867; ACB 

005885

Grand Jury Subp (ACB 005840-5843; ACB 005872)

Form 101 (ACB 005844-5848; ACB 005870-5871)

Phone Records (ACB 005849-5851)

Vehicle Tow Report (ACB 005859-5860; ACB 005881-5884)

Teletype Message (ACB 005861-5862)

Stop Order (ACB 005864; ACB 005886)

Latent Fingerprint Exam Report (ACB 005868-5869)

Daily Bulletin (ACB 005873-5878)

Crime Analysis Pattern (ACB 005891)

Copy of Envelope (ACB 005898-5899)

Case Report (ACB 005926-5927)

Supp Report (ACB 005928-5931)

YES N/A N/A YES 

ACB 005973; ACB 005979-5984; ACB 005994; ACB 005998-6002; 

ACB 006014-6020

YES

ACB 005948-5963; ACB 

005967; ACB 005976-5977; ACB 005980; ACB 005986-

5988; ACB 006003; ACB 

006007; ACB 006010; ACB 006015; ACB 006017; ACB 

006021

YES

ACB 005989-5997; ACB 006000; ACB 006004-6005; ACB 

006009; ACB 006011; 

ACB 006023; ACB 

006027; ACB 006029

ACB 005933-5934; ACB 005965-5966; ACB 005964; ACB 005974-5975; ACB 006022

ID Cards (ACB 005935-5942)

Bank cards (ACB 005943-5946)

Business card (ACB 005947)

Supp Report (ACB 005968-5969; ACB 005971-5972)

Case Report (ACB 005970)

Release of Person in Custody (ACB 005978)

Major Crime Worksheet (ACB 005985; ACB 006028)

Calendar (ACB 006012-6013)

YES NO N/A YES ACB 006080; ACB 006106 – 6114; ACB 006116 YES ACB 006051; ACB 006083; ACB 006085; ACB 006096; ACB 006115 YES ACB 006072

ACB 006065 – 6069; ACB 006052 - 6053; ACB 006054 – 6055; ACB 006056; ACB 006090; 

ACB 006120 - 6121

•ACB 006118 - 6119; ACB 006050; ACB 006095; General Offense Case Report: ACB 006040; 

Supplementary Report: ACB 006042-6043; ACB 006045 – 6048; ACB 006062; Request for Latent 

Fingerprint Comparison: ACB 006049; Typed Record: ACB 006064; 101’s: ACB 006073; ACB 

006075; Grand Jury Subpoena: ACB 006074; Daily bulletin: ACB 006077; Daily hot sheet: ACB 

006078; Latent Fingerprint Examination Report: ACB 006081; Request for Fingerprint 

Comparison: ACB 006082; Material Submitted for use in the daily bulletin: ACB 006084; Stop 

Order Cancellation Request: ACB 006086 – 6087; Body Diagram: ACB 006098; City of Chicago, 

Department of Police envelope: ACB 006117; Illinois Driver’s license: ACB 006122; Typed 

attorney contact information: ACB 006123; Investigative File Control: ACB 006124 – 6125; ACB 

006165; Vehicle status record: ACB 006126 – 6138; Secretaria De Relaciones Exteriores Envelope 

and letter: ACB 006139 – 6141; Phone service and equipment print out: ACB 006142 – 6147; 

Business Card: ACB 006148 – 6149; Typed Memo: ACB 006150; Firestone invoice: ACB 006151 

– 6152; State of Illinois office of the Secretary of State certificate: ACB 006153; Vehicle certificate 

of title: ACB 006154; ACB 006157 - 6159; Affidavit: ACB 006155; Certified copy of title history 

covering: ACB 006160 - 6164

YES NO N/A YES ACB 006200 – 6205; ACB 006209 - 6211 YES ACB 006206-08 NO N/A

ACB 006180 – 6184; ACB 006191 - 6193; ACB 006196; ACB 006197 - 6198; Major Crime 

Worksheet: ACB 006199

Investigation File Control: ACB 006170 

Court Attendance Report: ACB 006179; ACB 006187; ACB 006188

Arrest Information: ACB 006186

Arrest Report: ACB 006189

101s: ACB 006190

Latent Fingerprint Exhibit: ACB 006194 – 6195

YES NO N/A YES 

ACB 006232; ACB 006244; ACB 

006254; ACB 006270; ACB 006281 

– 6283; ACB 006285 - 6291

YES ACB 006222; ACB 006253; ACB 006255; ACB 006284 NO N/A

ACB 006216 - 6220; ACB 006275; ACB 006276; ACB 006251; ACB 006252; ACB 006272; ACB 

006273 - 6274; ACB 006268 - 6269; ACB 006221; ACB 006233; ACB 006246; ACB 006271; 

Supplementary Report: ACB 006259 

CPD report: ACB 006227

Court Attendance Report: ACB 006228

Body Diagram: ACB 006231

Statement: ACB 006242 – 6243

Arrest Warrant: ACB 006245

101s: ACB 006277

Arrest Report: ACB 006278

Statement: ACB 006279 – 6280

Investigative File Control: ACB 006292

YES NO N/A YES 

ACB 090475 – 90481; ACB 090484; 

ACB 090544; ACB 090554; ACB 

090574 – 90577; ACB 090581; ACB 

090583; ACB 090586

YES

ACB 090482-90483; ACB 

090491; ACB 090506; ACB 

090517; ACB 090545-

90548; ACB 090550-90553; 

ACB 090571-90573; ACB 

090579-90580; ACB 

090588; ACB 090590; ACB 090592; ACB 090598; ACB 

090614-90615

YES ACB 090595

ACB 090496 - 90501; ACB 090473; ACB 090474; ACB 090490; ACB 090495; ACB 090509 – 

90510; ACB 090511 – 90512; ACB 090513 – 90514; ACB 090558; ACB 090603 - 90613; ACB 

090463; ACB 090464; ACB 090488; ACB 090493; ACB 090494; ACB 090556; ACB 090560; 

ACB 090562; ACB 090564; ACB 090558; ACB 090585

Case Assignment Slip: ACB 090460

Arrest Report: ACB 090485; ACB 090486; ACB 090487; ACB 090556; ACB 090594

Arrest Information/Chicago Police: ACB 090489; ACB 090570

Latent Fingerprint Examination Report: ACB 090492

Stop Order or Cancellation Request: ACB 090502 – 90505

Court Attendance Report: ACB 090509 – 90508

Receipt for Exhibits: ACB 090515; ACB 090516 

Permit Items Slip: ACB 090518 

CPD form: ACB 090521; ACB 090525

Case Report: ACB 090527; ACB 090528; ACB 090529 - 90530 

Misdemeanor Complaint: ACB 090549

Major Crime Worksheet: ACB 090578

Typed Memo: ACB 090590; ACB 090600

Identification Index: ACB 090593

Response to Defendant’s Memo to Dismiss: ACB 090596

Chicago Police Intra-Departmental Mail Envelope: ACB 090602

YES N/A N/A YES ACB 006316 NO N/A NO N/A

Arrest Report: ACB 006313; ACB 006314

101’s: ACB 006315

General Offense Case Report: ACB 006317

4 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 262 of 433 PageID #:15683
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

15 F-277122 1984 1 Robert Davis Darryll Reid NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 006321 – 6323; ACB 006466 -6467 NO 14 GPRs in file, 12 listed on Inventory 6 Handwritten notes in file, 0 listed on Inventory YES ACB 006347; ACB 006349; ACB 006358; ACB 006368; ACB 006407 NO N/A

16 F-299912 1984 3 Armando Valdez, Javier Garcia NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 006514 NO 6 Handwritten notes in file, 3 listed on Inventory YES ACB 006576; ACB 006580; ACB 006586-87; ACB 006589; ACB 006595 NO N/A

17 F-308281 1984 3 Joe Metoxen NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 006614-6615 NO

14 GPRs in file, 13 listed on Inventory

4 Handwritten notes in file, 1 listed on 

Inventory

YES ACB 006639; ACB 006658 NO N/A

18 F-336114 1984 3 Elroy Morgan NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 006919-6921 NO 19 Handwritten notes in file, 13 listed on Inventory YES

ACB 006922-23; ACB 

006952-53; ACB 006959; 

ACB 006992; ACB 006996; 

ACB 007003-05; ACB 

007007; ACB 007009-18; 

ACB 007022; ACB 007033

YES ACB 006986

19 F-380662 1984 4 Lindsey Cannon YES YES

ACB 007075-77; ACB 

007087; ACB 007123; 

ACB 007137; ACB 

007141-44; ACB 

007158; ACB 007171-

96

NO N/A YES ACB 00 7179 - 7180 NO N/A NO N/A YES ACB 007075 NO 6 Handwritten notes in file, 0 listed on Inventory YES ACB 007135; ACB 007160 NO N/A

20 F-430186 1984 1 Terrance Brown NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A YES ACB 007310; ACB 007312; ACB 007328; ACB 007330 YES ACB 007307

5 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 263 of 433 PageID #:15684
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

15 F-277122 1984 1 Robert Davis Darryll Reid

16 F-299912 1984 3 Armando Valdez, Javier Garcia

17 F-308281 1984 3 Joe Metoxen18 F-336114 1984 3 Elroy Morgan19 F-380662 1984 4 Lindsey Cannon20 F-430186 1984 1 Terrance Brown

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 006360 – 6367; ACB 006369 – 6372; ACB 006398; ACB 006403 YES ACB 006347; ACB 006349; ACB 006358; ACB 006368; ACB 006407 NO N/A

ACB 006329 - 6334; ACB 006400; ACB 006402; ACB 006408; ACB 006409 – 6410; ACB 

006411; ACB 006412; ACB 006413; ACB 006414; ACB 006416; ACB 006415; ACB 006401; 

ACB 006341; ACB 006342; ACB 006344; ACB 006357; ACB 006405; ACB 006406; ACB 

006417; ACB 006469 – 6473; ACB 006475 – 6481; ACB 006483 – 6491; ACB 006493; ACB 

006496; ACB 006494 – 6495; ACB 006497 – 6519; ACB 006511; ACB 006345;

 Court Attendance Report: ACB 006324 – 6328; ACB 006335 – 6339; ACB 006356; ACB 006359

Investigative Request to the Chicago Police Department Crime Lab: ACB 006340

Firearms work sheet: ACB 006343

Request for Latent Fingerprint Comparison: ACB 006346

Firearms Receipt & Worksheet: ACB 006348 

Latent Fingerprint Examination Report: ACB 006352; ACB 006353

Statement: ACB 006381 – 6397; ACB 006418 – 6429; ACB 006430 – 6431; ACB 006432; ACB 

006433 – 6445; ACB 006446 – 6447; ACB 006448 - 6449

Stop Order/Missing Person printout: ACB 006399; ACB 006404

Juvenile Field Arrest Report: ACB 006450

Arrest Report: ACB 006451

General offense case report: ACB 006452 – 6453

Chicago Police Inter-Departmental Mail Envelope: ACB 006468

Envelope: ACB 006474; ACB 006482; ACB 006492

YES NO N/A YES ACB 006590 - 6594 YES

ACB 006576; ACB 006580; 

ACB 006586-87; ACB 

006589; ACB 006595

NO N/A

ACB 006578; ACB 006583; ACB 006544; ACB 006579; ACB 006584; ACB 006518 – 6524; 

ACB 006611

ACB 006597 - 6610; ACB 006525; ACB 006545;

Major Crime Worksheet: ACB 006588

Investigative File Control: ACB 006516 

Envelope: ACB 006517

Court Attendance Report: ACB 006526 – 6527; ACB 006540 – 6541

Order: ACB 006543

Statement: ACB 006547 – 6556; ACB 006557 – 6568

Latent Fingerprint Examination Report: ACB 006569; ACB 006571

Case Assignment Slip: ACB 006570

Arrest Report: ACB 006572 – 6573

Vehicle Tow Report: ACB 006574

Criminal Investigation Division form: ACB 006577

Receipt for Exhibits: ACB 006581 – 6582

Chicago Police Intra-Departmental Mail Envelope: ACB 006596

YES YES YES YES 

ACB 006656 – 6657; ACB 006659 – 

6661; ACB 006664 – 6665; ACB 

006667 – 6669; ACB 006672 - 6675

YES ACB 006639; ACB 006658 NO N/A

ACB 006670 - 6671; ACB 006634; ACB 006640; ACB 006666; ACB 006619; ACB 006635; ACB 

006638

Case Assignment Slip: ACB 006617

Investigative File Control: ACB 006618 Court Attendance Report: ACB 006620 

Report: ACB 006630 – 6631; ACB 006632 – 6633

Latent Fingerprint Examination Report: ACB 006637

Statement: ACB 006642 – 6655

Vehicle Tow Report: ACB 006662

YES YES YES YES ACB 006987 – 6991; ACB 006993 – 6995; ACB 006997 - 7002 YES

ACB 006922-23; ACB 

006952-53; ACB 006959; 

ACB 006992; ACB 006996; 

ACB 007003-05; ACB 

007007; ACB 007009-18; 

ACB 007022; ACB 007033

YES ACB 006986

ACB 006933 – 6936; ACB 007020 – 7021; ACB 006958; ACB 006984; ACB 006985; ACB 

006937; ACB 006968; ACB 006974; ACB 006978 – 6979; ACB 007038 – 7051; ACB 007054 – 

7064; ACB 007072

ACB 007065 - 7071; AB 006938; ACB 006971; ACB 006975; ACB 006976; ACB 006980; ACB 

006981; ACB 007024; ACB 007025

Investigative File Control: ACB 006924 

Major Crime Worksheet: ACB 006942

Arrest Report: ACB 006969; ACB 007026; ACB 007027

Arrest Information: ACB 006970; ACB 006973; ACB 006977; ACB 006982; ACB 007028

101’s: ACB 006972

Supplementary Report: ACB 007006; ACB 007008; ACB 007023

Court Attendance Report: ACB 007019

Fingerprint form: ACB 007029 – 7032

Chicago Police Intra-Departmental Mail Envelope: ACB 007034

Envelope: ACB 007035 – 7036

Business Card: ACB 007037

Driver’s License: ACB 007052 – 7053

Soundex Page Response: ACB 007073

YES NO N/A YES 

ACB 007106 – 7118; ACB 007145 – 

7146; ACB 007152 – 7156; ACB 

007167; ACB 007179 - 7180

YES ACB 007135; ACB 007160 NO N/A

ACB 007088 – 7092; ACB 007105; ACB 007086; ACB 007147; ACB 007119; ACB 007120; 

ACB 007161 - 7162; ACB 007087; ACB 007121; ACB 007122; ACB 007183 - 7195; ACB 

007182; ACB 007142; ACB 007171; ACB 007172

Receipt for Exhibits: ACB 007123

Statements: ACB 007124 – 7134

Arrest Report: ACB 007136; ACB 007137; ACB 007138; ACB 007141; ACB 007173; ACB 

007174; ACB 007175; ACB 007176; ACB 007177; ACB 007178

General Offense Case Report: ACB 007143 – 7144

Arrest Card: ACB 007158

Body Diagram: ACB 007170 

City of Chicago Envelope: ACB 007181

Investigative File Control: ACB 007196

YES N/A N/A YES ACB 007308; ACB 007309; ACB 007311; ACB 007319; ACB 007320 YES ACB 007310; ACB 007312; ACB 007328; ACB 007330 YES ACB 007307

ACB 007318; ACB 007313; ACB 007316; ACB 007317

Arrest Report: ACB 007314

Arrest Information: ACB 007315

Field Inquiry Sheet: ACB 007327

Body Diagram: ACB 007343 - 7344

6 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 264 of 433 PageID #:15685
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

21 F-445484 1984 4 Louis Foster NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007358 – 7359 NO

2 Handwritten notes in file, 0 listed on 

Inventory

1 To-from memo in file, 0 listed on Inventory

YES ACB 007361; ACB 007389; ACB 007391; ACB 007448 NO N/A

22 F-492465 1984 3 Jose Estrada NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007565-7567 NO

37 GPRs in file, 36 listed on Inventory 

22 Handwritten notes in file, 20 listed on 

Inventory 

6 To-from memos in file, 0 listed on Inventory

YES

ACB 007624; ACB 007645; ACB 007651; ACB 007685; 

ACB 007715; ACB 007718-

7720; ACB 007727-7731; 

ACB 007747

YES

ACB 007625; ACB 

007635-7636; ACB 

007686

23 G-011265 1985 1 Leonard Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 008829 NO 9 Handwritten notes in file, 1 listed on Inventory YES

ACB 008849; ACB 008877; ACB 008888; ACB 008894; ACB 008896; ACB 008898; ACB 008900; ACB 008902; 

ACB 008904

NO N/A

24 G-011889 1985 1 Earl Stademeyer YES YES

ACB 008911; ACB 

008913; ACB 008941-

42; ACB 008952; ACB 

008971-78

YES

NO - additional 

entries after 

6/28/1985

(ACB 008911 in 

Inv. file; 

CRIM.DEF FILES - 

FIELDS 041036-41037 in PD file)

NO N/A YES *ACB 008952 NO N/A YES ACB 008911 - 8912 NO

13 GPRs in file, 12 on Inventory

2 Handwritten notes in file, 0 listed on 

Inventory

4 To-from memos in file, 2 listed on Inventory

YES ACB 008917; ACB 008952 YES

ACB 008951; ACB 

008953; ACB 008968; ACB 

008969

25 G-014815 1985 1 Guy Johns YES YES

ACB 008987; ACB 

008989-90; ACB 

008992; ACB 009007-

09; ACB 009067; ACB 

009091-93

YES

NO - additional 

entries after 

7/5/1985

 (ACB 008986-

8987 in Inv. File; 

CRIM.DEF FILE - 

FIELDS 047677-47678 in PD file)

NO N/A YES ACB 008992; ACB 009067; ACB 009091 NO N/A YES ACB 008986 -8987 NO 19 GPRs in file, 12 listed on Inventory 7 Handwritten notes in file, 0 listed on Inventory YES ACB 009006; ACB 009065; ACB 009067; ACB 009089; ACB 009091; ACB 009101; ACB 009103; ACB 009105 NO N/A

26 G-027619 1985 1 Decco Brown NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009114 NO

11 GPRs in file, 2 listed on Inventory

7 Handwritten notes in file, 0 listed on 

Inventory

1 To-from memo in file, 0 listed on Inventory

YES

ACB 009134; ACB 009138; ACB 009164; ACB 009166; ACB 009168; ACB 009170; 

ACB 009172

YES ACB 009128

27 G-032161 1985 1 Jerome Jackson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009174 NO 1 Handwritten note in file, 0 listed on Inventory YES ACB 009207 NO N/A

28 G-049257 1985 1 Joe Brooks NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009422 YES N/A NO N/A NO N/A

7 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 265 of 433 PageID #:15686
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

21 F-445484 1984 4 Louis Foster22 F-492465 1984 3 Jose Estrada23 G-011265 1985 1 Leonard Williams24 G-011889 1985 1 Earl Stademeyer25 G-014815 1985 1 Guy Johns26 G-027619 1985 1 Decco Brown27 G-032161 1985 1 Jerome Jackson28 G-049257 1985 1 Joe Brooks

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 007386 – 7388; ACB 007390; ACB 007392 - 7394 YES ACB 007361; ACB 007389; ACB 007391; ACB 007448 NO N/A

ACB 007362 – 7366; ACB 007370 – 7371; ACB 007410 – 7413; ACB 007420 - 7423; ACB 

007372; ACB 007374; ACB 007368; ACB 007373; ACB 007380;

Investigative File Control: ACB 007357; ACB 007425; Receipt for Exhibits: ACB 007367; Latent 

Fingerprint Examination Report: ACB 007369; Body Diagram: ACB 007379; Chess Memo: ACB 

007395; ACB 007405; Original Case Incident Report: ACB 007396 – 7398; Case Supplementary 

Report: ACB 007399 – 7400; ACB 007401 – 7404; ACB 007406 – 7409; ACB 007414 – 7419; 

Envelope: ACB 007424; Saint Charles Saints: ACB 007426; Social Security Card: ACB 007427 – 

7428; Talisman Marabaki card: ACB 007429 – 7430; Lottery Card: ACB 007431 – 7440; Delivery 

Reminder or Receipt: ACB 007441 – 7442; Business Card: ACB 007443; Chicago Boys Clubs 

membership card: ACB 007444 – 7445; Armando’s card: ACB 007446; Taste of Chicago 50 cent 

value: ACB 007447 - 7448

YES NO N/A YES 

ACB 007623; 7676 – 7677; 7678 – 

7679; 7680 – 7681; 7682; 7683; 

7684; 7687 – 7688; 7689; 7690 – 7691; 7692 – 7693; 7694; 7695 – 

7696; 7697; 7698; 7699; 7700; 7701; 7702; 7704; 7705; 7706; 7707; 7708; 7709; 7710; 7711; 7712; 7713; 7714; 

7716; 7717; 7732; 7733; 7734

YES

ACB 007624; ACB 007645; ACB 007651; ACB 007685; 

ACB 007715; ACB 007718-

7720; ACB 007727-7731; 

ACB 007747

YES

ACB 07625; ACB 

07635 – 7636; ACB 

07686

Inventory Number 140826: ACB 007656; Inventory Number 13080: 7661; Inventory Number 

151602: 7662 – 7663; Inventory of things Seized in Search form: 7664; ACB 007616 – 7617; 7657 

– 7658; 7660; Person: ACB 007751 – 7764; 7766 – 7776; 7784; Scene: 7777 - 7783; ACB 007568 

– 7570; 7650; 7665; 7738; 7739

Supplementary report: 7722 - 7724; 7725; 7735 – 7736; 7737

Case Assignment Slip: 7562 

Inventory File Control: 7563 – 7567

Major Crime Worksheet: 7613; 7721

Statement: 7620 – 7622; 7646 – 7647; 7648; 7652 - 7654 

Letter: 7626; 7627; 7628 – 7629; 7630 – 7631; 7632 – 7633; 7634

Brea Police Department Special Service Sheet: 7637 – 7641; 7666 - 7667

Fingerprints: 7642; 7671 – 7672; 7675; 7743 - 7746

Illinois Certificate of title of a vehicle: 7643 – 7644

Illinois Vehicle Registration: 7645

Arrest Warrant: 7649

A&T Communications Itemized Calls: 7655

Latent Fingerprint Examination Report: 7659

Department of California Highway Patrol form: 7668Orange-County Jail Pre Booking Record: 7669; 7673

Brea Police Department Certificate of Release: 7670; 7674

Arrest Report: 7740; 7741

Arrest Information: 7742

Chicago Police Intra-Departmental Mail: 7748

Envelope: 7749 

Card: 7750

Illinois Driver’s License: 7765

Soundex Page Response: 7785

YES NO N/A YES 

ACB 008887; ACB 008889; ACB 

008890; ACB 008891; ACB 008892; 

ACB 008893; ACB 008895; ACB 

008897; ACB 008899; ACB 008901

YES

ACB 008849; ACB 008877; ACB 008888; ACB 008894; ACB 008896; ACB 008898; ACB 008900; ACB 008902; 

ACB 008904

NO N/A

Property Inventory #161756: 8847; Property Inventory #161755: 8848; Property Inventory 

#151276: 8861; Property Inventory #151277: 8862; Property Inventory #151274: 8863; Property 

Inventory #148620: 8903; 8850; 8864; 8906; Person/People: 8830; 8876

Investigative File Control: 8831Court Attendance Report: 8832

Body Diagram: 8833; 8867

Statement: 8853 – 8860; 8868 – 8875

101’s: 8905

Vehicle Tow Report: 8909

YES NO N/A YES ACB 008915 – 8916; ACB 008918 - 8928 YES ACB 008917; ACB 008952 YES ACB 008951; ACB 008953; ACB 008968; ACB 008969

8929 – 89 42; Property Inventory #151278: 8971; Property Inventory #151279: 8972; Property 

Inventory #151280: 8973; Property Inventory #151281: 8974; Property Inventory #148621: 8975; 

Property Inventory #148622: 8976; Property Inventory #148623: 8977; Property Inventory 

#148624: 8978; 8945; 8947 - 8948; 8979; 8980; Investigative File Control: 8913

Court Attendance Report: 8914; 8943; 8944

Release of Person in Custody: 8970 

101’s: 8981

Search consent: 8982

YES NO N/A YES 

ACB 009026 – 9030; ACB 009063 – 

9064; ACB 009080 – 9087; ACB 

009097; ACB 009100; ACB 009102; 

ACB 009104

YES

ACB 009006; ACB 009065; ACB 009067; ACB 009089; ACB 009091; ACB 009101; 

ACB 009103; ACB 009105

NO N/A

9007 – 9009; 9041; Property Inventory #161748: 9066

Property Inventory #158040: 9094Property Inventory #158041: 9095

Property Inventory #158042: 9096; 9005; 9025; 9050; 9090

Chicago Police Intra-Departmental Mail envelope: 8988

Investigative File Control: 8990

Latent Fingerprint Examination Report: 9010; 9035

Body Diagram: 9038 – 9040; 9092 - 9093

Receipt for Exhibits: 9088

Arrest Information: 9098 - 9099; 9112

Court Attendance Report: 9000; 9004

YES NO N/A YES 

ACB 009131 – 9137; ACB 009163; 

ACB 009165; ACB 009167; ACB 

009169; ACB 009171

YES

ACB 009134; ACB 009138; ACB 009164; ACB 009166; ACB 009168; ACB 009170; 

ACB 009172

YES ACB 009128

9119 - 9125; Property Inventory #165289: 9153; 9116; 9158; 9117; 9118; 9129;

Investigative File Control: 9115Court Attendance Report: 9146

Identification Check Procedure Control: 9127

To-From: 

Complaint for Preliminary Examination: 9130 

Diagram: 9156 – 9157

Statement: 9161 - 9162

YES NO N/A NO N/A YES ACB 009207 NO N/A

9176 - 9181; Property Inventory #14682: 9205; Investigative File Control: 9175

Statement: 9200 – 9203

101’s: 9204

YES NO N/A NO N/A NO N/A NO N/A

9426 - 9432; Property Inventory #167719: 9439; Investigative File Control: 9423

Court Attendance Report: 9425

Body Diagram: 9435

8 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 266 of 433 PageID #:15687
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

29 G-051225 1985 1 Jerry Monden NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009444 NO

12 GPRs in file, 1 listed on Inventory

6 Handwritten notes in file, 0 listed on 

Inventory

YES

 ACB 009467; ACB 009469; 

ACB 009473; ACB 009483; 

ACB 009485; ACB 009507

NO N/A

30 G-056199 1985 1 Maria Martin NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009514 NO 10 GPRs in file, 9 listed on Inventory NO N/A NO N/A31 G-087375 1985 1 Ronald Jones NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009669 - 9671 NO

27 GPRs in file, 22 listed on Inventory

23 Handwritten notes in file, 1 listed on 

Inventory

6 To-from memos in file, 0 listed on Inventory

YES

ACB 009676; ACB 009683-

85; ACB 009687; ACB 

009689; ACB 009694-95; 

ACB 009699; ACB 009701; 

ACB 009708-09; ACB 

009713; ACB 009715; ACB 

009723; ACB 009727-9728; ACB 009730; ACB 009742-

43; ACB 009746; ACB 

009748; ACB 009756-57; 

ACB 009768-69; ACB 

009778-81; ACB 009784; 

ACB 009792; ACB 009796; 

ACB 009799-800; ACB 

009820-22; ACB 009824-

25; ACB 009831; ACB 

009842; ACB 009849-50; 

ACB 009867; ACB 009877; 

ACB 009886; ACB 009889-

91; ACB 009896; ACB 

009898-99; ACB 009906-

07; ACB 009927-33; ACB 

009949; ACB 009959; ACB 

0010007; ACB 0010061; 

ACB 0010065; ACB 

0010072; ACB 0010085; 

ACB 0010087

Yes ACB 0010053

32 G-106586 1985 1 Alice Hamilton NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 010097 - 10098 NO 13 GPRs in file, 5 listed on Inventory 2 To-from memos in file, 1 listed on Inventory YES ACB 010124; ACB 010127; ACB 010175 YES ACB 010108

33 G-108642 1985 1 Roscoe Evans YES YES

ACB10441-43; 

ACB10453; 

ACB10459; ACB10462-

65; ACB10469; 

ACB10471; ACB10473; ACB10486; ACB10499; 

ACB10529; ACB10537

NO N/A NO N/A YES ACB 010499; ACB 010529; ACB 010537 YES ACB 010462; ACB 010463 YES ACB 010441 - 10442 NO 21 Handwritten notes in file, 8 listed on Inventory 3 To-from memos in file, 0 listed on Inventory YES ACB 010446; ACB 010470; ACB 010475; ACB 010494- 97; ACB 010529; ACB 010537; ACB 010548-55 YES ACB 010462; ACB 010493, ACB 010463

9 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 267 of 433 PageID #:15688
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

29 G-051225 1985 1 Jerry Monden30 G-056199 1985 1 Maria Martin31 G-087375 1985 1 Ronald Jones32 G-106586 1985 1 Alice Hamilton33 G-108642 1985 1 Roscoe Evans

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 009482; ACB 009484; ACB 009486 - ACB 009495 YES ACB 009467; ACB 009469; ACB 009473; ACB 009483; ACB 009485; ACB 009507 NO N/A

9449 - 9454; Property Inventory #168454: 9466

Property Inventory #168453: 9468Property Inventory #169250: 9474

Property Inventory #148699: 9504; 9445; 9472; 9446; 9496; 9497

Court Attendance Report: 9448

Body Diagram: 9470

Statement: 9498 – 9500; 9501 – 9503

Release of Person in Custody: 9505

Arrest Report: 9506

Case Report: 9508

Major Crime Worksheet: 9509

Memo: 9510

YES NO N/A YES ACB 009534 - 9543 NO N/A NO N/A

Property Inventory #167794: 9522; 9523; Investigative File Control: 9515

Court Attendance Report: 9516 – 9517; 9521

Diagram: 9520

Statement: 9530 - 9531

YES NO N/A YES 

ACB 009948; ACB 009998 – 10002; ACB 010004 – 10005; ACB 010010; 

ACB 010036 – 10044; ACB 010058 -

10059; ACB 010066 – 10071; ACB 

010073 – 10076; ACB 010077; ACB 

010084; ACB 010086; ACB 010088; 

ACB 010089

YES

ACB 009676; ACB 009683-

85; ACB 009687; ACB 

009689; ACB 009694-95; 

ACB 009699; ACB 009701; 

ACB 009708-09; ACB 

009713; ACB 009715; ACB 

009723; ACB 009727-9728; ACB 009730; ACB 009742-

43; ACB 009746; ACB 

009748; ACB 009756-57; 

ACB 009768-69; ACB 

009778-81; ACB 009784; 

ACB 009792; ACB 009796; 

ACB 009799-800; ACB 

009820-22; ACB 009824-25; 

ACB 009831; ACB 009842; 

ACB 009849-50; ACB 

009867; ACB 009877; ACB 

009886; ACB 009889-91; 

ACB 009896; ACB 009898-

99; ACB 009906-07; ACB 

009927-33; ACB 009949; 

ACB 009959; ACB 

0010007; ACB 0010061; 

ACB 0010065; ACB 

0010072; ACB 0010085; 

ACB 0010087

YES ACB 010053

9954 – 9957; 10009; 10017 – 10021; Property Inventory #174352: 9920 

Property Inventory #228960: 9969

Property Inventory #174354: 10064

Property Inventory #174353: 10094; 10060; 10062 - 10063; Person: 9911 – 9912; 9914; 9917 - 

9918

Scene: 9908 – 9910; 9913; 9915 - 9916; 9970 - 9971; Herff Jones Company telephone book: 9672 -

9905

Envelope: 9906 – 9907

Investigative File Control: 9919 

Court Attendance: 9921 – 9926; 9934; 9938 – 9941; 9943; 9945-9946; 9960; 9968 

City of Chicago Police Mail envelope: 9953

Request for Latent Fingerprint Comparison: 9958; 9961

Statement: 9972 – 9979

Arrest Report: 10003

Request for Latent Fingerprint Comparison: 10006; 10008

Supplementary Report: 10022 – 10023; 10028 – 10029

Illinois State Police Division of Forensic Services: 10045 – 10048; 10050 

Order: 10049

Latent Fingerprint Examination Report: 10051

Diagram: 10056; 10057; 10090

Major Crime Worksheet: 10080 – 10081; 10082 – 10083

Police form: 10091

Crime Laboratory Report: 10092 – 10093

City of Chicago, Department of Police envelope: 10095

YES NO N/A YES 

ACB 010115 – 10116; ACB 010155; ACB 010158 – 10159; ACB 010163; 

ACB 010171 – 10172; ACB 010184 - 

10194

YES ACB 010124; ACB 010127; ACB 010175 YES ACB 010108

10150 - 10154; Property Inventory #182422: 10125

Property Inventory #182421: 10126

Property Inventory #165135: 10181; 10183

Inventory of things seized in search: 10182; 10173; 10174; Investigative File Control: 10099

Court Attendance Report: 10100 – 10104; 10106 – 10107

Waiver of Extradition: 10117

Body Diagram: 10160; 10123

YES NO N/A YES ACB 010497 – 10517; ACB 010551 - 10552 YES

ACB 010446; ACB 010470; 

ACB 010475; ACB 010494-

97; ACB 010529; ACB 

010537; ACB 010548-55

YES ACB 010462; ACB 010493

Property Inventory #165200: 10456 – 10457; Property Inventory #165200: 10458 ; Property 

Inventory #174387: 10524; Property Inventory #174386: 10525; Property Inventory #174385: 

10526; Property Inventory #182426: 10527; Property Inventory #182425: 10528; Property 

Inventory #165137: 10530; Property Inventory #165136: 10531; Property Inventory #165138: 

10532; Property Inventory #174384: 10533; Property Inventory #174382: 10534; Property 

Inventory #174383: 10535; Property Inventory #165137: 10556 – 10557; Property Inventory 

#165136: 10558 - 10559; 10445; 10448 – 10452; 10460 - 10461; 10465; 10467; 10469; 10472; 

10474; 10518; 10520; 10522; Investigative File Control: 10443

Latent Fingerprint Examination Report: 10447; 10459 

Court Attendance Report: 10453; 10487

Memo: 10463

Receipt for Exhibits: 10464; 10471; 10472; 10536; 

Body Diagram: 10486

101’s: 10490

10 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 268 of 433 PageID #:15689
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

34 G-148403 1985 1 Derrick Johnson YES YES

ACB011174; ACB011177; ACB011258; ACB011276; ACB011290; ACB011326; ACB011348; ACB011312; 

ACB011356-59; 

ACB011347; ACB011248; ACB011259; ACB011281; ACB011294; ACB011324; ACB011327; ACB011330; ACB011334;

NO N/A NO N/A YES

ACB 011174; ACB 

011258; ACB 011276; 

ACB 011290; ACB 

011326; ACB 011348

NO N/A YES ACB 011177-11179 NO

29 GPRs in file, 19 listed on Inventory

26 Handwritten notes in file, 0 listed on 

Inventory

2 To-from memos in file, 0 listed on Inventory

YES

ACB 011174; ACB 011176; ACB 011192; ACB 011208; ACB 011210; ACB 011212; ACB 011234; ACB 011244; ACB 011246; ACB 011253; ACB 011256; ACB 011258; ACB 011268; ACB 011278; ACB 011283; ACB 011287; ACB 011290; ACB 011293; ACB 011304; ACB 011309; ACB 011322; ACB 011326; ACB 011332; ACB 011334; 

ACB 011348

YES ACB 011292

35 G-156178 1985 1 William Talkowski NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 011556 NO

11 GPRs in file, 5 listed on Inventory

1 Handwritten note in file, 0 listed on Inventory

2 To-from memos in file, 0 listed on Inventory

NO N/A NO N/A

36 G-159857 1985 3

Stanley Hagler

James Walker

Jeffrey Boyd

Carl Pollard

YES YES

ACB 011630-643; ACB 

011645-51; ACB 

011654; ACB011657-

58; ACB 011660-78; 

ACB 011680-84; ACB 

011686-87; ACB 011689-90; ACB 

011719; ACB 011728; 

ACB 011731; ACB 

011734; ACB 011749-

51; ACB 011758-59; 

ACB 011765-66; ACB 

011777; ACB 011780-

89; ACB 011804-812; 

ACB 011816-818; ACB 

011829-32; ACB 011834-35; ACB 011837-38; ACB 

011847-848; ACB 

011850; ACB 011874; 

ACB 011879; ACB 

011905; ACB 011913; 

ACB 011915; ACB 

011917; ACB 011935-

937; ACB 011939-943; 

ACB 011945-950; ACB 

011953-961; ACB 

011963-67; ACB 

011969-970

YES

NO - entries added 

after Aug. 24, 1985; 

also, the PD file 

contains inventory 

sheets that are 

missing from the 

Inv. File (ACB 

011732-11734 in 

Inv. File; 

CRIM.DEF FILES - 

FIELDS 019401-19413 in PD file)

NO N/A YES

*ACB 011627, *ACB 

011653, *ACB 011655-

658,

*ACB 011660, *ACB 

011662, *ACB 011664, 

*ACB 011666-668, *ACB 011670-671,

*ACB 011673, *ACB 

011676-678,

* ACB 011680-682,

*ACB 011684, *ACB 

011686, *ACB 011689-

690, ACB 011749,

*ACB 011766, *ACB 

011785

*ACB 011964, *ACB 

011966

NO N/A YES ACB 011731-34 NO

36 GPRs in file, 35 listed on Inventory

80 Handwritten notes in file, 54 listed on 

Inventory

24 To-from memos in file, 10 listed on 

Inventory

YES

 ACB 011657-58; ACB 

011660; ACB 011662; ACB 

011664; ACB 011666-68; 

ACB 011670-71; ACB 

011676-78; ACB 011680-

82; ACB 011684; ACB 

011686; ACB 011689-90; 

ACB 011739; ACB 011749; 

ACB 011762-64; ACB 

011791-92; ACB 011803; 

ACB 011891-902; ACB 

011904; ACB 011906-10; 

ACB 011912; ACB 011914; 

ACB 011916; ACB 011918-

34; ACB 011938; ACB 

011944; ACB 011951; ACB 011960; ACB 011962; ACB 

011968

YES

ACB 011752-57; 

ACB 011790; ACB 

011886-90; ACB 

011971-77

37 G-165272 1985 1 Williams Goodin YES YES

ACB 089326-28; ACB 

089330-53; ACB 

089359; ACB 089362; 

ACB 089368-405; ACB 

089411-12; ACB 

089414; ACB 089417-

20; ACB 089426-29; 

ACB 089429; ACB 

089435-38; ACB 

089445; ACB 089452-

56; ACB 09362-65.

NO N/A YES

ACB 089326-89328, 

ACB 089362, ACB 

089417-89420, ACB 

089453-89455

YES ACB 089452 YES ACB 089330-89331, ACB 089333 NO N/A N/A N/A Yes

ACB 012306-12311; ACB 

012320-12334; ACB 

012353; ACB 012368; ACB 

012374 

No N/A

38 G-176242 1985 1 William Grant NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A YES NO N/A

11 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 269 of 433 PageID #:15690
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

34 G-148403 1985 1 Derrick Johnson35 G-156178 1985 1 William Talkowski36 G-159857 1985 3

Stanley Hagler

James Walker

Jeffrey Boyd

Carl Pollard

37 G-165272 1985 1 Williams Goodin38 G-176242 1985 1 William Grant

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES 

ACB 011186-11194; ACB 011203-

11211; ACB 011255; ACB 011271-

11274; ACB 011279; ACB 011282; 

ACB 011286-11291; ACB 011303-

11308

YES

ACB 011174; ACB 011176; ACB 011192; ACB 011208; ACB 011210; ACB 011212; ACB 011234; ACB 011244; ACB 011246; ACB 011253; ACB 011256; ACB 011258; ACB 011268; ACB 011278; ACB 011283; ACB 011287; ACB 011290; ACB 011293; ACB 011304; ACB 011309; ACB 011322; ACB 011326; ACB 011332; ACB 011334; 

ACB 011348

YES ACB 011292

11260-11266; 11333; 11349-11351; Finger/palmprints (11275-11276)

Crime Scene Evidence & Fingerprints (11301; 11346); Person (11312; 11356-11359); 11299; 

11347

Request for Latent Fingerprint Comparison (11175; 11233; 11243; 11245; 11248; 11250-11252; 

11254; 11257; 11259; 11267; 11280-11281; 11294-11298; 11319-11327; 11330)

Fingerprint Results (11242)

Receipt for Exhibits (11277; 11331)

Form 101 (11345)

YES NO N/A YES ACB 011607 – 11608; ACB 011611 - 11620 NO N/A NO N/A

Property Inventory #191319: 11609Property Inventory #191367: 11610

Property Inventory #176116: 11621; 11623

Inventory of Things Seized in Search: 11622; 

11598 - 11604; 11605; 11606

Bureau of Detectives Memo: 11557

FOIA Request To-From: 11558

Law office o H. Candace Gorman letter: 11559

Body diagram: 11624

Investigative File Control: 11625 - 11626

YES YES

NO - there are additional pages and items on the 

Inventory in the PRF (Investigative file: ACB 

011731-34; PRF: CITY-PRF-01589-94; CITY-PRF01598) YES 

ACB 011738; ACB 011750-751; 

ACB 011758-759; ACB 011878-879; 

ACB 011905; ACB 011935-970

YES

ACB 011658; ACB 011660; ACB 011662; ACB 011664; 

ACB 011666-668; ACB 

011670-671; ACB 011673; 

ACB 011676-678; ACB 

011680-682; ACB 011684; 

ACB 011686; ACB 011689-

690; ACB 011739; ACB 

011749; ACB 011762-764; 

ACB 011791-792; ACB 

011803; ACB 011881; ACB 

011883; ACB 011891-902; 

ACB 011904; ACB 011906-

912; ACB 011914; ACB 

011916; ACB 011918-934; 

ACB 011938; ACB 011944; ACB 011951; ACB 011960; ACB 011962; ACB 011964; 

ACB 011966; ACB 011968

YES

ACB 011752-757; 

ACB 011790; ACB 

011861; ACB 011880; 

ACB 011882; ACB 

011884-890; ACB 

011971-977

CPD Intra-Departmental Mail Envelope - ACB 011628

Copy of Envelope - ACB 011629; 011691

Photos with handwritten identification notes on the back - ACB 011630-657

Phone memo sheet (blank) - ACB 011659

Watch Assignment Sheet - ACB 011661; 011663; 011672; 011674; 011683; 011913; 011915; 

011917

Portion of Case Report - ACB 011665

Attorney Business Card - ACB 011669 

Field Contact Card - ACB 011675

Portion of Supp Report - ACB 011679

Arrest Information Card - ACB 011685; 011760-761; 011794-797; 011846; 011851-853; 011903

Evidence Report - ACB 011687; 011800; 011812

Photos - ACB 011692-721

Inv. File Control - ACB 011722

Major Crime Worksheet - ACB 011723-724; 011815-816

Criminal History - ACB 011727; 011737; 011768-779

Arrest Report - ACB 011728; 011736; 011782-789; 011827; 011854-858

Final page of Supp Report w/ Handwritten note - ACB 011748

Request for Latent Fingerprint Comparison - ACB 011765; 011830

Felony Complaint - ACB 011780-781

Evidence Identification No. - ACB 011793

Arrest Warrant - ACB 011798-799

Vehicle Tow Report - ACB 011802; 011814

Property Inventory Sheets - ACB 011804-811; 011837-839; 011850

Daily Bulletin - ACB 011813

Case Report - ACB 011817-819; 011831-836; 011847-849

Lost & Found Case Report - ACB 011826

Supp Report - ACB 011829

Nickname Index Cards - ACB 011840-845

FBI Letter - ACB 011859-860

Body Diagram - ACB 011871-873

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

YES N/A N/A YES ACB 012317-12333; ACB 012347- 12356; ACB 012367; ACB 012379 YES

ACB 012306-12311; ACB 

012320-12334; ACB 

012353; ACB 012368; ACB 

012374

NO N/A

12335-12340; 12345; Copy of Envelope (12299; 12312)

Arrest Cards (12300-12305)

Funeral Card (12313-12316)

Arrest Report (12341-12346; 12355)

Major Crime Worksheet (12377-12378)

12 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 270 of 433 PageID #:15691
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

39 G-192900 1985 1 Maria Everton NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 013237-38 NO

12 GPRs in file, 1 listed on Inventory

5 Handwritten notes in file, 1 listed on 

Inventory

YES ACB 013276-13278; NO N/A

40 G-215280 1985 1 Maurice Green YES YES

ACB 013390-93; ACB 

013396; ACB 013398-

99; ACB 013400-06; 

ACB 013408; ACB 

013414; ACB 013501-

04; ACB 013546

NO N/A YES ACB 013404; ACB 013408 YES

ACB 013391-13392; ACB 013405-13406; 

ACB 013414; ACB 

013501; ACB 013546

NO N/A YES ACB 013502-13503 NO

3 additional GPRs not in G-215280A

5 Handwritten notes in files, 0 listed on 

Inventory

1 To-from memo in files, 0 listed on Inventory

YES ACB 013391-13392; ACB 013405-13406; ACB 013501 YES ACB 013399; ACB 013414; ACB 013533 

41 G-230261 1985 1 Michael Thompson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 014079-14080 NO

11 GPRs in file, 1 listed on Inventory

8 Handwritten notes in file, 0 listed on 

Inventory

YES ACB 014148; ACB 014151- 14159; ACB 014168 NO N/A

42 G-235180 1985 1 Willie Pizza NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A YES

ACB 014189; ACB 014196-14197; ACB 014202-14203; 

ACB 014206-14207

YES ACB 014208 

43 G-245282 1985 1 Eddie Robinson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 014212-13 NO 2 Handwritten notes in file, 0 listed on Inventory NO N/A NO N/A

44 G-248336 1985 4 Ruben Avilez YES YES

ACB 014302-34; ACB 

014359-60; ACB 

014367-14368; ACB 

014379-81; ACB 

014413-14414; ACB 

014425; ACB 014427-

14438; ACB 014441; 

ACB 014444-46; ACB 

014453-14454; ACB 

014456-64; ACB 

014467

YES YES YES ACB 014427 YES

ACB 014302; ACB 

014334; ACB 014441; 

ACB 014425; ACB 

014446; ACB 014457

YES

ACB 014303; ACB 

014305-14307; ACB 

014333; ACB 014359; 

ACB 014379; ACB 

014380; ACB 014444)

YES ACB 014371-72; ACB 014417-18 NO

2 GPRs in file, 1 listed on Inventory

7 Handwritten notes in file, 1 listed on 

Inventory

9 To-from memos in file, 0 listed on Inventory

YES

ACB 014302; ACB 014334; ACB 014425; ACB 014441; 

ACB 014446; ACB 014457

YES

ACB 014303; ACB 

014305; ACB 

014306-14307; ACB 

014333; ACB 014359; ACB 

014379-14380; ACB 

014444 

45 G-257089 1985 1 Freddie Brown YES YES

ACB 014790-93; ACB 

014796-98; ACB 

014802; ACB 014804; 

ACB 014806-19; ACB 

014838

NO N/A YES *ACB 014806-819 NO N/A NO N/A YES ACB 014790 YES N/A NO N/A NO N/A

46 G-265171 1985 1 Nidal Haddad NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 015104 NO 5 Handwritten notes in file, 3 listed on Inventory YES ACB 015138-15140; ACB 015149 NO N/A

47 G-267631 1985 3 Fred Daniels NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 015313 NO 1 To-from memo in file, 0 listed on Inventory NO N/A YES ACB 015356 48 G-267820 1985 1 Patricia Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 015360 YES N/A NO N/A NO N/A

13 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 271 of 433 PageID #:15692
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

39 G-192900 1985 1 Maria Everton40 G-215280 1985 1 Maurice Green41 G-230261 1985 1 Michael Thompson42 G-235180 1985 1 Willie Pizza43 G-245282 1985 1 Eddie Robinson44 G-248336 1985 4 Ruben Avilez45 G-257089 1985 1 Freddie Brown46 G-265171 1985 1 Nidal Haddad47 G-267631 1985 3 Fred Daniels48 G-267820 1985 1 Patricia Williams

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 013253-13264 YES ACB 013276-13278; NO N/A

Latent Fingerprint Exam. Report (13246-13247)

Arrest Info (13265)

Arrest Report (13266)

Arrest Warrant (13268)

Complaint (13269)

Stop Order (13270-13271)

Will Call Sales Check (13272)

Sign-in Sheet (13273-13275)

Sketch (13277)

Witness Statement (13307-13310)

13239-13243; 13279-13292; 13295-13296; Scene photos, physical evidence and ridge impressions 

(13251-13252)

Finger and Palmprint (13293-13294); 13267

YES NO N/A YES ACB 013404; ACB 013407-13408; ACB 013560-13566 YES ACB 013391-13392; ACB 013405-13406; ACB 013501 YES ACB 013399; ACB 013414; ACB 013533

13509-13513l; 13394-13396; 13534; 13545; 13553; Photos, Impressions & Blood Sample (13505; 

13543)

Rape Kit (13535); 13496-13499; 13506; Picture of Cassette (13369)

Form 101 (13390)

Arrest Info (13393; 13398)

Arrest Report (13397; 13422; 13432; 13485-13495; 13552)

Grand Jury Subp (13400-13403)

Witness Statement (13410-13413)

Information Report (13423; 13433; 13474-13484; 13551)

Inv. File Control (13504)

Lab Report (13507-13508; 13514-13515)

Body Diagram (13530)

Firearms Receipt & Worksheet (13531)

Receipt for Exhibits (13547)

HBT Incident Personnel Control Log (13554)

YES NO N/A YES ACB 014109; ACB 014144-14158 YES ACB 014148; ACB 014151- 14159; ACB 014168 NO N/A

14082-14085; 14133-14139; 14141; Photos (14129)

Cartridge/Cartridge Case (14142-14143); 14118-14119; Inv. File Control (14081)

Body Diagram (14088)

Form 101 (14116)

Complaint (14117)

Witness Statement (14120-14122)

Gang Specialist Daily Activity Summary (14140)

Case Report w/ Handwritten note (14166-14167)

YES N/A N/A YES ACB 014181; ACB 014210 YES

ACB 014189; ACB 014196-14197; ACB 014202-14203; 

ACB 014206-14207

YES ACB 014208

14173-14174; 14177; Inv. File Control (14170)

Arrest Warrant (14171)

Complaint (14172)

Arrest Report (14178-14180)

Illinois Department of Public Aid (14190-14191)

Change Report Form (14192-14195)

State of Illinois Department of Employment Security (14198-14201)

State of Illinois Department of Public Aid (14204-14205)

Victim Information (14209)

YES NO N/A YES ACB 014275-14276 NO N/A NO N/A

14241-14245; 14281-14282; 14288-14291; Blood Sample (14219; 14279-14280); Safety Helmet 

(14215-14216)

Auto Used in Homicide (14231-14232); 14220; Copy of Envelope (14214)

Inv. File Control (14217)

Form 101 (14237)

Arrest Report (14238)

Body Diagram (14250)

Receipt for Exhibits (14253-14256)

Case Report (14299-14300)

YES YES YES YES ACB 014426-14427 YES

ACB 014302; ACB 014334; ACB 014425; ACB 014441; 

ACB 014446; ACB 014457

YES

ACB 014303; ACB 

014305; ACB 014306-

14307; ACB 014333; 

ACB 014359; ACB 

014379-14380; ACB 

014444

Person (14464); 14308-14317; 14319-14332; 14428-14429; 14445; 14455; 14462; Arrest Report 

(14304; 14360; 14381; 14431; 14435; 14461; 14467)

Request for ID Records (14318)

Arrestee History (14430; 14434; 14459-14460)

Offenders General Information (14432)

Name Check Report (14433; 14436-14438)

Daily Bulletin (14448-14452)

Deceptive Practice Report (14453-14454)

Wanted Card (14456; 14463)

Typed Message (14458)

Stop Order (14465-14466)

YES NO N/A YES ACB 014806-14819 NO N/A NO N/A

14838; Photos & Blood Sample (14796; 14804); 14797-14798; Inv. File Control (14791)

Lab Report (14792-14793)

Body Diagram (14802)

Witness Statement (14825-14835)

Case Report w/ additional note (14837)

YES NO N/A YES ACB 015150-15159 YES ACB 015138-15140; ACB 015149 NO N/A

15115-15119; 15144-15147; IDPA Identification (15105-15106)

Inv. File Control (15107)

Firearms Receipt (15123)

Arrest Report (15143)

Body Diagram (15148)

Form 101 (15160)

YES YES YES NO N/A NO N/A YES ACB 015356

15326-15330; 15322-15324; 15344-15354; Case Assignment Slip (15311)

Inv. File Control (15312)

Receipt for Exhibits (15331)

Witness Statement (15332-15338)

Body Diagram (15339)

Lab Report (15340-15341)

Major Crime Worksheet (15355)

YES NO N/A YES ACB 015379-15384 NO N/A NO N/A

15368-15371; 15364-15367; 15387-15389; Photos (15362); Inv. File Control (15361)

Body Diagram (15372)

Case Report w/ additional notes (15386); 15363

14 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 272 of 433 PageID #:15693
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

49 G-267826 1985 1 James Walker YES YES

ACB 015390-394; ACB 

015396-401; ACB 

015405; ACB 015408-

09; ACB 015413-424; 

ACB 015425-432; ACB 

015469-71; ACB 015473-74; ACB 015477-87; ACB 

015492; ACB 015496-504; ACB 015493-495

NO N/A YES *ACB 015413-423, ACB 015425-432 YES *ACB 015481 *ACB 015424 NO N/A YES ACB 015391-15392 NO 3 Handwritten notes in file, 0 listed on Inventory YES ACB 015424; ACB 015481 NO N/A

50 G-278643 1985 1 Claude Lewis NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016011-16012 NO

23 GPRs in file, 7 listed on Inventory

8 Handwritten notes in file, 6 listed on 

Inventory

YES

ACB 016046; ACB 016072; ACB 016075; ACB 016098; 

ACB 016103; ACB 016105-

16106; ACB 016108

NO N/A

51 G-283147 1985 4 James Willingham NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016126-16127 NO Photos (16189-16196) NO N/A NO N/A52 G-284291 1985 1 Lucille Pye YES YES

ACB 016198-200; ACB 

016206-09; ACB 

016218; ACB 016220-

24; ACB 016242-43; 

ACB 016246-47; ACB 

016249-51; ACB 016253-70; ACB 

016272; ACB 016274-

76; ACB 016283-86

NO N/A YES

ACB 016220-16223; ACB 016255-16256; ACB 016259-16262; 

ACB 016274; ACB 

016283-16284

YES ACB 016270; ACB 016272 NO N/A YES ACB 016198-16199 NO 2 Handwritten notes in file, 0 listed on Inventory 5 To-from memos in file, 0 listed on Inventory YES ACB 016270 NO N/A

53 G-289217 1985 1 Delanda Dillard NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016288 NO 1 Handwritten note in file, 0 listed on Inventory YES ACB 016326 NO N/A54 G-303402 1985 1 Nancy West NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016328 NO 5 GPRs in file, 0 listed on Inventory YES ACB 016401 NO N/A55 G-321886 1985 4

Manuel Rios

Willie Mullen

James Crockett

YES YES

ACB 016649-54; ACB 

016658-64; ACB 016667-70; ACB 016675-77; ACB 016682-86; ACB 016723-24; ACB 016726-30; ACB 016732-97; ACB 

016799- 807

NO N/A YES

ACB 016686; ACB 

016726; ACB 016734 – 

16739; ACB 016750 – 

16753; ACB 016771 - 

16776

YES

ACB 016649; ACB 

016724; ACB 016729; 

ACB 016740; ACB 

016759; ACB 016761; 

ACB 016780; ACB 

016784; ACB 016794; 

ACB 016796; ACB 

016797

YES ACB 016667 YES ACB 016650-16652 NO

16 GPRs in file, 14 listed on Inventory

8 Handwritten notes in file, 0 listed on 

Inventory

1 To-from memo in file, 0 listed on Inventory

YES

ACB 016724; ACB 016740; ACB 016751; ACB 016753; 

ACB 016780-97

YES ACB 016667

56 G-322101 1985 1 James Baker NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016809-16810 NO 6 Handwritten notes in file, 1 listed on Inventory YES ACB 016863-72 NO N/A

57 G-331216 1985 1 Maurice McCants NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 017595-17596 NO

12 GPRs in file, 1 listed on Inventory

5 Handwritten notes in file, 0 listed on 

Inventory

YES ACB 017642; ACB 017684; ACB 017686 NO N/A

58 G-354748 1985 1 Byron Lawrence NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 017689-17690 NO 5 Handwritten notes in file, 0 listed on Inventory YES ACB 017709; ACB 017712; ACB 017736; ACB 017750; ACB 017761 NO N/A

59 G-356930 1985 1 Alonzo Jordon NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 017899-17900 NO 1 Handwritten note in file, 0 listed on Inventory YES ACB 017923; ACB 017984 NO N/A

15 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 273 of 433 PageID #:15694
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

49 G-267826 1985 1 James Walker50 G-278643 1985 1 Claude Lewis51 G-283147 1985 4 James Willingham52 G-284291 1985 1 Lucille Pye53 G-289217 1985 1 Delanda Dillard54 G-303402 1985 1 Nancy West55 G-321886 1985 4

Manuel Rios

Willie Mullen

James Crockett

56 G-322101 1985 1 James Baker57 G-331216 1985 1 Maurice McCants58 G-354748 1985 1 Byron Lawrence59 G-356930 1985 1 Alonzo Jordon

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 015413-15432 YES ACB 015424; ACB 015481 NO N/A

15397-15401; 15394-15396; 15408-15410; 15471-15476; Line-up Photos (15470); Person (15493-

15503); 15477-15479; 15482-15483; Inv. File Control (15393)

Body Diagram (15405)

Witness Statements (15450-15468)

Form 101 (15469)

Wanted Card (15480)

Release of Person in Custody (15484)

Complaint (15485)

Arrest Report (15486-15487)

Copy of Envelope (15492)

Request for ID Photos (15504)

YES NO N/A YES 

ACB 016036-16049; ACB 016058-

16060; ACB 016071-16076; ACB 

016102-16107

YES

ACB 016046; ACB 016072; ACB 016075; ACB 016098; 

ACB 016103; ACB 016105-

16106; ACB 016108

NO N/A

16021-16024; 16068-16070; 16094-16095; Photos (16015; 16109-16110); 16016; Lab Report 

(16013-16014; 16019-16020)

Supp Report (4th page missing - 16028;16067; 2nd page missing - 16035; 16054-16057)

Receipt for Exhibits (16050--16051)

Body Diagram (16053)

Written Witness Statement (16061-16062)

Witness Statement (16079-16089; 16096-16097)

Arrest Report (16093)

Gang Arrest Information (16099-16101)

Release of Person in Custody (16111)

Case Report (16123-16124)

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

YES NO N/A YES 

ACB 016220-16223; ACB 016255-

16256; ACB 016259-16262; ACB 

016274; ACB 016283-16284

YES ACB 016270 NO N/A

16201-16204; 16207-16209; Victim fingerprints & photos (16205; 16271-16272); Person (16242-

16243; 16250-16251; 16257-16258); 16206; 16244-16246; 16252; 16263-16267; Inv. File Control 

(16200)

Body Diagram (16218)

Form 101 (16224)

Witness Statement (16232-16241)

Arrest Report (16247-16248; 16253-16254; 16268-16269)

Release of Person in Custody (16249)

Supp Report (16275-16276)

Case Report w/ missing note (16286)

YES NO N/A NO N/A YES ACB 016326 NO N/A

16298-16301; 16303-16305; 16295-16297; 16312; 16324; Victim fingerprints & photos (16313-

16314)

Plastic Bag containing rifle (16325); Inv. File Control (16289)

Lab Report (16291)

Case Assignment Slip (16302)

Body Diagram (16306)

YES NO N/A YES ACB 016389-16393; ACB 016397- 16398 YES ACB 016401 NO N/A

16340-16344; 16336-16339; 16374-16378; 16395-16396; Victim photos & physical evidence 

(16333); 16334-16335; Inv. File Control (16329)

Lab Report (16331)

Witness Statement (16369-16370)

Stop Order (16371)

Complaint (16372)

Arrest Warrant (16373)

Body Diagram (16379)

YES NO N/A YES 

ACB 016686; ACB 016726; ACB 

016734-16739; ACB 016750; ACB 

016752; ACB 016771-16776

YES

ACB 016724; ACB 016740; ACB 016751; ACB 016753; 

ACB 016780-97

YES ACB 016667

16658-16662; 16758-16761; Photos (16728-16729)

Vehicle Evidence (16730-16731); Person (16779-16795); 16654;16684-16685; Case Assignment 

Slip (16653)

Latent Fingerprint Exam. Report (16663)

Towed Vehicle Disposition (16664)

Witness Statement (16687-16722)

Nickname Index (16723)

Body Diagram (16727)

Arrest Info (16767-16768)

Inv. File Control (16777)

Material Submitted for Daily Bulletin (16799-16804)

Stop Order (16805-16807)

YES NO N/A YES ACB 016864-16871 YES ACB 016863-16872 NO N/A

16818-16826; 16833-16834; 16845-16847; Clothing seized from Baker, James (16827-16828)

Request to pick up clothes (16835-16836)

Victim Evidence (16876-16877); Weapon (16881); Inv. File Control (16811)

Lab Report (16815-16817; 16829; 16875)

Latent Fingerprint Exam. Report (16832)

Receipt for Exhibits (16837-16838)

Witness Statement (16848-16859)

Body Diagram (16860-16862)

YES NO N/A YES ACB 017634-17640; ACB 017643- 17647 YES ACB 017642; ACB 017684; ACB 017686 NO N/A

17602-17606; 17630-17633; 17651-17653; 17678; Crime Scene & Victim Evidence (17598; 

17650); 17599; 17677; Inv. File Control (17597)

Case Assignment Slip (17601)

Body Diagram (17609)

Court Notification (Blank - 17641)

Lab Report (17648-17649)

Witness Statement (17663-17676)

Form 101 (17679)

Complaint (17680-17681)

Arrest Report (17682)

Case Report w/ additional note (17685)

YES NO N/A YES ACB 017708; ACB 017710-17711; ACB 017760; ACB 017762 YES ACB 017709; ACB 017712; ACB 017736; ACB 017750; ACB 017761 NO N/A

17697-17700; 17756-17758; Photos (17733-17734)

Rifle Evidence (17747-17748; 17759); Inv. File Control (17688)

Firearms Receipt & Worksheet (17725)

Receipt for Exhibits (17735; 17749)

Body Diagram (17743)

YES NO N/A YES ACB 017965-17979 YES ACB 017923; ACB 017984 NO N/A

17917-17921; 17946; 17949-17950; Photos & Blood Sample (17947-17948); Inv. File Control 

(17901)

Case Assignment Slip (17912)

Receipt for Exhibits (17922)

Supp Report (17936)

Witness Statement (17951-17963)

16 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 274 of 433 PageID #:15695
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

60 G-385135 1985 1 Earlin Turner NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 018147-18148 NO 1 Handwritten note in file, 0 listed on Inventory YES ACB 018161 NO N/A61 G-401782 1985 1 Dwayne Cheers NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 018838-18839 NO

6 GPRs in file, 5 listed on Inventory

9 Handwritten notes in file, 5 listed on 

Inventory

YES

ACB 018851; ACB 018872-

75; ACB 018882; ACB 

018885 

NO N/A

62 G-405711 1985 1 Wardell Gates NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A NO N/A NO N/A

63 G-446754 1985 1 Edward Terrett YES YES

ACB 020110-11; ACB 

020113-15; ACB 020118-23; ACB 020126-27; ACB 

020132; ACB 020147; 

ACB 020156;

YES

NO - additional 

entries after 

11/24/1985

 (ACB 020110 in 

Inv. File; 

CRIM.DEF FILES - 

FIELDS 043792 in 

PD file)

NO N/A YES ACB 020156 NO N/A YES ACB 020110 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 020136; ACB 020156 NO N/A

64 G-456900 1985 1 Larry Buchanan YES YES

ACB 020810; ACB 

020814-15; ACB 020820-21; ACB 020830-32; ACB 020835-37; ACB 

020853; ACB 020855 

–59;

NO N/A YES ACB 020857 - 20858 YES ACB 020815; ACB 020821; ACB 020837 NO N/A YES ACB 020810 NO 2 GPRs in file, 1 listed on Inventory 2 Handwritten notes in file, 0 listed on Inventory YES ACB 020815; ACB 020837 NO N/A

65 G-468726 1985 1 Albert Spraggins YES YES

ACB 020861-76; ACB 

020879-84; ACB 

020886-902; ACB 

020904-16; ACB 020918-22; ACB 020924-42; ACB 020965-67; ACB 020981-82; ACB 

021004-06

YES

NO - additional 

entries after 

2/7/1986

 (ACB 020864 in 

Inv. File; 

CRIM.DEF FILES - 

FIELDS 044380 in 

PD file) 

YES ACB 020966-20967 YES

ACB 020861; ACB 

020896; ACB 020898; 

ACB 020908

NO N/A YES ACB 020862-20864 NO

15 GPRs in file, 14 listed on Inventory

7 Handwritten notes in file, 0 listed on 

Inventory

3 To-from memos in file, 2 listed on Inventory

YES

ACB 020861; ACB 020866; ACB 020868; ACB 020896; 

ACB 020898; ACB 020907-

09; ACB 020920; ACB 

020928

YES

ACB 020899; ACB 

020916; ACB 

020924 

80 G-468726 1985 1 Maurice Spraggins YES YES

ACB 020861-76; ACB 

020879-84; ACB 

020886-902; ACB 

020904-16; ACB 020918-22; ACB 020924-42; ACB 020965-67; ACB 020981-82; ACB 

021004-06

YES

NO - additional 

entries after 

2/9/1986

 (ACB 020864 in 

Inv. File; 

CRIM.DEF FILES - 

FIELDS 044567 in 

PD file)

YES ACB 020925-20937 YES

ACB 020861; ACB 

020896; ACB 020898; 

ACB 020907; ACB 

020908-20909; ACB 

020920; ACB 020928

YES ACB 020899; ACB 020916; ACB 020924 YES ACB 020862-20864 NO 24 Handwritten notes in file, 14 listed on Inventory 3 To-from memos in file, 2 listed on Inventory YES

ACB 020861; ACB 020866; ACB 020868; ACB 020896; 

ACB 020898; ACB 020907-

09; ACB 020920; ACB 

020928

YES

ACB 020899; ACB 

020916; ACB 

020924 

17 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 275 of 433 PageID #:15696
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

60 G-385135 1985 1 Earlin Turner61 G-401782 1985 1 Dwayne Cheers62 G-405711 1985 1 Wardell Gates63 G-446754 1985 1 Edward Terrett64 G-456900 1985 1 Larry Buchanan65 G-468726 1985 1 Albert Spraggins80 G-468726 1985 1 Maurice Spraggins

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 018163; ACB 018174; ACB 018191; ACB 018196-18207 YES ACB 018161 NO N/A

18152-18156; 18157; 18188-18189; 18193-18194; Photos, Black Cap, and GSR kit (18187); 

Person (18195); 18160; 18162; 18173; Case Assignment Slip (18146)

Lab Report (18150-18151)

Recovered Property Disposition Tracer (18158)

Waiver of Extradition (18167)

Form 101 (18168)

Body Diagram (18190)

Inv. File Control (19192)

Arrest Warrant (18209)

Complaint (18210)

YES NO N/A YES ACB 018871; ACB 018881-18887 YES

ACB 018851; ACB 018872-

75; ACB 018882; ACB 

018885 

NO N/A

18855-18856; 18878-18880; Crime Scene Photos & Physical Evidence (18840; 18876-18877)

Brown Handled Butcher Knife (18844-18845)

Fingerprints (18853-18854); 18841; Lab Report (18842-18843; 18846)

Body Diagram (18850)

Witness Statement (18863-18867)

Complaint (18868)

Arrest Report (18869)

Form 101 (18870)

Inv. File Control (18888)

Copy of Envelope (18891)

State of IL ID (18892-18893)

Identification (18894)

Food Stamp Issuance Doc. (18895)

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

YES NO N/A YES ACB 020135-20137; ACB 020148 YES ACB 020136; ACB 020156 NO N/A

20132-20134; Photos (20155); Inv. File Control (20111)

Arrest Information (20113)

Supp Report COD (20120-20121)

Mail (20130-20131)

Witness Statement (20138-20146)

Body Diagram (20147)

YES NO N/A YES ACB 020857-20858 YES ACB 020815; ACB 020837 NO N/A

20823-20829; 20835-20836; Photos & Crime Scene Evidence (20820-20821; 20856)

Photos (20853-20854); Receipt for Exhibits (20814)

Lab Report (20830-20831)

Body Diagram (20832)

Witness Statement (20838-20847)

Form 101 (20855)

Inv. File Control (20859); 20811-20812

YES NO N/A YES ACB 020925-20937; ACB 020966- 20967; ACB 020977 YES

ACB 020861; ACB 020866; ACB 020868; ACB 020896; 

ACB 020898; ACB 020907-

09; ACB 020920; ACB 

020928

YES ACB 020899; ACB 020916; ACB 020924

20938-20942; 20904-20906; 20978; 21003; 21005; Photos (20902; 20979)

Photos & Cardboard Wadding (20921; 21004)

Printed & Photographed (21006); Person (20865-20867; 20914-20915); 20887; 20889; 20891; 

20895; 20897; 20919; 20922; Case Assignment Slip (20863)

Inv. File Control (20869)

FBI Identification Record (20873; 20890)

Form 101 (20884)

Arrest Report (20886; 20911-20913; 20918)

Arrest Control Set (20888)

Arrest Info (20892)

Campaign Poster (20910)

Arrest Warrant (20945)

Complaint (20946)

Body Diagram (20965)

Witness Statement (20983-21002)

YES NO N/A YES ACB 020925-20937; ACB 020966- 20967; ACB 020977 YES

ACB 020861; ACB 020866; ACB 020868; ACB 020896; 

ACB 020898; ACB 020907-

09; ACB 020920; ACB 

020928

YES ACB 020899; ACB 020916; ACB 020924

20938-20942; 20904-20906; 20978; 21003; 21005; Photos (20902; 20979)

Photos & Cardboard Wadding (20921; 21004)

Printed & Photographed (21006); Person (20865-20867; 20914-20915); 20887; 20889; 20891; 

20895; 20897; 20919; 20922; Case Assignment Slip (20863)

Inv. File Control (20869)

FBI Identification Record (20873; 20890)

Form 101 (20884)

Arrest Report (20886; 20911-20913; 20918)

Arrest Control Set (20888)

Arrest Info (20892)

Campaign Poster (20910)

Arrest Warrant (20945)

Complaint (20946)

Body Diagram (20965)

Witness Statement (20983-21002)

18 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 276 of 433 PageID #:15697
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

66 G-482955 1985 3 Howard Wiley NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 021018-21023 NO

24 Handwritten notes in file, 14 listed on 

Inventory

3 To-from memos in file, 2 listed on Inventory

YES

ACB 021155; ACB 021157; 

ACB 021206; ACB 021245-

21263; ACB 021272; ACB 

021289

YES

ACB 021075; ACB 

021188; ACB 

021190

67 G-483470 1985 1 Michael McMillan NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 021311; ACB 021313 NO 3 Handwritten notes in file, 0 listed on Inventory YES ACB 021373 YES ACB 021349; ACB 021402 

68 G-501974 1985 1 Willie Cunningham NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 021770 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 021787; ACB 021790 NO N/A

69 H-024109 1986 4

Sidney Hines

Sammy Walker

Arthur Alexander

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 028493 – 28494; ACB 028481 -28483 NO

11 Handwritten notes in file, 1 listed on 

Inventory

1 To-from memo in file, 0 listed on Inventory

YES

ACB 028365; ACB 028412; ACB 028418; ACB 028435; ACB 028442; ACB 028444; ACB 028492; ACB 028506; ACB 028526; ACB 028565; ACB 028581; ACB 028583; 

ACB 028602

YES ACB 028403

70 H-349049 1986 4 Jesse Avery Robert Divine NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 028655 - 28656 NO 13 GPRs in file, 12 on inventory NO N/A NO N/A71 H-435581 1986 4 Jettie Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 028718 YES N/A NO N/A NO N/A

19 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 277 of 433 PageID #:15698
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

66 G-482955 1985 3 Howard Wiley67 G-483470 1985 1 Michael McMillan68 G-501974 1985 1 Willie Cunningham69 H-024109 1986 4

Sidney Hines

Sammy Walker

Arthur Alexander

70 H-349049 1986 4 Jesse Avery Robert Divine71 H-435581 1986 4 Jettie Williams

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 021264-21307 YES

ACB 021155; ACB 021157; 

ACB 021206; ACB 021245-

21263; ACB 021272; ACB 

021289

YES ACB 021075; ACB 021188; ACB 021190

21084-21097; 21229-21243; Elimination Prints (21109; 21164)

Manilla Envelope (21116)

Photos (21225; 21228)

Crime Scene Physical Evidence (21227); Person (21033-21049)

Crime Scene (21051-21073); 21110; 21152-21154; 21202-21205; 21207-21213; Case Assignment 

Slip (21015-21017)

Inv. File Control (21024)

Envelope (21025)

Cook County Hospital Card (21026-21027)

Business Card (21028)

IL Driver's License (21029-21032)

Photo No. (21050)

Bureau of Detectives Memo (21074)

IL Torture Inquiry & Relief Commission Subp. (21076-21077)

Lab Report (21079-21083; 21099-21100; 21114-21115; 21138-21139; 21176-21177)

Arrest Info (21101; 21214-21215; 21220-21221; 21257)

Supp Report (21102-21104; 21112-21113; 21140-21142; 21186-21187)

Major Crime Worksheet (21107-21108; 21178-21179)

Latent Fingerprint Exam. Report (21117-21118)

Body Diagram (21145; 21148; 21151; 21193-21201)

Receipt for Exhibits (21156; 21165; 21222-21223)

Witness Statement (21167-21175)

Continuation of Narrative w/ additional notes (21182)

Arrest Report (21189; 21244)

Case Report (21191-21192)

Fingerprints (21217-21218)

Rifling Class Characteristics (21224)

YES NO N/A YES ACB 021347-21348; ACB 021396- 21401 NO N/A YES ACB 021349; ACB 021402

21324-21331; 21336-21344; 21386-21388; 21407-21408; Photos & Crime Scene Evidence 

(21320; 21413-21414)

Finger & palmprints (21409-21410)

Photos of Vehicle (21411-21412); 21321-21322; 21345; 21350-21358; 21377-21385; Case 

Assignment Slip (21312)

Consent to Search (21346; 21391)

Body Diagram (21363)

Diagram (21373)

Arrest Info (21381)

Witness Statement (21389-21390)

Vehicle Tow Report (21392)

Major Crime Worksheet (21394-21395; 21416-21417)

Form 101 (21403)

Inv. File Control (21418)

YES NO N/A YES ACB 021782-21791 YES ACB 021787; ACB 021790 NO N/A

21776-21779; 21781; Photos & Crime Scene Evidence (21773; 21792); 21774; Body Diagram 

(21795)

Inv. File Control (21806)

YES NO N/A YES 

ACB 028378 – 28380; ACB 028429; ACB 028443; ACB 028457 – 28465; 

ACB 028519; ACB 028525; ACB 

028527 – 28529; ACB 028540 – 

28542; ACB 028585 – 28592; ACB 

028603 – 28605; ACB 028624 – 

28642

YES

ACB 028365; ACB 028412; ACB 028418; ACB 028435; ACB 028442; ACB 028444; ACB 028492; ACB 028506; ACB 028526; ACB 028565; ACB 028581; ACB 028583; 

ACB 028602

YES ACB 028403

Inventory # 260873: 28544; Inventory # 249759: 28595 ; Inventory # 249762: 28597; Inventory # 

249756: 28623; Inventory # 271160: 28424; Inventory # 271122: 28430;Inventory # 271101: 

28452; Inventory # 271103: 28453; Inventory of Things Seized in Search: 28596; 28598; 28375 – 

28376; 28521; 28611; Person: 28486 – 28490; 28645; 28652 - 28653

Scene: 28485; 28647 – 28651; 28423; 28428; 28431 – 28432; 28454; 28555; 28557 – 28559; 

28561; 28563; 28564; 28566; 28600 – 28601; 28612; Court Attendance Report: 28369 - 28372; 

28394; 28397 – 28401; 28480; 28497

Request for Identification Photos: 28502 – 28503

Name Card: 28504

Latent Fingerprint Examination Report: 28505

Request for Latent Fingerprint Comparison: 28367 – 28368; 28377; 28404; 28441

Case control slip: 28506

Missing/Found Person Case Report: 28507 -28516 

Arrest Report: 28387; 28433 – 28434; 28451; 28530; 28554; 28556; 28560; 28562; 28567; 28599; 

28606

Court Complaint Transmittal Listing: 28531

Release of Person in Custody: 28543

Form 101: 28382; 28402; 28552 – 28553

Statement: 28466 – 28479; 28568 – 28579

Arrest Information: 28445; 28456; 28580; 28582 – 28583; 28594

Body Diagram: 28584

Gang Arrest Information: 28593

Case Assignment Slip: 28366

To-From: 28403

Chicago Daily Bulletin: 28413 – 28414; 28419 - 28422

Arrest Warrant: 28417

Stop Order or Cancellation Request: 28427 

Material Submitted for Use in the Daily Bulletin: 28440 

Fingerprint Check Only: 28455

Investigative File Control: 28484

YES NO N/A YES ACB 028703 - 28714 NO N/A NO N/A

28658 - 28661; 28683; Investigative File Control: 28657; 28716

Court Attendance Report: 28662

Arrest Information Slip: 28682

Arrest Report: 28685 – 28686

Statement: 28687 – 28702

Envelope: 28715

YES NO N/A NO N/A NO N/A NO N/A

Inventory # 1299885: 28728Inventory # 1299886: 28730

Inventory of things seized in search: 28729; 28731; Arrest Report: 28720- 28721

Identification Check Procedure: 28723Crime Scene Processing Report: 28732

Crime Laboratory Report: 28733

Hospitalization Case Report: 28734

Supplementary Report: 28735 - 28742

20 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 278 of 433 PageID #:15699
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

72 H-465163 1986 2

Omar Saunders

Bradford Marcelliuss

Duane Roach

Eddie Harris

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 028043 - 47 NO 41 To-from memos in file, 0 listed on Inventory YES ACB 028241 YES

ACB 028214; ACB 

028242 – 28245; AB 

028255 – 28256; 

ACB 028266 – 

28268; ACB 028286 

– 28287; ACB 

028290 – 28291; 

ACB 028293; ACB 

028305 – 28306; 

ACB 028314 – 

28315; ACB 028318 

– 28319; ACB 

028326 – 28330; 

ACB 028333 – 

28336; ACB 028349 

– 28351; ACB 

028357

73 J-381525 1987 4 Albert Buckles YES YES

ACB 046797; ACB 

046837; ACB 046839 

–51; ACB 046853; 

ACB 046855-80;

NO N/A YES ACB 046839 – 46842; ACB 046875 - 46877 YES

ACB 046843; ACB 

046845; ACB 046848; 

ACB 046853; ACB 

046855

NO N/A YES ACB 046797 NO

7 GPRs in file, 4 listed on Inventory

5 Handwritten notes in file, 0 listed on 

Inventory

YES ACB 046843 NO N/A

74 J-418229 1987 1 Mervyn Wright YES YES

ACB 046883-91; ACB 

046920; ACB 046926; 

ACB 046932-46; ACB 

046949-52; ACB 046954-75; ACB 047012-13; ACB 

047958-59

NO N/A YES

*ACB 046934*ACB 046940

*ACB 046942-945*ACB 046954-956*ACB 046958-959*ACB 046961-968

*ACB 046970

*ACB 046974-975

YES

*ACB 046886

*ACB 046936-937

*ACB 046941

*ACB 046946 *ACB 

046950 

*ACB 046952*ACB 046957*ACB 046960

*ACB 046969 *ACB 

046973

*ACB 047013

NO N/A YES ACB 046883 - 46885 NO

22 GPRs in file, 3 listed on Inventory

15 Handwritten notes in file, 5 listed on 

Inventory

YES

ACB 046882; ACB 046886; ACB 046927; ACB 046931; 

ACB 046937-39; ACB 

046950; ACB 046952; ACB 046973; ACB 047013; ACB 

047053 

YES

ACB 046948; ACB 

047049; ACB 

047051

75 J-486857 1987 4 Kevin Murray Tyrone Washington NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047135-47137 UNKNOWN

Cover of file states "Duplicate file, can't find 

original." Appears to be a copy of the 

Permanent Retention File, so unable to evaluate 

whether inventory is complete, because most 

items on the inventory are not in the file

NO N/A NO N/A

76 J-510242 1987 4 Juan Maldonado NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047141-47142 NO 8 Handwritten notes in file, 0 listed on Inventory YES ACB 0 47139-40; ACB 0 47147; ACB 0 47207; ACB 0 47209; ACB 0 47214 YES ACB 0 47187

77 K-300724 1988 4 Alex Aleman NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047286-47287 NO 4 Handwritten notes in file, 0 listed on Inventory YES ACB 047289; ACB 047291; ACB 047303; ACB 047356 NO N/A

21 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 279 of 433 PageID #:15700
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

72 H-465163 1986 2

Omar Saunders

Bradford Marcelliuss

Duane Roach

Eddie Harris

73 J-381525 1987 4 Albert Buckles74 J-418229 1987 1 Mervyn Wright75 J-486857 1987 4 Kevin Murray Tyrone Washington

76 J-510242 1987 4 Juan Maldonado77 K-300724 1988 4 Alex Aleman

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO N/A YES ACB 028140 – 28169; ACB 028181; ACB 028289 YES ACB 028241 YES

ACB 028214; ACB 

028242 – 28245; AB 

028255 – 28256; ACB 028266 – 28268; ACB 028286 – 28287; ACB 028290 – 28291; ACB 

028293; ACB 028305 

– 28306; ACB 028314 – 28315; ACB 028318 – 28319; ACB 028326 – 28330; ACB 028333 – 28336; ACB 028349 

– 28351; ACB 028357

28078 – 28087; 28091 – 28099; 28177 - 28178; Supp Reports (28048-28076); Arrest Report 

(28077; 28088; 28090; 28122 – 28123; 28179 – 28180; 28182 - 28186); Moving of Arrestee out of 

& into arrest (28089); Illinois Sate Police Division of Forensic Science (28100 – 28120; 28307 - 

28312); Form 101 (28121); Lab Corporation of America (28124; 28131); Grand Jury Subpoena 

(28125); Daily Major Incident Log (28126 – 28127); Consenting Party (28128; 28133); Affidavit 

(28129 – 28130); Forensic Identity Testing (28132); Order for use of an eavesdropping device 

(28134); Matter of judicial approval form (28135); Consent to collect biological and/or hair 

standards (28136 – 28138; 28193 – 28196; 28288)'; To-from Memo Central Homicide (28170 – 

28172; 28187 – 28192; 28197; 28212 – 28213; 28215 - 28240); Chicago Police Department Name 

Check Report (28173 – 28174); Arrestee History (28175-28176); Case Fact Sheet (28198 – 

28202); Lori Roscetti PowerPoint (28203 – 28211); Police Narrative (28246 – 28254; 28257 – 

28265); Cook County Jail Visitor Records (28269 – 28285); Person Locator (28292); Subpoena 

(28294); Cellmark Diagnostics (28295 – 28304; 28321; 28352; 28364); Newspaper Article (28313; 

28320); Chicago Tribune Article (28316 – 28317); Circuit Court of Cook County Criminal Division

Fax Cover (28322; 28353; 28358); Agreed Order (28323 – 28325; 28354 – 28356; 28359 - 28361); 

Department of Police Letter (28331); City of Dallas letter (28332); Arrest Information (28348) ; 

HUB travel Center booking locator (28362); City of Chicago Letter (28363)

YES NO N/A YES ACB 046839-46842; ACB 046875- 46877 YES ACB 046848 NO N/A

46798-46802; 46837-46838; 46849-46851; Fingerprints on survival knife (46805)

Photos & Blood Sample (46852)

Photos (46854); Lab Reports (46803-46804)

Form 101 (46821)

Witness Statement (46822-46836)

Diagram (46843)

Firearms Receipt & Worksheet (46844)

Body Diagram (46846)

Fired Evidence Report (46847)

CHESS Memo (46857)

Supp Reports (46858-46874; 46878-46880)

YES NO N/A YES 

ACB 046934; ACB 046940 – 46946; 

ACB 046954 – 46970; ACB 046974 - 

46975

YES

ACB 046882; ACB 046886; ACB 046927; ACB 046931; 

ACB 046937-39; ACB 

046950; ACB 046952; ACB 046973; ACB 047013; ACB 

047053 

YES ACB 046948; ACB 047049; ACB 047051

Inventory # 420962: 46976; Inventory # 420962: 46978; Inventory # 420961: 46979; 46981; Inventory # 420960: 46982; 46984; Inventory # 420959: 46985; 46987; Inventory # 420958: 

46988; 46990; Inventory # 420956: 46991; 46993; Inventory # 420957: 46994; 46996; Inventory # 

440677: 46997; 46999; Inventory # 440678: 47000; 47001; Inventory # 435676: 47074; 47076 – 

47077; Inventory # 435675: 47078; 47080 ;47081

Inventory # 438562: 47082; 47084; Inventory of things seized in search: 46977; 46980; 46983; 

46986; 46989; 46992; 46995; 46998; 47002; 47075; 47079; 47083; 46909 – 46910; 46918 – 

46925; 47012; 47014; 47072 - 47073; Scene: 46887 – 46891

Other: 46935 - 46936; 46932 – 46933; 46972; 47058 - 47059; Court Attendance Report: 46892 – 

46898; 46902 – 46903; 46907 – 46908; 46911 – 46917; 46928

Motion to suppress statement: 46899 – 46901

Subpoena: 46904 – 46905; 46929

Arrest Information: 46906; 46949; 46951; 46971

Request for Latent Fingerprint Comparison: 46926; 46947; 47050 

The University of Chicago Hospitals map: 46930

Arrest Report: 46953; 47052; 47055

Statement: 47003 – 47011; 47031 - 47048

Body diagram: 47029; 47070

Patient Record: 47054

Release of Person in Custody: 47056 - 47057

YES YES YES NO N/A NO N/A NO N/A N/AYES NO N/A YES ACB 047198-47213; ACB 047230; ACB 047237-47241 YES ACB 0 47139-40; ACB 0 47147; ACB 0 47207; ACB 0 47209; ACB 0 47214 YES ACB 0 47187

47177-47186; 47196; 47227-47229; Fingerprints (47223)

Photos (47225); 47195; Arrest Information (47180)

Request for Ballistics Comparison (47188-47189)

Traffic Accident Report (47190-47191)

Vehicle Tow Report (47192)

Arrest Report (47193)

Cable Communications Inc. Bill (47197)

Release of Person In Custody (47215)

Preliminary Fired Evidence Report (47216)

Line-Up Report (47217)

Body Diagram (47220)

YES NO N/A YES ACB 047293-47302; ACB 047324; ACB 047335; ACB 047338 YES ACB 047289; ACB 047291; ACB 047303; ACB 047356 NO N/A

47339-47345; 47320-47321; 47327; 47350; Photos, Blood Samples (47304); 47353; 47365; Inv. 

File Control (47288)

Watch Assignment Sheet (47290)

Form 101 (47292)

Body Diagram (47317)

Arrest Warrant (47346-47347)

Arrest Report (47351)

Supp Report (47354-47355)

Copy of Attorney Business Card (47363)

Copy of Request to stop questioning until lawyer present (47364)

22 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 280 of 433 PageID #:15701
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

78 K-562024 1988 4

Robert McAllister

Joseph BravieriRichard Zuniga

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047370-74732 NO

24 GPRs in file, 19 listed on Inventory

10 Handwritten notes in file, 0 listed on 

Inventory

YES

ACB 047377; ACB 047386; 

ACB 047401-09; ACB 

047437; ACB 047536; ACB 

047555

YES ACB 047473

79 M-139566 1989 4 Miller Holston NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047559 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 047563; ACB 047566 NO N/A

23 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 281 of 433 PageID #:15702
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

78 K-562024 1988 4

Robert McAllister

Joseph BravieriRichard Zuniga

79 M-139566 1989 4 Miller Holston

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES YES

No

• CITY-PRF-03180 = ACB 047370 except PRF 

only has 3 entries instead of the ACB 15. PRF ends 

with “Copy to Unit 164” on 1/4/89.

• Entries from 1/5/89 to 8/22/89 are missing from 

PRF file.

Unlisted Entries in PRF: 

• Evidence Report (Date of Entry (DOE) 1/5/89 – 

Report Date 12/28/88), 

• Crime Lab Photos (DOE 1/13/89), 

• GOCR (DOE 1/26/89 – Report Date 12/18/88), 

• Request for Analysis (DOE 1/30/85 – Report Date 

1/9/89), 

• Supp. Report (DOE 2/23/89 – Report Date 

2/10/89), 

• Property Inventory and Xerox Prop. Inventory 

w/corrections (DOE 6/4/89 - Report Date 6/5/89), 

• Receipt for Exhibit (DOE 6/4/89), 

• Postmortem (DOE 6/27/89), 

• Postmortem (DOE 7/13/89 – Tox. Report Date 

12/26/88), 

• Supp. Crime Lab (DOE 8/22/89 – Report Date 

8/15/89), 

• Supp. Crime Lab (DOE – None)

YES ACB 047373-47378; ACB 047433- 47438; ACB 047442-47455 YES

ACB 047377; ACB 047386; 

ACB 047401-09; ACB 

047437; ACB 047536; ACB 

047555

YES ACB 047473

47416-47432; 47440-47441; 47463; 47476-47477; 47534-47535; 47539-47550; Pertinent Physical 

Evidence (47384)

Photos & Blood Vial (47385-47387)

Cards (47388-47390)

Fingerprints & Shotgun (47521); Person (47554); 47456; 47508-47512; 47553; Arrest Information 

(47379-47380)

Arrest Report (47391-47397)

Complaint for Search Warrant (47398-47408)

Search Warrant (47410-47415)

Request for Analysis (47464; 47474-47475; 47518; 47531; 47551)

Witness Statement (47468-47472; 47513-47517)

Body Diagram (47488-47490; 47495)

Address Book Copy (47556-47557)

YES NO

No

• CITY-PRF-03272 = ACB 047823 except PRF has 

6 entries instead of the ACB 13 entries

• PRF Inventory ends with “Copy to Unit 164” on 

11/29/89. 

• Entries from 12/1/90 to 6/10/90 are missing. 

Unlisted Entries in PRF

• GOCR (DOE 12/1/90 – Report Date 11/18/90)

• Property Inventory (DOE 12/1/90)

• Postmortem (DOE 1/10/90 – Report Date 12/7/89 

– Tox. Report Date 12/6/89)

• Subpoena (DOE 1/23/90 – Subpoena Date 

1/16/90)

• Subpoena (DOE 2/8/90 – Subpoena Date 2/6/90)

• Crime Lab Report (DOE 2/8/90 – Report Date 

2/5/90)

• Subpoena (DOE 6/10/90 – Subpoena Date 6/1/90)

YES ACB 047560-47562 YES ACB 047563; ACB 047566 NO N/A

47616-47621; 47571-47582; 47610-47611; Photo ID (47568)

Photos & Paper Bag with Victim belongings (47569)

Photos & Sealed Envelope (47570); Person (47623-47625); 47564-47565;Arrest Report (47567)

Form 101 (47583)

Body Diagram (47586)

Witness Statement (47597-47599)

Lab Report (47612-47614)

24 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 282 of 433 PageID #:15703
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

80 M-510728 1989 4 Leroy Lyons NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047780 NO 4 To-from memos in file, 3 listed on Inventory NO N/A YES

ACB 047781; ACB 

047786; ACB 047809; ACB 

047811

81 M-534290 1989 4

Gerardo Degollado

David Estrada

Juan Portillo

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047823-24784 NO 4 Handwritten notes in file, 0 listed on Inventory YES

ACB 047826; ACB 047828; ACB 047852; ACB 047856; ACB 047858; ACB 047860; ACB 047889; ACB 047891; ACB 047893; ACB 047922; 

ACB 047956

NO N/A

25 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 283 of 433 PageID #:15704
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

80 M-510728 1989 4 Leroy Lyons81 M-534290 1989 4

Gerardo Degollado

David Estrada

Juan Portillo

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO

No

• CITY-PRF-03339 = ACB 047627 except PRF has 

15 entries instead of the ACB 20 entries. PRF ends 

with GOCR on 12/19/85

• Entries from 2/2/90 to 3/21/90 are missing from 

PRF file

Unlisted Entries in PRF:

• Postmortem (Date of Entry (DOE) 2/2/90 – Report 

Date 1/9/90)

• ASA Subpoena (DOE 2/13/90 – Subpoena Date 

1/24/90)

• Subpoena (DOE 3/12/90 – Supoena Date 3/1/90)

• Receipt for Analysis (DOE 3/21/90 – “Date 

Turner Over” 12/8/89 – Result date 3/7/90)

• Lab Report (DOE 3/21/90 – Report Date 3/8/90)

YES ACB 047818-47819 NO N/A YES

ACB 047781; ACB 

047786; ACB 047809; 

ACB 047811

47812-47817; 47805-47806; 47810; Illinois Bell Records (47774-47778; 47782-47785; 47808)

 Court Notification (47779)

 Form 101 (47787)

 Arrest Report (47788)

 Body Diagram (47804)

 Court Complaint Transmittal (47807)

YES YES

No

• CITY-PRF-03272 = ACB 047823 except PRF has 

6 entries instead of the ACB 13 entries

• PRF Inventory ends with “Copy to Unit 164” on 

11/29/89. 

• Entries from 12/1/90 to 6/10/90 are missing. 

Unlisted Entries in PRF

• GOCR (DOE 12/1/90 – Report Date 11/18/90)

• Property Inventory (DOE 12/1/90)

• Postmortem (DOE 1/10/90 – Report Date 12/7/89 

– Tox. Report Date 12/6/89)

• Subpoena (DOE 1/23/90 – Subpoena Date 

1/16/90)

• Subpoena (DOE 2/8/90 – Subpoena Date 2/6/90)

• Crime Lab Report (DOE 2/8/90 – Report Date 

2/5/90)

• Subpoena (DOE 6/10/90 – Subpoena Date 6/1/90)

YES ACB 047842-47846; ACB 047929- 47938 YES

ACB 047826; ACB 047828; ACB 047852; ACB 047856; ACB 047858; ACB 047860; ACB 047889; ACB 047891; ACB 047893; ACB 047922; 

ACB 047956

NO N/A

47944-47949; 47830; 47872; 47941-47942; 47851; 47855; 47857; Release of Person in Custody 

(47827; 47861)

 Body Diagram (47832; 47904)

 Form 101 (47847)

 Arrest Report (47848-47850; 47853-47854; 47859)

 Witness Statement (47862-47870)

 Vehicle Tow Report (47871)

 ID Record Request (47921)

26 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 284 of 433 PageID #:15705
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

82 M-539997 1989 4 Peter Guzaldo NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 047959-47960 NO 4 Handwritten notes in file, 0 listed on Inventory YES ACB 047972; ACB 047982; ACB 047992 NO N/A

83 M-544975 1989 4 Liddale Jones NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 048023 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 048028 NO N/A

84 M-566742 1989 4 Fredy Roberson YES YES

ACB 047627-28; ACB 

047632; ACB 047660; 

ACB 047662; ACB 

047666; ACB 047673; 

ACB 047677

NO N/A NO N/A YES *ACB 047662 *ACB 047666 NO N/A YES ACB 047627 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 047662; ACB 047666 NO N/A

85 M-568343 1989 4 Steve Jones Perry Lewis YES YES

ACB 0048059-60; ACB 

0048130-33; ACB 

0048135; ACB 

0048137-42

YES

NO - additional 

entries after 

8/8/1990

(ACB 048059-

48060 in Inv. File; 

CRIM.DEF FILES - 

FIELDS 050064, 

CRIM.DEF FILES - 

FIELDS 050212 in 

PD file)

NO N/A NO N/A NO N/A YES ACB 048059-60 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 048062; ACB 048064; ACB 048140; ACB 048142 NO N/A

27 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 285 of 433 PageID #:15706
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

82 M-539997 1989 4 Peter Guzaldo83 M-544975 1989 4 Liddale Jones84 M-566742 1989 4 Fredy Roberson85 M-568343 1989 4 Steve Jones Perry Lewis

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES NO

No

• CITY-PRF-03404 = ACB 048144 except PRF has 

8 entries instead of the ACB 16 entries. PRF ends 

with Subpoena on 12/19/89

• Entries from 12/26/89 to 3/9/91 are missing from 

PRF file

Unlisted Entries in PRF:

• GOCR (Date of Entry (DOE) 12/26/89 – Report 

Date 12/10/89)

• To-From Request for Ballistics (DOE 12/26/89 – 

Report Date 12/20/89)

• Property Inventories (DOE 12/26/89)

• Postmortem (DOE 1/10/90 – Report Date 1/2/90 – 

Tox. Report Date is 12/27/89)

• Request for Ballistics Comparison (DOE 1/26/90 – 

Report Date 12/20/89)

• ASA Subpoena (DOE 2/13/90 – Subpoena Date 

2/6/90)

• Subpoena (DOE 6/15/90 – Subpoena Date 6/8/90)

• IR Sheet (DOE 3/9/91)

YES ACB 047971-47981 YES ACB 047972; ACB 047982; ACB 047992 NO N/A 48012-48014; 47985-47988; 47999-48001; 47989-47991; 47995; Form 101 (47983; 48007) Arrest Report (47993; 48006) Request for Analysis (48011)

YES NO N/A YES ACB 048036-48037 YES ACB 048028 NO N/A

48049-48054; 48033-48035; 48040; Request for Analysis (48031)

 Form 101 (48038; 48046)

 Arrest Report (48039)

 Supp Report (48042)

 Defendant Release Order (48045)

YES YES

No

• CITY-PRF-03339 = ACB 047627 except PRF has 

15 entries instead of the ACB 20 entries. PRF ends 

with GOCR on 12/19/85

• Entries from 2/2/90 to 3/21/90 are missing from 

PRF file

Unlisted Entries in PRF:

• Postmortem (Date of Entry (DOE) 2/2/90 – Report 

Date 1/9/90)

• ASA Subpoena (DOE 2/13/90 – Subpoena Date 

1/24/90)

• Subpoena (DOE 3/12/90 – Supoena Date 3/1/90)

• Receipt for Analysis (DOE 3/21/90 – “Date 

Turner Over” 12/8/89 – Result date 3/7/90)

• Lab Report (DOE 3/21/90 – Report Date 3/8/90)

YES ACB 047661-47670 YES ACB 047662; ACB 047666 NO N/A

47634-47637; 47671; 47638-47641; 47651-47653; 47660; Body Diagram (47649)

 Form 101 (47654)

 Complaint (47655)

 Arrest Report (47656)

 Witness Statement (47657-47658)

 Recording Tape Hold Request (47659)

 Request for Analysis (47673)

 Lab Report (47675-47676)

YES YES

No

• 2nd Page of Inventory (8 entries) Missing from 

PRF File (ACB 048059)

• PRF Inventory Ends with subpoena on 12/21/89.

• Entries from 12/21/89 to 3/9/91 missing from PRF 

file

Unlisted Entries in PRF:

• 2 GPRs (Date of Entry (DOE) 12/21/89 – 

Supervisor Approval 12/19/89)

• Supp. Reports (DOE 12/21/89 – Supervisor 

Approval 12/18/89)

• Postmortem (DOE 2/2/90 – Report Date 12/30/89 

– Tox. Report Date 12/27/89)

• Subpoena (DOE 2/6/90 – Subpoena Date 1/29/90)

• Supp. Report (DOE 8/8/90 – Report Date 7/26/90)

• GOCR (DOE 8/27/90 – Report Date 8/22/90)

• IR Sheet (DOE 3/9/91)

YES ACB 048061-48067; ACB 048118- 48119 YES ACB 048062; ACB 048064; ACB 048140; ACB 048142 NO N/A

48123-48128; 48068-48072; 48087-48089; 48134; Person (48137-48141); 48090-48091; 48135; 

Body Diagram (48094)

 Form 101 (48109-48110)

 Arrest Report (48113; 48115)

 Supp Report (48114; 48120-48122; 48130)

 Case Report (48132-48133)

28 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 286 of 433 PageID #:15707
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

86 M-569727 1989 4 John Avery YES YES

ACB 048144-46; ACB 

048149; ACB 048159; 

ACB 048179-80

YES

NO - additional 

entries after 

12/26/1989

(ACB 048144 in 

Invest. File; 

CRIM.DEF FILES - 

FIELDS 045941 in 

PD File)

NO N/A NO N/A NO N/A YES ACB 048144 NO 3 To-from memos/request for ballistics in file, 2 listed on Inventory; Medical Examiner Report NO N/A YES ACB 048159; ACB 048167; ACB 048176

87 M-580592 1989 4 Elmer Carrillo David Duarte YES YES ACB 048204; ACB 048216; ACB 048316- 27 YES

NO - additional 

entries after 

1/9/1990

(ACB 048182-

48183 in Inv. File; 

CRIM.DEF FILES - 

FIELDS 051064-51065 in PD file)

NO N/A YES

*ACB 048204*ACB 048216*ACB 048323*ACB 048327

NO N/A YES ACB 048182-48183 NO 11 Handwritten notes in file, 0 listed on Inventory YES

ACB 048204; ACB 048216; ACB 048233; ACB 048235; ACB 048237; ACB 048323; 

48327

YES ACB 048187

88 M-587998 1989 4

Darryl Milton

Tony Allen

Cleve Jackson

Robert Brown

Tyrone Brown

Darryl Milton

YES YES

ACB 048329-30; ACB 

048333; ACB 048345; 

ACB 048364; ACB 

048386; ACB 048406-

07; ACB 048419-22

NO N/A NO N/A YES

ACB 048345; ACB 

048364; ACB 048386; 

ACB 048422

NO N/A YES ACB 048329 NO 4 Handwritten notes in file, 1 listed on Inventory YES ACB 048345; ACB 048364; ACB 048386; ACB 048422 YES ACB 048388

89 M-590700 1989 4 Ricky Icenberg YES YES

ACB 047679-80; ACB 

047694; ACB 047696; 

ACB 047751; ACB 

047765; ACB 047767-

72

YES

NO - additional 

entries after 

4/11/1990

 (ACB 047679-

47680 in Inv. File; 

CRIM.DEF FILES - 

FIELDS 052463-52464 in PD file)

NO N/A YES ACB 047694; ACB 047696; ACB 047751 NO N/A YES ACB 047679-80 NO 4 Handwritten notes in file, 0 listed on Inventory YES ACB 047694; ACB 047696; ACB 047698; ACB 047751; ACB 047768 YES ACB 047681

90 D-322218 1999 4

Rodolfo Garcia

Robert Salinas

Sergio Ledesma

Monico Orozco

Philip Deavilla

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 004143-145 NO

Subpoenas –Streetfiles 

Handwritten Statements

Handwritten Notes 

Photos –Person 

YES

ACB 004497 ACB 004582 ACB 004247 ACB 004249 

ACB 04251-252 

ACB 004256ACB 004272 ACB 004326 ACB 004457 ACB 004461

NO N/A

91 D-192218 1999 4 Steven Spears Dion Dorn YES YES

ACB 003680; ACB 

003740-54; ACB 

003768; ACB 003844; 

ACB 003842-43; ACB 

003848-51; ACB 

003859-83

NO N/A YES ACB 003844 YES ACB 003695; NO N/A YES ACB 003680 NO

Search Consent 

General Offense Case Report 

Subpoena – Streetfiles 

Sup. Report 

Crime Scene Proc. Reports

Property Inventories 

GPRs 

Body Diagrams 

Photos – Scene/Body 

NO N/A NO N/A

92 D-579065 1999 4 Jimmy Velasquez YES YES

ACB 004923-25; ACB 

004931-38; ACB 

005007; ACB 005009-

10; ACB 005022-25

NO N/A YES

ACB 005009-10; ACB 

005007; ACB 005023; 

ACB 005022-24

YES

ACB 004930; ACB 

004941; ACB 004975; 

ACB 004984; ACB 

004922; ACB 005036;

NO N/A YES ACB 004823-924 NO

Handwritten Notes

Subpoena Streetfiles 

Property Inventories

YES

ACB 005036 ACB 005024ACB 005007

NO N/A 

93 D-131199 1999 4 Juan Mendez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 002998-999 NO Subpoenas - Streetfiles NO N/A NO N/A

94 D-145734 1999 4 Refugio Gomez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 003118-120 NO

Subpoena – Streetfiles

Biz Card

Handwritten Notes 

YES

ACB 003139 ACB 003142 ACB 003165

NO N/A

95 D-146057 1999 4 Hector Medina NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 003375-379 NO

Subpoenas -Streetfiles 

Handwritten Notes

To- from Memo

Photos – Scene/Body

YES

ACB 003573 ACB 003575 

ACB 003577-578

YES ACB 003374

96 D-454658 1999 4

Raymond Vera

Ricardo Raygoza

Francisco Rodriguez

Frank Arenibar

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 004732-734 NO Subpoenas Streetfiles Request for Evidence ID Photographs NO N/A NO

97 D-724882 1999 4 Tanya McWilliams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 005044 NO Handwritten Note YES ACB 0050669 NO N/A

98 F-475-960 2000 4 Juan Cordova NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007450-451 NO Subpoenas- Streetfiles NO N/A NO N/A

99 F-405-633 2000 4 Joe Jackson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007198-199 NO Subpoenas- Streetfiles Handwritten Notes YES ACB 007218-219 NO N/A

29 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 287 of 433 PageID #:15708
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

86 M-569727 1989 4 John Avery87 M-580592 1989 4 Elmer Carrillo David Duarte88 M-587998 1989 4

Darryl Milton

Tony Allen

Cleve Jackson

Robert Brown

Tyrone Brown

Darryl Milton

89 M-590700 1989 4 Ricky Icenberg90 D-322218 1999 4

Rodolfo Garcia

Robert Salinas

Sergio Ledesma

Monico Orozco

Philip Deavilla

91 D-192218 1999 4 Steven Spears Dion Dorn

92 D-579065 1999 4 Jimmy Velasquez93 D-131199 1999 4 Juan Mendez94 D-145734 1999 4 Refugio Gomez95 D-146057 1999 4 Hector Medina96 D-454658 1999 4

Raymond Vera

Ricardo Raygoza

Francisco Rodriguez

Frank Arenibar

97 D-724882 1999 4 Tanya McWilliams98 F-475-960 2000 4 Juan Cordova99 F-405-633 2000 4 Joe Jackson

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

YES YES

No

• CITY-PRF-03404 = ACB 048144 except PRF has 

8 entries instead of the ACB 16 entries. PRF ends 

with Subpoena on 12/19/89

• Entries from 12/26/89 to 3/9/91 are missing from 

PRF file

Unlisted Entries in PRF:

• GOCR (Date of Entry (DOE) 12/26/89 – Report 

Date 12/10/89)

• To-From Request for Ballistics (DOE 12/26/89 – 

Report Date 12/20/89)

• Property Inventories (DOE 12/26/89)

• Postmortem (DOE 1/10/90 – Report Date 1/2/90 – 

Tox. Report Date is 12/27/89)

• Request for Ballistics Comparison (DOE 1/26/90 – 

Report Date 12/20/89)

• ASA Subpoena (DOE 2/13/90 – Subpoena Date 

2/6/90)

• Subpoena (DOE 6/15/90 – Subpoena Date 6/8/90)

• IR Sheet (DOE 3/9/91)

NO N/A NO N/A YES ACB 048159; ACB 048167; ACB 048176 48171-48175; 48146; 48149; 48168-48170; 48179; Body Diagram (48156) Case Report pages 1 & 2 (48161-48162)

YES NO N/A YES 

ACB 048192; ACB 048198-48205; 

ACB 048211-48220; ACB 048222-

48236

YES

ACB 048204; ACB 048216; ACB 048233; ACB 048235; ACB 048237; ACB 048323; 

48327

YES ACB 048187

48312-48314; 48188-48191; 48209-48210; Person (48317-48320); 48184-48185; 48197; 48221; 

48311; 48321-48326; Arrest Info (48186)

 Form 101 (48208)

 Release of Person in Custody (48238)

 Body Diagram (48245)

 Witness Statement (48276-48291)

 Arrest Report (48292-48293)

YES NO N/A YES 

ACB 048331; ACB 048344; ACB 

048362-48365; ACB 048369; ACB 

048379-48381

YES ACB 048345; ACB 048364; ACB 048386; ACB 048422 YES ACB 048388

48408-48413; 48338-48340; 48349; 48389-48390; 48423; Body Diagram (48342)

 Line-Up Info (48348)

 Form 101 (48350; 48371; 48382)

 Arrest Report (48352-48353; 48370; 48383; 48385)

 Request for Analysis (48378)

 Permission to Search (48384; 48387)

 Witness Statement (48391-48396)

 Lab Report (48414-48415)

 ID Card (48419-48420)

 Typed Note (48421)

YES NO N/A YES ACB 047689-47697; ACB 047716- 47722 YES ACB 047694; ACB 047696; ACB 047698; ACB 047751; ACB 047768 YES ACB 047681

47761-47764; 47682-47684; 47686; Person (47767-47772); 

 Body Diagram (47688)

 Witness Statement (47733-47735)

 Form 101 (47743; 47756)

 Arrest Warrant (47744-47745; 47757-47758)

 Complaint (47746-47748)

 Consent to Search (47749)

 Arrest Report (47750; 47754)

NO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/ANO N/A N/A N/A N/A N/A N/A N/A N/A N/A

30 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 288 of 433 PageID #:15709
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

100 F-731010 2000 4 Eric Brocks Johnny Sims NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007787 YES N/A NO N/A NO N/A

101 F-746059 2000 1 Jermaine Washington NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007831 NO Photos – Scene/Body NO N/A NO N/A

102 G-032399 2001 1 Latoya Jones Diante Wiley YES YES

ACB 009209-10; ACB 

009215-20; ACB 009264-77; ACB 009282-86; ACB 

009288-302; ACB 

009333-34; ACB 009365-66; ACB 

009369; ACB 009409-

13

NO N/A NO N/A NO N/A NO N/A YES ACB 009209-9210 NO

Photos – Person 

Daily Major Incident Log 

To-From Memo

Felony Minutes- Form 101

Child Abuse Investigation/Placement Report 

Consent to Search Form

NO N/A YES ACB 009264

103 G-082465 2001 1 Andre Richardson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 009545-9546 YES N/A NO N/A NO N/A104 G-108432 2001 1 Rasson Davis Gregory Brown NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 010196-10197 NO Handwritten notes (10286-10288; 10300) YES ACB 010287-10289, ACB 010300, ACB 010339 NO N/A

105 G-118582 2001 1 Stanton Adams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 010563 NO Handwritten notes (10715-10717; 10725- 10727) YES ACB 010686, ACB 010715- 10717, ACB 010721-10722, ACB 010734 NO N/A

106 G-128509 2001 1 Leonard Suggs NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 010777-10779 NO Handwritten notes (10851-10854; 10867; 10869; 10882-10887; 10889-10892) YES

ACB 010851-10852, ACB 

010854, ACB 010858, ACB 010867, ACB 010869, ACB 

010882-10887, ACB 010889-

10892, ACB 010917

YES ACB 010855, ACB 010908-10915

107 G-142325 2001 4 Brian Robinson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 010999-11000 NO Handwritten notes (11005; 11051); Subpoena (11001) YES ACB 011051, ACB 011148 NO N/A

108 G-152113 2001 1 Tirrell Marshall Aaron Givens NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 011361-11362 NO Handwritten notes (11529); Crime Scene Photos (11366-11406) NO N/A NO N/A

109 G-168213 2001 1 Shakina Feazell Dion Banks NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 011979-11981 NO Handwritten notes (12064; 12067) Subpoena (12202; 12203) YES ACB 012155-12156 YES ACB 012178

110 G-187460 2001 4 Arnold Paris NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 012381-12382 NO GPR (12385) NO N/A NO N/A111 G-188311 2001 1 Donny McGee NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 012525-12528 NO Handwritten note (12681; 12735; 12779) GPR (12706) YES ACB 012681, ACB 012735, ACB 012739, ACB 012779, ACB 012794 NO N/A

112 G-188820 2001 1 Tyrone Sanders NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 012881-12883 NO GPRs (13038-13063) Handwritten notes (13061-13065) YES

ACB 012972, ACB 012976, 

ACB 013002, ACB 013061-

13062, ACB 013064-13065, 

ACB 013102

NO N/A

113 G-190057 2001 1 Donald Mann NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 013146 NO To-from Memo (13173-13174) NO N/A YES ACB 013173-13174114 G-221780 2001 1 Maurice Forest NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 013572-13573 NO Handwritten note (13609; 13644; 13723-13724) YES

ACB 013605, ACB 013609, 

ACB 013644, ACB 013723-

13724, ACB 013726

NO N/A

115 G-226841 2001 1 Carl Jones Andre Jackson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 013742-13743 NO Handwritten note (13981; 14005; 14054); 63 GPRs inventoried, 71 in the file. YES ACB 014005 NO N/A

116 G-248938 2001 1 Jeffery Hester NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 014469-14471 NO To-from Memo (14541); Handwritten note (14688) YES ACB 014598-14599, ACB 014688 YES ACB 014541

117 G-259321 2001 1 Kevin Jackson YES NO N/A YES YES NO N/A NO N/A NO N/A NO N/A N/A N/A118 G-261213 2001 1 Samer Itani NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 014926-14927 NO Handwritten note (15026; 15039) NO N/A NO N/A119 G-266841 2001 1 Timothy Malone YES YES

ACB 15162-15164; 

ACB 15179-15180 

ACB 015186; 15183-

15184; ACB 15191-95; 

ACB 015199-200; ACB 

015263; ACB 015268; 

ACB 015270; ACB 

015281

NO N/A YES

*ACB 015194-195

*ACB 015268*ACB 015281

YES *ACB 015263

*ACB 015270

YES ACB 015192 YES ACB 015162 NO Photo- Person NO N/A NO N/A

120 G-268444 2001 1 Isaiah Brady YES YES

ACB 015506; ACB 

015661; ACB 015670; 

ACB 015601; ACB 

015603; ACB 015642-

71; ACB 015606-09; 

ACB 015728-35; ACB 

015740; ACB 015675-

79; ACB 015689-700; 

ACB 015511; ACB 

015584-85; ACB 015591-92; ACB 015701-02; ACB 

015623; ACB 015641; 

ACB 015672-74; ACB 

015686-87; ACB 

015688; ACB 015703-

04

YES

NO - additional 

entries after 

1/10/2002

(PD file - 

CRIM.DEF FILES - 

FIELDS 025609-

10; Inv. File - 

15506-15507)

YES

ACB 015601; ACB 

015603; ACB 015642-

15671

YES ACB 015661; ACB 015670 NO N/A YES ACB 015506-15507 NO Handwritten note (15661; 15670) YES ACB 015591, ACB 015661, ACB 015670 NO N/A

121 G-276602 2001 1 Thomas Reese NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 015763-15764 NO Handwritten note (15994) To-from Memo w/ handwritten note (16000) YES ACB 015994, ACB 015998, ACB 016002 YES ACB 016000-16001

122 G-311269 2001 1 Tracy Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016402-16403 NO Case Report (16542-16543) NO N/A NO N/A

123 G-322669 2001 1 Carlos Corona NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 016883-16884 NO Handwritten note (16996) YES

ACB 016996, ACB 017000, ACB 017029, ACB 017038, 

ACB 017042

NO N/A

31 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 289 of 433 PageID #:15710
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

100 F-731010 2000 4 Eric Brocks Johnny Sims

101 F-746059 2000 1 Jermaine Washington102 G-032399 2001 1 Latoya Jones Diante Wiley103 G-082465 2001 1 Andre Richardson104 G-108432 2001 1 Rasson Davis Gregory Brown105 G-118582 2001 1 Stanton Adams106 G-128509 2001 1 Leonard Suggs107 G-142325 2001 4 Brian Robinson108 G-152113 2001 1 Tirrell Marshall Aaron Givens109 G-168213 2001 1 Shakina Feazell Dion Banks110 G-187460 2001 4 Arnold Paris111 G-188311 2001 1 Donny McGee112 G-188820 2001 1 Tyrone Sanders113 G-190057 2001 1 Donald Mann114 G-221780 2001 1 Maurice Forest115 G-226841 2001 1 Carl Jones Andre Jackson

116 G-248938 2001 1 Jeffery Hester117 G-259321 2001 1 Kevin Jackson118 G-261213 2001 1 Samer Itani119 G-266841 2001 1 Timothy Malone120 G-268444 2001 1 Isaiah Brady121 G-276602 2001 1 Thomas Reese122 G-311269 2001 1 Tracy Williams123 G-322669 2001 1 Carlos Corona

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

32 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 290 of 433 PageID #:15711
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

124 G-326467 2001 1

Anthony Mason

Edward Ware

George Frison

Eddie Baker

YES YES

ACB 017073-075; ACB 

017077; ACB 017079-

116; ACB 017118-55; 

ACB 017157-161; ACB 

17178; ACB 17182-87; 

ACB 017195; ACB 

017198; ACB 017201; 

ACB 017232; ACB 

017241; ACB 017256; 

ACB 01265; ACB 017266-275; ACB 

017277-82; ACB 

017300-302; ACB 017317-318; ACB 017360-361; ACB 

017374; ACB 017376

NO N/A YES

ACB017300-302, ACB017317-318, 

ACB017360-361

YES

ACB017154-155, 

ACB017185,

ACB017374

NO N/A YES ACB 017073-075 NO

Complaints for Preliminary Examination 

Handwritten Notes 

Criminal History

ISP Submission

Photos –Scene/Body

Request for Evidence Identification 

Photographs 

YES

ACB 017154-155 

ACB 017185 

ACB 017370-371

NO N/A

125 G-330755 2001 1 Pyreese Waller Jermaine Roberson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 017382-17383 NO To-from Memo (17452) Handwritten note (17552) YES ACB 017548, ACB 017552 YES ACB 017452-17453

126 G-356804 2001 1 James House NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 017766-17767 NO Supp Report, July 14, 01 (17841-17842) NO N/A NO N/A127 G-380402 2001 4 Jose Jimenez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 017987-17988 NO Handwritten note (18046) YES ACB 018015-18016, ACB 018046-18047 NO N/A

128 G-389122 2001 1 Kenneth Gayden NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 018226-18227 NO Daily Major Incident Logs (18346-18347) NO N/A NO N/A

129 G-390651 2001 1 Francisco Rodriguez Julio Camacho NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 018350-18351 NO Handwritten notes (18407-18410) YES ACB 018407-18410, ACB 018469 YES ACB 018470-18473

130 G-397986 2001 1 Stacy Samuels NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 018514 NO Daily Major Incident Log (18518) Request for Evidence (18519-18520) NO N/A NO N/A

131 G-399481 2001 1 Desmond Vinson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 018559-18561 NO Handwritten note (18770) YES ACB 018729, ACB 018770 YES ACB 018782132 G-406405 2001 1 Santana McCree YES YES

ACB 018902; ACB 

018942; ACB 019026; 

ACB 019028-30; ACB 

019051-052

YES

NO - additional 

entries after 

1/14/2002

(ACB018902 in 

Inv. File; 

CRIM.DEF FILES - 

FIELDS 007060 in 

PD file)

NO N/A YES ACB 019146 YES ACB019024, ACB019028 YES ACB 018901-902 NO

Hospitalization Case Report 

Handwritten Note

IL Torture Commission Files

Photos- Scene/Body

Photos-Person

YES ACB 019084 NO N/A

133 G-419125 2001 1 Francisco Gutierrez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 019191-19193 NO Handwritten note of crime scene diagram (19351) YES ACB 019328, ACB 019351, ACB 019381 NO N/A

134 G-425608 2001 1 Ernest Motes NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 019458-19460 NO Handwritten note (19630; 19632; 19716) Photocopies (19665-19667) YES ACB 019667, ACB 019716 NO N/A

135 G-434632 2001 1 Barabara Rolark NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 019725-19726 NO Typed Memo (19813-19818) Subpoena (19874) NO N/A NO N/A

136 G-443474 2001 4 Salvador Rico NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 019876-19877 NO Handwritten note (20030; 20032) NO N/A NO N/A

137 G-447444 2001 1 Derrick Crawford NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 020158 NO

Daily Major Incident Log (20237)

Handwritten note (20240; 20321)

Supp Report CC (20241-20250)

YES ACB 020321 NO N/A

138 G-450601 2001 1 Margaret Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 020327-20328 NO Daily Major Incident Log (20361) Handwritten note (20408) NO N/A NO N/A

139 G-451387 2001 1 Ubex Lopez Richard Gacho NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 020455-20456 NO Handwritten note (20541) YES ACB 020460, ACB 020463, ACB 020541 NO N/A140 G-456492 2001 1 Filimon Resendez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 020565-20566 NO

 Handwritten note (20620; 20688; 20692; 

20721; 20723; 20731-20736; 20742; 20764; 

20767; 20779-20789)

To-from Memo (20683-20690; 20710-20713)

YES

ACB 020620-20621, ACB 

020631, ACB 020688, ACB 020692, ACB 020721, ACB 

020723, ACB 020731-

20736, ACB 020742, ACB 

020764, ACB 020767, ACB 020779, ACB 020781, ACB 

020783-20789

YES

ACB 020648, ACB 

020683-20687, ACB 020689-20690, ACB 

020710-20713

141 G-491442 2001 1 Edward Pleasant NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 021420-21421 NO Daily Major Incident Log (21573-21575) NO N/A NO N/A

142 G-497018 2001 1 Gerald Henry NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 021577-21578 NO Case Report (21649-21650) NO N/A NO N/A

143 G-506663 2001 4 Miguel Garcia NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 021808-21811 NO

Handwritten note (21858; 21864; 22064-22065; 

22078; 22081-22083)

To-from Memo w/ photo of poss. Offender 

(22066)

YES

ACB 021858, ACB 021864, 

ACB 021868, ACB 021875-

21880, ACB 021896, ACB 

022064-22065, ACB 

022067, ACB 022069, ACB 

022074-22075, ACB 022078-

22079, ACB 022081-22083

NO N/A

144 G-541859 2001 1 Alan Coleman NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 022139 NO Witness Statements (22206-22234) NO N/A NO N/A145 G-543889 2001 1 Bennie Teague NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 022261-22262 NO

Daily Major Incident Log (22330-22331)

Body Diagram (22384)

Attorney IDs and notes (22370-22371)

YES ACB 022370-22376 NO N/A

146 G-547890 2001 1

Juan Macias

Sergio Jimenez

Christopher Kuhar

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 022495 NO Handwritten note (22632; 22652) Inv. Alerts (22620; 22621) YES ACB 022632 NO N/A

147 G-554146 2001 1 Leroy Washington NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 022656-22657 NO Handwritten note (22757; 22760; 22762) To-from Memo (22761) YES ACB 022742, ACB 022755- 22757, ACB 022762 YES ACB 022751-22754, ACB 022758-22761

148 G-556311 2001 4 Roberto Barrera NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 022824-22825 NO

Handwritten note (22831)

ISP Criminal History Record Info (22827-

22829)

NO N/A NO N/A

149 G-567131 2001 1 Charles Walker Michael Harris NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 022950-22951 NO Handwritten note (23130; 23178; 23188; 23226) Daily Major Incident Log (23028-23030) YES ACB 023134, ACB 023178, ACB 023226 NO N/A

33 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 291 of 433 PageID #:15712
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

124 G-326467 2001 1

Anthony Mason

Edward Ware

George Frison

Eddie Baker

125 G-330755 2001 1 Pyreese Waller Jermaine Roberson126 G-356804 2001 1 James House127 G-380402 2001 4 Jose Jimenez128 G-389122 2001 1 Kenneth Gayden129 G-390651 2001 1 Francisco Rodriguez Julio Camacho130 G-397986 2001 1 Stacy Samuels131 G-399481 2001 1 Desmond Vinson132 G-406405 2001 1 Santana McCree133 G-419125 2001 1 Francisco Gutierrez134 G-425608 2001 1 Ernest Motes135 G-434632 2001 1 Barabara Rolark136 G-443474 2001 4 Salvador Rico137 G-447444 2001 1 Derrick Crawford138 G-450601 2001 1 Margaret Thomas139 G-451387 2001 1 Ubex Lopez Richard Gacho

140 G-456492 2001 1 Filimon Resendez141 G-491442 2001 1 Edward Pleasant142 G-497018 2001 1 Gerald Henry143 G-506663 2001 4 Miguel Garcia144 G-541859 2001 1 Alan Coleman145 G-543889 2001 1 Bennie Teague146 G-547890 2001 1

Juan Macias

Sergio Jimenez

Christopher Kuhar

147 G-554146 2001 1 Leroy Washington148 G-556311 2001 4 Roberto Barrera149 G-567131 2001 1 Charles Walker Michael Harris

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

34 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 292 of 433 PageID #:15713
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

150 G-570120 2001 1 Crisino Bravo Filiberto Bravo YES YES

ACB 023264; ACB 

023268-307, ACB 

023309-351; ACB 

023366; ACB 023369-

70; ACB 023379; ACB 

023382; ACB 023386-

388; ACB 023392; 

ACB 023402; ACB 

023412-417; ACB 

23421; ACB 023427-

28; ACB 023432; ACB 

023446-447; ACB 

23456; ACB 023460-468; ACB 023469-71

NO N/A YES

*ACB 023402

*ACB 023412-417

*ACB 023421*ACB 023432*ACB 023438*ACB 023427

YES ACB 023370 NO N/A YES ACB 023264 NO

Photos – Person

Photos – Scene/Body

Biz. Card

Handwritten Note 

Subpoena –Defense

Daily Major Incident Log 

YES ACB 023370 NO N/A

151 G-575283 2001 1 Andrzej Konopacki NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 023474 NO Daily Major Incident Log (23477; 23536) Handwritten note (23554; 23559) NO N/A NO N/A

152 G-578724 2001 1 Tramel Foreman NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 023608-23610 NO Handwritten note (23614; 23751) Daily Major Incident Log (23613-23615) YES ACB 023696, ACB 023751, ACB 023760 NO N/A

153 G-592219 2001 1 Raul Lemus NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 023801-23803 NO Handwritten note (23878; 23934-23936) YES ACB 023934-23936 NO N/A

154 G-602617 2001 1 Kimberley Hood NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 024047 NO 3 to-from memos are listed and there are 4 in the file. (24062; 24106-24108) NO N/A YES ACB 024062, ACB 024106-24108

155 G-630073 2001 1 Iran Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 024118-24119 NO

GPRs - 2 are listed and there are 25 in the file. 

(24267-24295) 

Handwritten notes (24270; 24272; 24296; 

24318)

YES ACB 024270, ACB 024296, ACB 024318 NO N/A

156 G-630295 2001 1 Terry Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 024369-24374 NO 2 Handwritten notes listed, 4 in file (24439; 24686-24687; 24737) YES ACB 024439, ACB 024686, ACB 024737 NO N/A

157 G-632707 2001 1 Baruch Shaw NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 024743-24745 NO

0 GPRs listed in the inventory, 55 in the file 

(24771-24818)

Handwritten note (24751)

YES ACB 024834, ACB 024836, ACB 024840 YES ACB 024832, ACB 024842-24845

158 G-648246 2001 1 Helen Kos NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 024984-24986 NO Handwritten note (25089; 25091; 25093; 25127) YES ACB 025091, ACB 025093, ACB 025127 NO N/A

159 G-655145 2001 1 Earl Herron NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 025281-25282 NO Inv. File Control (25285) NO N/A NO N/A

160 G-656885 2001 1 Larry Simpson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 025436-25437 NO Handwriten/drawn sketch (25603; 25607) YES ACB 025603, ACB 025607 NO N/A

161 G-670379 2001 1

Devale HolmanSandy Williams

Ebonie Gadison

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 025617-25619 NO Handwritten note (25741; 25788) YES ACB 025687, ACB 025788 NO N/A

162 G-678089 2001 1 Omarr Teague NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 025963-25964 NO

Inv. File Control (26034)

64 Photos (25969-26033)

Handwritten note (26139)

NO N/A NO N/A

163 G-686446 2001 1

Jason Davis

Mario Garcia

Hector Flores

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 026145-26147 NO 10 Handwritten notes in file, 2 listed on Inventory YES

ACB 026226, ACB 026252, ACB 026257, ACB 026311, ACB 026396, ACB 026423, ACB 026434, ACB 026436, ACB 026438, ACB 026440, 

ACB 026483

NO N/A

164 G-688481 2001 1 Terry Powe NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 026524-26525 NO

Inv. File Control (26528)

Photos (26530-26546)

Community Alert Flyer (26611)

YES ACB 026610 NO N/A

165 G-691809 2001 1 Johnnie Hill NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 026747-26748 NO 2 Handwritten notes in file, 0 listed on Inventory YES ACB 026832, ACB 026895 NO N/A

166 G-694725 2001 4

Jermaine Jackson

Peter Lawrence

Byron Jones

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 007899-7901 NO

To-from Memo (7902; 8047)

Typed Witness List with Handwritten notes 

(7904)

Handwritten map (8081)

YES ACB 007902-7904, ACB 008081 YES ACB 008047

167 G-694885 2001 1 William Lyles NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 026934-26935 NO Inv. File Control (26966) Photos (26939-26965) NO N/A NO N/A

168 G-701363 2001 4 Erik Argueta NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 008168-8170 NO

Handwritten note (8266)

Attorney Business Card (8303)

(Note: it appears something on line 23, page 

8170 was whited-out.)

NO N/A NO N/A

169 G-705434 2001 1 Norman McIntosh YES YES

ACB 027080-082; ACB 

027085-104; ACB 027106-135; ACB 027136-137; ACB 

027139-77; ACB 

027183-187; ACB 027193-197; ACB 027204-205; ACB 

027222; ACB 027231-

233; ACB 027246-47; 

ACB 027250; ACB 

027255-257; ACB 

027280; ACB 027283-

84

NO N/A YES ACB027231-233, ACB027246-247 YES ACB 027222 NO N/A YES ACB 027080-082 NO

Outreach Ministry Card

Handwritten Note 

Photos - Scene/Body

Daily Major Incident Log 

YES ACB 027222 NO N/A

170 G-708133 2001 1 Kevin McGraw NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 027316-27317 NO Miranda Warning with Handwritten note (27432) NO N/A NO N/A

171 G-722334 2001 1 Renetta Braboy NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 027436 NO

To-from Memo with Handwritten note (27490)

3 Handwritten notes in file, 0 listed on 

Inventory

NO N/A NO N/A

172 G-751124 2001 1 Jorge Mendez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 027627 NO State's Ex. 1 Photo (27658) 1 Handwritten note in file, 0 listed on Inventory NO N/A NO N/A

173 G-759169 2001 1 Arthur Shanklin NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 027720-27722 NO 33 GPRs in file, 32 listed on Inventory 1 Handwritten note in file, 0 listed on Inventory YES ACB 027879 NO N/A

35 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 293 of 433 PageID #:15714
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

150 G-570120 2001 1 Crisino Bravo Filiberto Bravo

151 G-575283 2001 1 Andrzej Konopacki152 G-578724 2001 1 Tramel Foreman153 G-592219 2001 1 Raul Lemus154 G-602617 2001 1 Kimberley Hood155 G-630073 2001 1 Iran Thomas156 G-630295 2001 1 Terry Thomas157 G-632707 2001 1 Baruch Shaw158 G-648246 2001 1 Helen Kos159 G-655145 2001 1 Earl Herron160 G-656885 2001 1 Larry Simpson161 G-670379 2001 1

Devale HolmanSandy Williams

Ebonie Gadison

162 G-678089 2001 1 Omarr Teague163 G-686446 2001 1

Jason Davis

Mario Garcia

Hector Flores

164 G-688481 2001 1 Terry Powe165 G-691809 2001 1 Johnnie Hill166 G-694725 2001 4

Jermaine Jackson

Peter Lawrence

Byron Jones

167 G-694885 2001 1 William Lyles168 G-701363 2001 4 Erik Argueta169 G-705434 2001 1 Norman McIntosh170 G-708133 2001 1 Kevin McGraw171 G-722334 2001 1 Renetta Braboy172 G-751124 2001 1 Jorge Mendez173 G-759169 2001 1 Arthur Shanklin

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

36 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 294 of 433 PageID #:15715
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

174 G-763-171 2001 4 Andres Martinez William Pelmer NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 008362-8365 NO 64 GPRs in file, 62 listed on Inventory 2 To-from memos in file, 0 listed on Inventory YES ACB 008440-8444, ACB 008759 YES ACB 008451-8456

175 G-776686 2001 1 LaTonya Starnes NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 027956 NO

Inv. File Control (27961)

2 Hospitalization Case Reports in file, 1 listed 

on Inventory

Photos (28032-28040)

NO N/A NO N/A

176 HH-101153 2002 1 Henry Ingram NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 028753-28754 NO

ACB 028752: Folder Cover; ACB 028756: 

Homicide File Review; ACB 028758-762: Crim.

History Stuckey; ACB 028766-767: Lab 

Report; ACB 028768-69: ISP to-from; ACB 

028770: Investigative File Control; ACB 

028781: Biz Card; ACB 028811-812, ACB 

028829, ACB 028834, ACB 028922, ACB 

028948, ACB 028974: Handwritten notes; ACB 

028855-56 Tow Vehicle Report; ACB 028866-

67: Firearm Recovery Report; ACB 028977, 

ACB 029016: Envelope; ACB 028978-015, 

ACB 029018-038, ACB 029040-046: Photos 

Scene; ACB 029017, ACB 029039: Photo 

Scene Card

YES

ACB 028811-28812

 ACB 028869

ACB 048894ACB 048899ACB 048900

YES 028868 ACB 028870-

177 HH-105486 2002 1 Marcus Robinson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 029048-29049 NO

No

Not Listed:

ACB 029047: Folder Cover

ACB 029050: Homicide File Review

ACB 029051: Investigative File Control

ACB 029052: Daily Major Incident Log

ACB 029093: Handwritten note

YES ACB 029130 YES ACB 029128-29129 ACB 029155

178 HH-112360 2002 UNK

Lawrence Bradley

Iran Thomas

Byron Nelson

Corey Hodges

Jerome Weathers

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A NO N/A NO N/A

179 HH-112848 2002 1 Montreis Hinton NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 029287-29289 NO

ACB 029286: Folder Cover

ACB 029290: Homicide File Review

ACB 029291: Envelope

ACB 029292-306: Scene/Body Photo

ACB 029307: Scene Card Photo

ACB 029308: Investigative File Control

ACB 029310, ACB 029314: Daily Major 

Incident Log

ACB 029499: Handwritten Note

NO N/A YES ACB 029312-29313

180 HH-123814 2002 1 Ardell NcNeal Roderick Smith NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 029542-29544 NO

ACB 029541: Folder Cover

ACB 029545: Homicide File Review

ACB 029546: Envelope

ACB 029547-570: Scene/Body Photo

ACB 029571: Investigative File Control

ACB 029575, ACB 029577, ACB 029581, 

ACB 029583: Moving of Arrestee

ACB 029627-628: Crime Scene Processing 

Report and copy (only one listed in inventory)

NO N/A NO N/A

181 HH-131667 2002 1 Antoine Sanders NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 029768-29770 NO Handwritten Notes

Photos- Scene/Body

YES ACB 029847 ACB 029886-887 NO N/A

182 HH-138499 2002 1 Reginald Flemister NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 029976-29978 NO Daily Major Incident Log Photos NO N/A NO N/A183 HH-154152 2002 1 Eric Nichols NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 030243-245 NO

ACB 030242: Folder

ACB 030246: Homicide File Review 

ACB 030247, ACB 030421: Envelope

ACB 030248-250, ACB 030252-265: Scene/ 

Body Photo

ACB 030251: Scene Card Photo

ACB 030266: Investigative File Control

ACB 030411: Moving of Arrestee

ACB 030432-435: Major Crime Worksheet

ACB 030444-445, ACB 030447-448: 

Investigative Alerts

ACB 030302, ACB 030304, ACB 030306, ACB 030315, ACB 030322, ACB 030345, ACB 030354, ACB 030397, ACB 030408, 

ACB 030413: Handwritten Notes

YES

ACB 030302ACB 030304ACB 030306ACB 030315ACB 030323

NO N/A

184 HH-158954 2002 1 Victor Wright NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 048948-950 NO To-From memo Daily Major Incident Lot YES ACB 049154 NO N/A

185 HH-175723 2002 1 Maurice Brown YES YES

ACB 049235-236; ACB 

049240; ACB 049243; 

ACB 049245; ACB 

049264; ACB 049266-

267; ACB 049306-308; 

ACB 049350; ACB 

049385, ACB 049387; 

ACB 049394-95, ACB 

049397, ACB 049399

NO N/A NO N/A YES

ACB049383, ACB049385, 

ACB049387

NO N/A YES ACB 049236-237 NO

GPR

Handwritten Note 

Photos – Scene/Body

Daily Major Incident Log 

YES ACB 049387 ACB 049385 NO N/A

186 HH-249096 2002 1 Armando Cruz NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 049404-49406 NO

Daily Major IncidentFelony Minutes 101s

Photos- Scene/Body

Arrest Report

NO N/A NO N/A

37 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 295 of 433 PageID #:15716
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

174 G-763-171 2001 4 Andres Martinez William Pelmer

175 G-776686 2001 1 LaTonya Starnes176 HH-101153 2002 1 Henry Ingram177 HH-105486 2002 1 Marcus Robinson178 HH-112360 2002 UNK

Lawrence Bradley

Iran Thomas

Byron Nelson

Corey Hodges

Jerome Weathers

179 HH-112848 2002 1 Montreis Hinton180 HH-123814 2002 1 Ardell NcNeal Roderick Smith181 HH-131667 2002 1 Antoine Sanders182 HH-138499 2002 1 Reginald Flemister183 HH-154152 2002 1 Eric Nichols184 HH-158954 2002 1 Victor Wright185 HH-175723 2002 1 Maurice Brown186 HH-249096 2002 1 Armando Cruz

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

38 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 296 of 433 PageID #:15717
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

187 HH-257532 2002 1 Curtis Baldwin NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 049738-49740 NO

ACB 049737: Folder Cover; ACB 049741: 

Homicide File Review; ACB 049742: 

Investigative File Control; ACB 049743: 

Envelope; ACB 049744-770, ACB 049773-792: 

Scene/Body Photo; ACB 049771-772: Scene 

Card Photo; ACB 049793-794: Daily Major 

Incident Log; ACB 049877, ACB 049906: 

Handwritten Note; ACB 049923: Moving of 

Arrestee; ACB 049878: License Plate; ACB 

049897: Arrest Report; ACB 049844-845 and 

ACB 049824-825: ISP forensic report and copy 

of report. only listed once in inventory

YES ACB 049896 NO N/A

188 HH-263021 2002 1 Josheph Murchison Steven Brandon NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 050033-50034 NO Clear Data Inventory Recovered Reports Daily Major Incident Log Photos- Scene/Body NO N/A NO N/A

189 HH-270572 2002 1 Ernesto Flores Rogelio Guerra NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 050135-50137 NO

ACB 050134: Folder Cover; ACB 050138: 

Homicide File Review; ACB 050139-142: Daily

Major Incident Log; ACB 050143, ACB 

050319: Handwritten Note; ACB 050144-145: 

Investigative File Control; ACB 050225: Biz. 

Card; ACB 050320, ACB 050261: Envelope; 

ACB 050321, ACB 050331, ACB 050337-338, 

ACB 050362, ACB 050368, ACB 050379, 

ACB 050390-391: Scene Card Photo; ACB 

050322-330, ACB 050363-367, ACB 050369-

378, ACB 050380-389, ACB 050392-395: 

Persons Photo; ACB 050332-336, ACB 050339-

360: Scene/Body Photo; ACB 050400-401: 

Crime Scene Proc. Report and copy (only listed 

once)

YES ACB 050143 NO N/A

190 HH-279592 2002 1 Ron Turner Jarmichael Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 050510-50511 NO

ACB 050425-426: Folder Cover; ACB 050427, 

ACB 050560: Envelope; ACB 050428, ACB 

050493: Scene Card Photos; ACB 050429-459, 

ACB 050461-492, ACB 050494-496: 

Scene/Body Photos (only 4 crime scene photos 

listed but 63 Scene photos present); ACB 

050497: Investigative File Control; ACB 

050498-500: Daily Major Incident Log; ACB 

050501-504, ACB 050506-509: To-From 

Memo; ACB 050505, ACB 050556, ACB 

050588, ACB 050620, ACB 050626: 

Handwritten Note; ACB 050552, ACB 050606: 

Arrest Report; ACB 050558-559: Viewer’s Map 

(Only 1 listed but 2 present); ACB 050569-660: 

I-Cam Photo Smith (only 1 listed but 2 present); 

ACB 050575-576, ACB 050592: Arrestee 

History Photo; ACB 050584, ACB 050605: 

Photo Person; ACB 050591: Investigative Alert

YES

ACB 050505ACB 050588ACB 050626

YES

ACB 050501 ACB 050502ACB 050503ACB 050506

ACB 050507-509

191 HH-280024 2002 1 Andrew Robinson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 050660-50662 NO Handwritten Notes YES ACB 050907-908 NO N/A192 HH-280696 2002 1 Willie Murray John Murray NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 030468-30469 NO

Photos- Body

Daily Major Incident Log

Handwritten Notes

Name Check Report

Moving of Arrestee

YES

ACB 030509ACB 030520ACB 030575

NO N/A

193 HH-285733 2002 1 DeShanta Young NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 050933-50935 NO

Daily Major Incident 

Photos- Scene/Body

ISP Forensics Report

YES ACB 051100 ACB 051105 NO N/A

194 HH-296357 2002 1 Jesus Munoz-Padilla NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 051188-51190 NO

Daily Major Incident

Photos- Scene/Body

Handwritten Notes 

Property Inventory

Felony Minutes- 101

YES ACB 051424 ACB 051440-447 NO N/A

195 HH-301377 2002 1 Jermaine Evans NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 030616-30617 NO Daily Major Incident Log Lost and Found Case Report NO N/A NO N/A196 HH-316330 2002 1 Victor Rivera NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB030795-30796 NO Photos, Photo Array, SOS Search, Leads 

Responses

YES

ACB 030987ACB 031052ACB 031054ACB 031055

NO N/A

197 HH-321998 2002 1 Michael Wordlow NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 031073 NO

Daily Major Incident Log

Photos- Scene/Body

Handwritten Note

Biz Cards

YES ACB 031140 ACB 031136 NO N/A

198 HH-347787 2002 1 Kendrick Jackson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 031210 NO

Daily Major Incident Log

Photos- Scene/Body

Written Statements

Handwritten Notes

GPRs

Supp. Report

YES ACB 031243 NO N/A

199 HH-358668 2002 1

James Mitchell

Marcel White

Christopher Peoples

Lawrence Harper

YES YES

ACB 031270-295; ACB 

031307-309; ACB 031311-322; ACB 

031325-40; 031342-82, 

031387-91, 031394-

397, 031399-453; ACB 

031455-489; 031491-

499, ACB, 031500-538; 

031539-55, 031383-86

NO N/A YES

*ACB 031329, *ACB 

031358-361, 

*ACB 031419-427,

* ACB 031429, *ACB 

031491-495, 

*ACB 031497, *ACB 

031500-511, 

*ACB 031513-517

YES

*ACB 031327, *ACB 

031330,

*ACB 031496, *ACB 

031499, *ACB 031512,

*ACB 031484 (on an 

investigative alert)

YES ACB 031294, ACB 031295 YES ACB 031307-309 NO

Photos – Scene/Body 

Daily Major Incident Log

IL Torture Inquiry Documents

Handwritten Notes 

YES

ACB 031330 ACB 031327ACB 031512

NO N/A

39 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 297 of 433 PageID #:15718
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

187 HH-257532 2002 1 Curtis Baldwin188 HH-263021 2002 1 Josheph Murchison Steven Brandon189 HH-270572 2002 1 Ernesto Flores Rogelio Guerra

190 HH-279592 2002 1 Ron Turner Jarmichael Williams

191 HH-280024 2002 1 Andrew Robinson192 HH-280696 2002 1 Willie Murray John Murray193 HH-285733 2002 1 DeShanta Young194 HH-296357 2002 1 Jesus Munoz-Padilla195 HH-301377 2002 1 Jermaine Evans196 HH-316330 2002 1 Victor Rivera197 HH-321998 2002 1 Michael Wordlow198 HH-347787 2002 1 Kendrick Jackson199 HH-358668 2002 1

James Mitchell

Marcel White

Christopher Peoples

Lawrence Harper

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

40 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 298 of 433 PageID #:15719
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

200 HH-361418 2002 1 Michael Smith NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 051605 NO

ISP Forensics Lab Report

Handwritten Note

Daily Major Incident Log

Photos- Scene/Body

Supp. Reports

GPRs

Photos- Person

Criminal History Reports

Written Statements 

Investigative Alerts

Arrest Report 

Subpoenas

YES ACB 051601 NO N/A

201 HH-367441 2002 1

Hananiah Dukes

Larry Williams

Damien Braboy

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 051831-51832 NO

Daily Major Incident Log

Photos- Scene/Body

Handwritten notes

YES ACB 051887 NO N/A

202 HH-367666 2002 1 Terrance Edwards NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 052085-52087 NO Daily Major Incident Log Photos- Scene/Body NO N/A NO N/A203 HH-377524 2002 1 el Lateef Mannie NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 052317 NO Daily Major Incident Log Photos- Scene/Body NO N/A NO N/A204 HH-414131 2002 1 Robert Paschall NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 052389-52390 NO

Moving of Arrestee 

Photos- Person

Supp. Report 

Daily Major Incident Log

YES ACB 052391-392 NO N/A

205 HH-447119 2002 1 Kevin Frazier NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 052580 NO

Supp. Report 

GPR

Photo- Scene/Body

NO N/A NO N/A

206 HH-447396 2002 1 Bernard Allen NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 052694-52695 NO

Handwritten Notes

GPRs (inventory has it listed but they left a 

space for # of GPRs)

Daily Major Incident Log 

Photos- Scene/Body

YES ACB 052770 ACB 052772 NO N/A

207 HH-500856 2002 4 James Hardy NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 052794-52797 NO

Photos- Tapes

GPRs

Body Diagram

NO N/A NO N/A

208 HH-505945 2002 1 Maurice McGee NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 053150 NO

Daily Major Incident Log

Photos- Person

Memo

NO N/A NO N/A

209 HH-522403 2002 1 Emil Lee NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 053307 NO

Handwritten Notes

Daily Major Incident Log

Photos- Scene

YES

ACB 053342ACB 053344 ACB 053346

NO N/A

210 HH-524796 2002 1 Marcus Cureton NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 053427-428 NO

Photos- Person

Photos- Scene/Body

Daily Major Incident Log

Non-Chicago Police Dept. Pages

NO N/A NO N/A

211 HH-525230 2002 1 Shonita Roach NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 053585 NO Daily Major Indicent Log GPR NO N/A NO N/A212 HH-529070 2002 1 Douglas Bowman Dwon Alexander NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 053654-53655 NO Photos- Scene/Body Daily Major Incident Log Photos- Scene/Body YES ACB 053785 NO N/A

213 HH-546846 2002 1

Antonio Fort

Robert Tucker

Roosevelt Lawrence

James Ousley

Lamont Motes

Ricky Lawson

Henry Lawrence

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 053789-53791; ACB 054195-197 NO

Photos Scene/Body

Photos Person

Handwritten Note

Form 101

 Property Inventory 10009628

 Handwritten Notes (2)

 Memo

 Major Crime Worksheet

 Daily Major Incident Report

YES

ACB 054228ACB 054277ACB 054354ACB 054389

NO N/A

214 HH-551686 2002 1 Romelle Jones NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 054570-54571 NO

Photos- Scene/Body

Daily Major Incident Log

Property Inventory

Handwritten Note

NO N/A NO N/A

215 HH-572150 2002 1 Rafel Baltazar Jesus Zaragoza NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 054664-54665 NO Photos- Scene/Body Handwritten Note YES ACB 054829 NO N/A

216 HH-576930 2002 1

Sedronio Alonso

Celestino Chavez

Urbano Perez

Juan Alverez

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 054934-54935 NO

Photos – Scene/Body

GPRs

Handwritten Notes

Daily Major Incident Log

YES ACB 055009 NO N/A

217 HH-609705 2002 1 Jose Luera Pierre Montanez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 055256 NO

Daily Major Incident Log

Arrestee History/ Mugshot

Leads Reports

Notice of Disclosure

Request for Non-Published Telephone 

Information

Felony Minute Sheet- Form 101

ID Card

Criminal History 

GPRs

Supp. Reports

NO N/A NO N/A

218 HH-614198 2002 1 Larry Monroe Otis Blackmun NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 055313-55315 NO

Biz Cards 

Handwritten notes

Daily Major Incident Log

Felony Minute Sheet –Form 101

YES ACB 055392 ACB 055426 NO N/A

219 HH-617694 2002 1 Ronald Funches NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 055500-55501 NO

Photos- Scene/Body

Handwritten Notes

To-From Memo

Daily Major Incident Log

YES

ACB 055499

ACB 055539-542ACB 055564-565

YES ACB 055497-498

41 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 299 of 433 PageID #:15720
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

200 HH-361418 2002 1 Michael Smith201 HH-367441 2002 1

Hananiah Dukes

Larry Williams

Damien Braboy

202 HH-367666 2002 1 Terrance Edwards203 HH-377524 2002 1 el Lateef Mannie204 HH-414131 2002 1 Robert Paschall205 HH-447119 2002 1 Kevin Frazier206 HH-447396 2002 1 Bernard Allen207 HH-500856 2002 4 James Hardy208 HH-505945 2002 1 Maurice McGee209 HH-522403 2002 1 Emil Lee210 HH-524796 2002 1 Marcus Cureton211 HH-525230 2002 1 Shonita Roach212 HH-529070 2002 1 Douglas Bowman Dwon Alexander

213 HH-546846 2002 1

Antonio Fort

Robert Tucker

Roosevelt Lawrence

James Ousley

Lamont Motes

Ricky Lawson

Henry Lawrence

214 HH-551686 2002 1 Romelle Jones215 HH-572150 2002 1 Rafel Baltazar Jesus Zaragoza

216 HH-576930 2002 1

Sedronio Alonso

Celestino Chavez

Urbano Perez

Juan Alverez

217 HH-609705 2002 1 Jose Luera Pierre Montanez

218 HH-614198 2002 1 Larry Monroe Otis Blackmun

219 HH-617694 2002 1 Ronald Funches

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

42 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 300 of 433 PageID #:15721
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

220 HH-618363 2002 1 Darkeith Travis NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 055649-55650 NO

Photos- Scene/Body

Handwritten Note

Daily Major Incident Log

YES ACB 055734 NO N/A

221 HH-635313 2002 1 Joseph Booker NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 056062-56063 NO

Photos- Scene/Body

Handwritten Note

Daily Major Incident Log

NO N/A NO N/A

222 HH-660094 2002 1 Janene Clay NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 056255 NO Daily Major Incident Log Photos- Scene/Body YES ACB 056344 NO N/A

223 HH-690739 2002 1 Scott Aramian NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 056385-56386 NO Daily Major Incident Log Photos- Scene/Body NO N/A NO N/A224 HH-749335 2002 1 Devon Terrell YES YES

ACB 056507-10; ACB 

056512-524; ACB 

056532, ACB 056546; 

ACB 056564; ACB 

056579-81; ACB 

056610; ACB 056616

NO N/A NO N/A YES

ACB056509, ACB056564, 

ACB056610

NO N/A YES ACB 056510 NO Handwritten notes Daily Major Incident Log YES ACB 056615 ACB 056610 ACB 056564-567 NO N/A

225 HH-767627 2002 1 Jaber Ahmad NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 056690-56691 NO

Photos-Scene/Body

Daily Major Incident Log

Repot of Postmortem Examination

NO N/A NO N/A

226 HH-783159 2002 UNK Neptali Perdomo NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 056878-56879 NO Photos- Scene/Body Supp. Report NO N/A NO N/A

227 HH-811146 2002 1 Antonio Richmond NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB057055-56056 NO

Handwritten Notes

Photos- Scene/Body

Daily Major Incident Log

YES ACB 057093 NO N/A

228 HH-818229 2002 1 Chrishun Dalton NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 057186 NO

Photos- Scene

Photos-Person

Daily Major Incident Log

Handwritten Note

Supp. Report

YES ACB 057269 NO N/A

229 HH-823907 2002 1 Jajuan Hale NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 057348-57350 NO Photos- Scene Handwritten Notes YES ACB 057435 NO N/A

230 HH-842054 2002 1 Xavier Edwards NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 057631-57632 NO Photos-Scene/Body School Schedule YES ACB 057638 NO N/A

231 HH-844492 2002 1 Gregory Minniefield NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 057865-57866 NO

Photos- Scene/Body

Timeline ASA Work Product

Daily Minute

YES ACB 057973 NO N/A

232 HH-858534 2002 1 Choice Enge Jerome Howard NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 058054-58056 YES N/A NO N/A NO N/A

233 HH-858682 2002 1 David Hernandez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 058339-58340 NO

Photos- Scene/Body

Handwritten Notes

Photos- Person

YES ACB 058408 NO N/A

234 HH-860642 2002 1 Shellie Pakula NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 058549-58550 NO

Photos- Scene/Body

Lab Report

Handwritten Note

YES ACB 058603 NO N/A

235 HH-860835 2002 1 James Freeman NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 089966-59969 NO

Supp. Report

Investigative Alert

FOIA Request

To-From Memos

YES

ACB 090016-017 

ACB 090155ACB 090211ACB 090260ACB 090261

ACB 090319-321ACB 090330-332

YES N/A

236 HJ-102484 2002 1 Anthony Houston Jimmie Walls YES NO N/A YES YES NO N/A NO N/A NO N/A YES ACB 031564-31566 NO

Invest. Alerts

Complaint for Prelim. Examination

Felony Minutes

Photos- Scene/Body

Warrant

Daily Major Incident Log

NO N/A NO N/A

237 HJ-117531 2003 A/1 Jane Ashby NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 031834 - 31835 NO 3 property inventory items on inventory, 0 in file YES ACB 031899 NO N/A

238 HJ-117559 2003 A/1

Onecimo Guereca

Jose Melgoza

Oscar Corral

Jose Nieves

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 032085 - 32086 NO 0 handwritten notes on inventory, 6 handwritten notes in file YES ACB 032083 ACB 032104 NO N/A

239 HJ-143625 2003 1 David Giocondi Sr NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 032237 - 32239 NO 3 Detective Notes on inventory, 11 handwritten notes in file YES

ACB 032436

ACB 032542 – 32544

ACB 032546 YES ACB 032379 - 32380

240 HJ-145451 2003 1 Charles Harper NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 032658 - 32659 NO

0 handwritten notes on inventory, 1 handwritten 

note in file

0 Request for Temporary Release of Inmate on 

inventory, 1 Request for Temporary Release of 

Inmate in file

YES ACB 032687 NO N/A

241 HJ-158056 2003 1 Gabriel Stephens Neysa Benning NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 032841 – 32842 NO

20 GPRS on inventory, 17 in the file 

0 handwritten notes on the inventory, 2 in the 

file

0 To-From Memos on the inventory, 6 in the 

file

YES

ACB 032866ACB 032880ACB 032882 YES ACB 032829 - 32835

242 HJ-169496 2003 1 Bee Pittman NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 032986 - 32987 NO

0 handwritten notes on inventory, 5 in file. 

File indicated “problem loading this page” for 

pages 184-205 in pdf

YES

ACB 033035ACB 033047ACB 033097ACB 033103ACB 033111

NO N/A

243 HJ-211373 2003 1 Telvin Shaw NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 033216 - 33217 NO 0 handwritten notes on inventory, 3 handwritten notes in file YES

ACB 033339ACB 033341

ACB 033354 - 33355 NO N/A

43 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 301 of 433 PageID #:15722
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

220 HH-618363 2002 1 Darkeith Travis221 HH-635313 2002 1 Joseph Booker222 HH-660094 2002 1 Janene Clay223 HH-690739 2002 1 Scott Aramian224 HH-749335 2002 1 Devon Terrell225 HH-767627 2002 1 Jaber Ahmad226 HH-783159 2002 UNK Neptali Perdomo227 HH-811146 2002 1 Antonio Richmond228 HH-818229 2002 1 Chrishun Dalton229 HH-823907 2002 1 Jajuan Hale230 HH-842054 2002 1 Xavier Edwards231 HH-844492 2002 1 Gregory Minniefield232 HH-858534 2002 1 Choice Enge Jerome Howard233 HH-858682 2002 1 David Hernandez234 HH-860642 2002 1 Shellie Pakula235 HH-860835 2002 1 James Freeman236 HJ-102484 2002 1 Anthony Houston Jimmie Walls237 HJ-117531 2003 A/1 Jane Ashby238 HJ-117559 2003 A/1

Onecimo Guereca

Jose Melgoza

Oscar Corral

Jose Nieves

239 HJ-143625 2003 1 David Giocondi Sr240 HJ-145451 2003 1 Charles Harper241 HJ-158056 2003 1 Gabriel Stephens Neysa Benning242 HJ-169496 2003 1 Bee Pittman243 HJ-211373 2003 1 Telvin Shaw

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

44 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 302 of 433 PageID #:15723
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

244 HJ-211691 2003 1 Frederick Smith NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 033423 NO 19 GPRs on inventory, 8 in the file YES

ACB 033339ACB 033341

ACB 033354 - 33355 NO N/A

245 HJ-228346 2003 1

Antonio Shaw

Anthony Mitchell

John Fulton

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 033496 – 33497 NO 0 To-From Memos on inventory, 4 in the file 0 Handwritten Notes on inventory, 2 in file YES ACB 033604 - 33605 NO N/A

246 HJ-239255 2003 1 Dominique Johnson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 033664 – 33665 NO 0 Daily Major Incident Logs on inventory, 2 in file YES ACB 033604 - 33605 NO N/A

247 HJ-243231 2003 1 Lee Murphy NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 033834 – 33837 NO 126 GPRs on inventory, 119 in file YES

ACB 033920ACB 033926

ACB 033978 – 33979

ACB 034007

ACB 034170 – 34172

ACB 034189

YES ACB 034082

248 HJ-256409 2003 1 Cedric House NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 058690 – 58691 NO

24 GPRs listed on inventory, 22 in file (unless 

two pages of handwritten notes in between the 

GPRs are counted as GPRs) 

0 Handwritten notes on inventory, 2 in file

9 Supplementary Reports listed on inventory, 11 

in file

YES

ACB 058757ACB 058759 NO N/A

249 HJ-257094 2003 1 Charnell Woods Otha Woods NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 058955 - 58956 NO 0 Handwritten Notes on inventory, 4 in file YES

ACB 059078ACB 059093ACB 059095 NO N/A

250 HJ-274500 2003 4 Roger Padilla NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 059154 – 59155 NO 14 Handwritten Notes in inventory, 1 in file YES ACB 059162 NO N/A

251 HJ-284434 2003 1

Donnell Bolden

Christopher Bates

Darryl Grayson

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 059422 - 59424 NO 0 Handwritten Notes in inventory, 2 in file YES ACB 059488 NO N/A

252 HJ-307187 2003 1

Jessie Williams

Perry HigginsEric Williams

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 059670 – 59671 NO

34 GPRs on inventory, 33 in file (final page 

with set of GPRs is a handwritten note; 

inventory may have added handwritten note as 

a GPR. If so, 34 GPRs, if not 33 GPRs)

0 Handwritten notes on inventory, 1 in file (see 

assumption in first bullet point)

0 Daily Major Incident Logs on inventory, 1 in 

file

YES ACB 059726 NO N/A

253 HJ-307851 2003 1 Michael Warfield NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 059861 - 59862 NO 0 Handwritten Note on inventory, 1 in file 3 property inventory on inventory, 1 in file YES ACB 059893 NO N/A

254 HJ-310383 2003 1 Lessie Shields NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 059984 - 59985 NO 0 To-From Memos on inventory, 2 in file NO N/A YES ACB 059998 - 59999

255 HJ-320635 2003 1 Anthony Pitchford NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 060122 - 60123 NO

22 GPRs on inventory, 19 in file (final 3 pages 

with the set of GPRs is a handwritten note; 

inventory may have added handwritten note as 

a GPR. If so, 22 GPRs, if not 19 GPRs)

0 Handwritten notes on inventory, 3 in file (see 

assumption in first bullet point)

0 Daily Major Incident Log on inventory, 1 in 

file

YES

ACB 060199 – 60201

ACB 060226 NO N/A

256 HJ-324514 2003 1

Cleodis Bassett

George Anderson

Leon Brown

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 060323 – 60325 NO 0 To-From Memos on inventory, 3 in file 0 Handwritten notes on inventory, 13 in file Yes

ACB 060322

ACB 060361 – 60362

ACB 060366

ACB 060387 – 60389ACB 060394 – 60395

ACB 060396ACB 060420ACB 060422

YES ACB 060317 - 60321

257 HJ-366143 2003 1 Leivante Adams YES YES

ACB 060615-64; ACB 

060702; ACB 060720-

723; ACB 060733-738; 

ACB 060764-65; ACB 

060803-832

NO N/A NO N/A YES

*ACB 060702*ACB 060764

-765

NO N/A YES ACB 060323 - 60325 NO 0 Handwritten notes on inventory, 5 in file YES

ACB 060702

ACB 060726 – 60728

ACB 060764ACB 060802

NO N/A

258 HJ-376892 2003 1 Dexter Bailey Samuel Frieson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 080830 – 80831 NO 0 Daily Major Incident Log on inventory, 1 in file 0 Handwritten notes on inventory, 8 in file YES ACB 080980 NO N/A259 HJ-399272 2003 1 Eddie Mosley NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 081026 – 81027 YES N/A YES ACB 081116 NO N/A

260 HJ-400029 2003 1 Larry Gilbert NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 081245 - 81248 NO

6 property inventory reports on inventory, 2 in 

file 

55 GPRs on inventory, 54 in file (final page 

with the set of GPRs is a handwritten note; 

inventory may have added handwritten note as 

a GPR. If so, 55 GPRs, if not 54 GPRs)

0 Handwritten notes on inventory, 31 in file 

(see assumption in previous bullet point)

YES ACB 081293 NO N/A

261 HJ-410134 2003 1 Jian Tan NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 081531 – 81532 NO

0 Daily Major Incident Log on inventory, 1 in 

file

0 Photographs on inventory, 118 in file

NO N/A NO N/A

262 HJ-440488 2003 1 Frank Quiroz Lazaro Zapata NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 081777 – 81778 NO 0 Major Incident Report Log on inventory, 1 in file 0 Scene photos on inventory, 55 in file YES ACB 081822 NO N/A

263 HJ-492443 2003 1

Natalio Ramirez

Daniel Aguirre

Octavia Anima

Jesus SanchezMiguel Nunez

Pablo Aguilar

YES YES

ACB 081968; ACB 

081991-92; ACB 

081993-996; ACB 

082052; ACB 082173-

277

YES YES NO N/A YES ACB 082052 YES ACB 081991 YES ACB 081997-001 NO

FOIA Request 

Supp. Report 

Photos- Person

Daily Major Incident Log

Handwritten Notes 

No N/A YES 82492

45 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 303 of 433 PageID #:15724
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

244 HJ-211691 2003 1 Frederick Smith245 HJ-228346 2003 1

Antonio Shaw

Anthony Mitchell

John Fulton

246 HJ-239255 2003 1 Dominique Johnson247 HJ-243231 2003 1 Lee Murphy248 HJ-256409 2003 1 Cedric House249 HJ-257094 2003 1 Charnell Woods Otha Woods

250 HJ-274500 2003 4 Roger Padilla251 HJ-284434 2003 1

Donnell Bolden

Christopher Bates

Darryl Grayson

252 HJ-307187 2003 1

Jessie Williams

Perry HigginsEric Williams

253 HJ-307851 2003 1 Michael Warfield254 HJ-310383 2003 1 Lessie Shields255 HJ-320635 2003 1 Anthony Pitchford256 HJ-324514 2003 1

Cleodis Bassett

George Anderson

Leon Brown

257 HJ-366143 2003 1 Leivante Adams258 HJ-376892 2003 1 Dexter Bailey Samuel Frieson

259 HJ-399272 2003 1 Eddie Mosley260 HJ-400029 2003 1 Larry Gilbert261 HJ-410134 2003 1 Jian Tan262 HJ-440488 2003 1 Frank Quiroz Lazaro Zapata

263 HJ-492443 2003 1

Natalio Ramirez

Daniel Aguirre

Octavia Anima

Jesus SanchezMiguel Nunez

Pablo Aguilar

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

46 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 304 of 433 PageID #:15725
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

264 HJ-499310 2003 4 Randy Allen Derrick Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 082421 – 82424 NO 52 pages of Handwritten Notes on inventory, 49 pages in file NO N/A YES ACB 082492

265 HJ-505759 2003 1 Mark Scott NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 082701 - 82702 NO 0 Crime Scene Photos on inventory, 63 in file YES

ACB 082698ACB 082748

ACB 082757 - 82758 NO N/A

266 HJ-518923 2003 1 James Wheeler NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 082874 - 82875 NO 0 Crime Scene Photos on inventory, 29 in file NO N/A NO N/A

267 HJ-527506 2003 1

Edwin Harris

Milton Love

Goran Kotur

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 083016 – 83017 NO 0 Handwritten Notes on inventory, 1 in file 0 Daily Major Incident Log, 1 in file YES ACB 083102 NO N/A

268 HJ-545448 2003 1

Antonio Thomas

Toney Cole

Timothy Fulton

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 083209 – 83211 NO

45 GPRs on inventory, 44 in file

0 handwritten notes on inventory, 3 in file

0 photos on inventory, 8 in file

YES

ACB 083284ACB 083303ACB 083385 NO N/A

269 HJ-547936 2003 1 Edward Maholmes NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 083482 – 83483 NO

32 GPRs on inventory, 29 in file

0 handwritten notes on inventory, 3 in file

0 Daily Major Incident Log on inventory, 1 in 

file

YES ACB 083538 - 83540 YES ACB 083616

270 HJ-591782 2003 1 Gregory Carr Frederick Bagley NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 083646 - 83650 NO

39 GPRs on inventory, 38 in file

0 Handwritten notes on inventory, 1 in file

0 Daily Major Incident Log on inventory, 1 in 

file

YES ACB 083808 NO N/A

271 HJ-623228 2003 1 Jose Echevarria NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 084079 - 84080 NO 29 GPRs on inventory, 28 in file 0 Handwritten Notes on inventory, 2 in file YES ACB 084093 ACB 084122 - 84123 NO N/A

272 HJ-640575 2003 1 Sergio Tzintzun NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 084207 - 84208 NO

28 GPRs on inventory, 17 in file

0 Handwritten Notes on inventory, 12 in file 

0 Daily Major Inventory File 0n inventory, 0 in 

inventory

YES

ACB 084272

ACB 084276 – 84278

ACB 084284ACB 084286

ACB 084288 – 84290ACB 084292 – 84294

ACB 084296ACB 084301

NO N/A

273 HJ-647205 2003 1 Arthur Foote Derrick Hatchett NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 084408 - 84410 NO

53 GPRs on inventory, 52 in file

0 Handwritten Notes on inventory, 1 in file 

0 Daily Major inventory File 0n inventory, 0 in 

inventory 

0 To-From Memos on inventory, 1 in file

YES ACB 084539 YES

ACB 084406 – 

84407

ACB 084593ACB 084616ACB 084621

274 HJ-661717 2003 1 Sandra Stowers NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 034312 - 34313 NO 0 Daily Major Incident Log on inventory, 1 in file NO N/A NO N/A

275 HJ-664136 2003 1 Johnny Moore NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 034397 - 34398 NO

0 Handwritten Notes on inventory, 2 in file 

0 Daily Major Incident Log on inventory, 1 in 

file

YES

ACB 034444ACB 034472 NO N/A

276 HJ-664232 2003 1 Anthony Jackson Clayton Sims NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 084757 - 84758 NO 51 GPRs on inventory, 49 in file 0 Handwritten Notes on inventory, 4 in file 0 Daily Major Log on inventory, 1 in file YES ACB 084890 – 84891 ACB 084893 ACB 084918 YES ACB 084752 - 84754

277 HJ-671123 2003 UNK Timothy Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A NO N/A NO N/A

278 HJ-673789 2003 1 Markeith Jenkins NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 060904 NO 19 GPRs on inventory, 29 in file 0 To-From Memos on inventory, 2 in file YES ACB 060997 YES ACB 060902 - 60903

279 HJ-676387 2003 1 Albert Domagala NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 084982 - 84983 NO 0 Handwritten Notes on inventory, 2 in file YES ACB 085017 - 85018 NO N/A

280 HJ-678090 2003 1 Dante Brown Dwight Allen NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 085061 - 85063 NO 47 GPRs on inventory, 41 in file 0 Handwritten Notes on inventory, 8 in file 0 Daily Major Log on inventory, 1 in file YES

ACB 085109 - 85112

ACB 085114ACB 085116ACB 085209

YES

ACB 085052ACB 085162ACB 085164

281 HJ-687964 2003 1 Gena O'Shaughnessy James Gusich NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 085305 - 85307 NO 0 Handwritten Notes on inventory, 2 in file YES ACB 085407 ACB 085516 NO N/A

282 HJ-689560 2003 1 Charles Rice NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 085621 - 85622 YES N/A NO N/A NO N/A283 HJ-733462 2003 1 Rosendo Ruiz Lazarro Guitierrez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 085729 NO

0 Daily Major Incident Log on inventory, 1 in 

file

9 Cook County Sheriff’s Incident Reports on 

inventory, 1 in file

YES

ACB 085727ACB 085844 NO N/A

284 HJ-734895 2003 1 Keidrick Gray NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 085884 NO

0 Daily Major Incident Log on inventory, 1 in 

file

0 Crime Scene Photos on inventory, 27 in file

NO N/A NO N/A

285 HJ-737306 2003 1

Israel Ramirez

Jose L Gonzalez

Salvador Contreras

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 086049 - 86052 NO 42 GPRs on inventory, 41 in file 0 Handwritten Notes on inventory, 8 in file YES

ACB 086086ACB 086089

ACB 086091 – 86092

ACB 086099ACB 086106ACB 086123ACB 086157ACB 086160ACB 086268

NO N/A

286 HJ-745468 2003 1 Valerie Padin Joseph Martinez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 086408 - 86409 NO 47 GPRs on inventory, 32 in file 0 Handwritten Notes on inventory, 8 in file YES ACB 086451 ACB 086544 - 86549 NO N/A

287 HJ-757826 2003 4 Mahendra Anderson Micah Anderson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 034571 - 34572 NO 33 GPRs on inventory, 32 in file 0 Handwritten Notes on inventory, 1 in file YES ACB 034617 ACB 034625 NO N/A

47 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 305 of 433 PageID #:15726
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

264 HJ-499310 2003 4 Randy Allen Derrick Thomas265 HJ-505759 2003 1 Mark Scott266 HJ-518923 2003 1 James Wheeler267 HJ-527506 2003 1

Edwin Harris

Milton Love

Goran Kotur

268 HJ-545448 2003 1

Antonio Thomas

Toney Cole

Timothy Fulton

269 HJ-547936 2003 1 Edward Maholmes270 HJ-591782 2003 1 Gregory Carr Frederick Bagley

271 HJ-623228 2003 1 Jose Echevarria272 HJ-640575 2003 1 Sergio Tzintzun273 HJ-647205 2003 1 Arthur Foote Derrick Hatchett

274 HJ-661717 2003 1 Sandra Stowers275 HJ-664136 2003 1 Johnny Moore276 HJ-664232 2003 1 Anthony Jackson Clayton Sims277 HJ-671123 2003 UNK Timothy Thomas278 HJ-673789 2003 1 Markeith Jenkins279 HJ-676387 2003 1 Albert Domagala280 HJ-678090 2003 1 Dante Brown Dwight Allen

281 HJ-687964 2003 1 Gena O'Shaughnessy James Gusich282 HJ-689560 2003 1 Charles Rice283 HJ-733462 2003 1 Rosendo Ruiz Lazarro Guitierrez

284 HJ-734895 2003 1 Keidrick Gray285 HJ-737306 2003 1

Israel Ramirez

Jose L Gonzalez

Salvador Contreras

286 HJ-745468 2003 1 Valerie Padin Joseph Martinez

287 HJ-757826 2003 4 Mahendra Anderson Micah Anderson

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

48 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 306 of 433 PageID #:15727
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

288 HJ-776575 2003 1 Lamont Douglas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 061092-61093 NO 49 GPRs on inventory, 38 in file 0 Handwritten Notes on inventory, 4 in file YES

ACB 061157ACB 061162ACB 061238ACB 061241

YES ACB 061119

289 HJ-793204 2003 1 Darren Johnson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 061327 - 61328 NO 0 Daily Major Incident Logs on inventory, 1 in file NO N/A NO N/A

290 HJ-795462 2003 1 Michael Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 061496 NO 0 Daily Major Incident Log on inventory, 1 in file NO N/A NO N/A

291 HJ-796729 2003 1 Juan Boone NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 061663 - 61665 NO

44 GPRs on inventory, 43 in file

0 Handwritten Notes on inventory, 2 in file 

14 inventory reports on inventory, 3 in file 

0 Daily Major Incident Logs on inventory, 1 in 

file

YES

ACB 061790ACB 061799 YES ACB 061736

292 HJ-831700 2003 1 Santiago Torres NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 061876 - 61878 NO 0 Handwritten Notes on inventory, 3 in file YES

ACB 061993ACB 062022ACB 062025 NO N/A

293 HJ-834810 2003 2 Mickey Mason Renwick Wells NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 034751 - 34752 NO 0 Handwritten Notes on inventory, 2 in file 0 Clear Data Warehouse Arrestee History on inventory, 1 in file YES ACB 034786 ACB 034804 NO N/A

294 HJ-845688 2003 4 David Washington Kenya Henry NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 034920 - 34921 NO

0 Handwritten Notes on inventory, 1 in file 

0 Detective Division Progress Report on 

inventory, 1 in file

0 Investigative Alerts on inventory, 1 in file

0 Major Crime Scene Report on Inventory, 1 in 

file

YES ACB 034961 NO N/A

295 HK-000106 2004 1 Daniel Bowen Dennis McArdle NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 037325-37326 NO Handwritten notes (37370, 37387, 37463, 37483, 37490) YES ACB 037383, ACB 037386- 37387, ACB 037483, ACB 037490, ACB 037513 NO N/A

296 HK-106793 2004 1

Phillip Hartsfield

Mohammed 

Abukhdeir

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 035124-35125 NO Copy of Receipt & handwritten notes (35169) Handwritten note (35226) YES

ACB 035169, ACB 035194-

35196, ACB 035217-35218, 

ACB 035226-35227, ACB 

035235-35236

NO N/A

297 HK-142414 2004 1 Anthony Evans NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 035272-25273 NO Inv. File Control (35267) Daily Major Incident Log (35268-35270) NO N/A NO N/A

298 HK-148852 2004 1 Steven Myers Timothy Brewer NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 035439-35440 NO Inv. File Control (35437) Daily Major Incident Log (35438) YES ACB 035488-35489, ACB 035567 YES ACB 035531-35532

299 HK-158502 2004 1 Oliver Crawford NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 037577-37580 NO 2 Handwritten notes in file, 0 listed on Inventory (37744; 37867) YES

ACB 037744, ACB 037759-

37760, ACB 037788, ACB 

037815-37816, ACB 

037819, ACB 037827, ACB 

037840, ACB 037848

NO N/A

300 HK-165467 2004 1 Dominique Dennis NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 035622-35625 NO 1 Handwritten note in file, 0 listed on Inventory (35681) YES

ACB 035681, ACB 035701, ACB 035703, ACB 035708, ACB 035810, ACB 035815, 

ACB 035819 - 35820, ACB 

035824, ACB 035825, ACB 035828, ACB 035883, ACB 

035885, ACB 035898-35904

NO N/A

301 HK-195199 2004 1 Morris Hawkins NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 037911-37912 NO 2 To-from memos in file, 0 listed on Inventory NO N/A NO N/A

302 HK-196935 2004 1 Juvenal Reyes NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 038094 NO Inv. File Control (38089) Daily Major Incident Log (38090-38093) NO N/A NO N/A

303 HK-211174 2004 1

Navon Foster

Laquita Calhoun

Katherine Calhoun

Terence Jones

Lakesha Collins

Jeanette Daniels

YES YES

ACB 038165; ACB 

038166-167; ACB 038171-175; ACB 038177-188; ACB 

038189; ACB 038202-

214; ACB 038216-217; 

ACB 038219; ACB 

038232; ACB 038265-

86

NO N/A YES

ACB038202-214, 

ACB038189, 

ACB038177-188

YES ACB038298 YES ACB038219 YES ACB 038166-38167 YES N/A Yes

38376, 38457-38459, 38487, 

38490-38491, 38541-38542, 

38549-38552, 38554

No n/a

304 HK-222787 2004 1 Jerry Cooks NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 038356-38359 NO 3 Handwritten notes in file, 0 listed on Inventory (38490; 38541; 38554) YES

ACB 038376, ACB 038457-

38459, ACB 038487, ACB 

038490-38491, ACB 038541-

38542, ACB 038549-38552, 

ACB 038554

NO N/A

305 HK-223040 2004 1 Dennis Edwards NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 038611-38612 NO Major Crime Scene Reports (38701-38704) YES ACB 038672-38674 NO N/A306 HK-224777 2004 1 Juan Pena NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 038795-38796 NO Inv. File Control (38738) Daily Major Incident Log (38778-38780) NO N/A NO N/A

307 HK-238041 2004 1 Glenn Miles NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 038917-38918 NO 3 Handwritten notes in file, 0 listed on Inventory (38961; 39011; 39012) YES ACB 038961, ACB 039011- 39012 NO N/A

308 HK-238478 2004 1 Tythia Thigpen Jamal White NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 039174-39175 NO Inv. File Control (39099) Request for Evidence ID Photos (39167) YES ACB 039172-39173, ACB 039233 NO N/A

309 HK-245772 2004 1 Thomas Flowers NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 039445-39446 NO 1 To-from memo in file, 0 listed on Inventory (39444) NO N/A YES ACB 039444

310 HK-253794 2004 1 Malvin Washington NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 039599-39601 NO Inv. File Control (39596) Major Crime Scene Reports (39752-39755) YES ACB 039605, ACB 039637 NO N/A

311 HK-284640 2004 1 Lamont Griffin NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 035980 NO Inv. File Control (35976) ISP Submission (35986) NO N/A NO N/A

312 HK-316879 2004 1 Sergio Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 039886-39887 NO Crime Scene Photos (39799-39884) Inv. File Control (39885) NO N/A NO N/A313 HK-359543 2004 1 Dorial Valentine NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 039989-39990 NO Inv. File Control (39987) Daily Major Incident Log (39988) NO N/A YES ACB 039991-39992

314 HK-377605 2004 1 Marcelo Gonzaga Elijah Santiago NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 040236-40240 NO 10 To-from memos in file, 0 listed on Inventory (40177-40188) YES ACB 040247, ACB 040395 YES ACB 040177-40188

315 HK-378604 2005 1 Ronnie Carpenter NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 040578; ACB 040582; ACB 040587; ACB 040601; ACB 040612 NO Homicide Case Folder Table of Contents Photos- Scene/Body Major Incident Notification Detail NO N/A NO N/A

49 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 307 of 433 PageID #:15728
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

288 HJ-776575 2003 1 Lamont Douglas289 HJ-793204 2003 1 Darren Johnson290 HJ-795462 2003 1 Michael Williams291 HJ-796729 2003 1 Juan Boone292 HJ-831700 2003 1 Santiago Torres293 HJ-834810 2003 2 Mickey Mason Renwick Wells294 HJ-845688 2003 4 David Washington Kenya Henry295 HK-000106 2004 1 Daniel Bowen Dennis McArdle296 HK-106793 2004 1

Phillip Hartsfield

Mohammed 

Abukhdeir

297 HK-142414 2004 1 Anthony Evans298 HK-148852 2004 1 Steven Myers Timothy Brewer299 HK-158502 2004 1 Oliver Crawford300 HK-165467 2004 1 Dominique Dennis301 HK-195199 2004 1 Morris Hawkins302 HK-196935 2004 1 Juvenal Reyes303 HK-211174 2004 1

Navon Foster

Laquita Calhoun

Katherine Calhoun

Terence Jones

Lakesha Collins

Jeanette Daniels

304 HK-222787 2004 1 Jerry Cooks305 HK-223040 2004 1 Dennis Edwards306 HK-224777 2004 1 Juan Pena307 HK-238041 2004 1 Glenn Miles308 HK-238478 2004 1 Tythia Thigpen Jamal White309 HK-245772 2004 1 Thomas Flowers310 HK-253794 2004 1 Malvin Washington311 HK-284640 2004 1 Lamont Griffin312 HK-316879 2004 1 Sergio Williams313 HK-359543 2004 1 Dorial Valentine314 HK-377605 2004 1 Marcelo Gonzaga Elijah Santiago315 HK-378604 2005 1 Ronnie Carpenter

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

50 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 308 of 433 PageID #:15729
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

316 HK-404487 2004 1 RL Brooks NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 040746-40747 NO

Daily Major Incident Log (40742-40745)

1 To-from memo in file, 0 listed on Inventory 

(40815)

NO N/A NO N/A

317 HK406407 2004 1 Delvie Turpin YES YES

ACB 040847-900; ACB 

040905; ACB 040910; 

ACB 040918; ACB 

040923; ACB 040928-

930; ACB 040956; 

ACB 040962-968; ACB 

040992-016; ACB 041017-034; ACB 

041036; ACB 041038; 

ACB 041040; ACB 

041042-49

NO N/A YES *ACB 040992-005 *ACB 041033 YES ACB 041032 NO N/A YES ACB 040886-887 NO Handwritten Note Photos – Scene/Body Daily Major Incident Log YES ACB 041032 NO N/A

318 HK416661 2004 1 Donnell Johnson YES YES

ACB 041052; ACB 

041055-98; ACB 

041106; ACB 0411099-

100; ACB 041140; 

ACB 041188; ACB 

041237-44

NO N/A NO N/A YES ACB041140, ACB051188 YES ACB041237-244 YES ACB 041099-041100 NO

To-From Memos

Major Incident Notification Detail NO N/A YES ACB 041237-244

319 HK431410 2004 1 William Hull NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 041283-41284 NO

 7 Handwritten notes in file, 0 listed on 

Inventory (41367, 41370-41372, 41374, 41380, 

41403)

YES

ACB 041367, ACB 041370-

41372, ACB 041374, ACB 

041380

YES ACB 041285

320 HK440539 2004 1 Tyrone Gill NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 041573-41575 NO Handwritten note (41746) YES ACB 041690, ACB 041746 NO N/A321 HK-449083 2004 1

Jamell Murphy 

Melvin Williams

Noah Wilson

YES YES

ACB 041773-74; ACB 

042002; ACB 041755; 

ACB 041924; ACB 

041883-88; ACB 

041876- ACB 041881; 

ACB 041882; ACB 

041777

NO N/A YES *ACB 041777 NO N/A NO N/A YES ACB 041773-41774 NO Inv. File Control (41755) Daily Major Incident Log (41767-41771) YES ACB 041857 NO N/A

322 HK-457513 2004 1 Juan Rodriguez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 042029-42031 NO Handwritten note (42082) NO N/A NO N/A323 HK-457942 2004 1 Vincent Hudson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 062065-62066 NO Inv. File Control (62062) Daily Major Incident Log (62063-62064) NO N/A NO N/A324 HK-459545 2004 1 Somailla Green NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 062212 NO Inv. File Control (62188) Daily Major Incident Log (62209-62211) NO N/A NO N/A325 HK-465885 2004 1 Cuahtemoc Padilla NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 062345 NO Handwritten note (62373) YES ACB 062373 NO N/A326 HK-470751 2004 1 Verna Colbert YES YES

ACB 062434; ACB 

062436; ACB 062437; 

ACB 062438; ACB 

062439-40; ACB 062441-43; ACB 062444-45; ACB 

062446; ACB 062447-

49; ACB 062450; ACB 

062451; ACB 062563-

64; ACB 062572; ACB 

062598; ACB 062639

NO N/A NO N/A YES ACB 062437 YES ACB 062438, ACB 062446 YES ACB 062441-443 NO

Photos – Scene/Body

Daily Major Incident Log

To-from Memo 

Subpoena – Defense 

NO N/A YES ACB 062436

327 HK-479167 2004 1

William Smith James Massey

Deandre Greer

Samuel Dupree

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 062696-62697, ACB 062700 NO Handwritten notes (62987, 63003) YES ACB 063003 NO N/A

328 HK-483176 2004 1

Arthur Dent

Romelle Coleman

Ashley Miller

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 063058-63059 NO

To-from memos (63054, 63055, 63057)

Handwritten notes (63126-63131, 63170, 63213-

63215)

YES ACB 063126-63131, ACB 063213-63215 YES ACB 063054-63057

329 HK-487688 2004 1 Daniel Bradford NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 036059-36060 NO Inv. File Control (36054) Daily Major Incident Log (36055-36058) NO N/A NO N/A330 HK-500451 2004 1 Tenaro Williams Virgil Daniel NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 036186-36187 NO 27 GPRs in file, 26 listed on Inventory NO N/A NO N/A

331 HK-526394 2004 1 Sheena Rucker NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 036407-36410 NO Handwritten note (36556, 36721) To-from memo (36675) YES ACB 036721 NO N/A

332 HK-526818 2004 1 Juan Munoz NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 036905 NO Handwritten note (36965, 36971, 36980, 36986, 36997, 37015) YES ACB 036965, ACB 036971, ACB 036980, ACB 036986, ACB 036997, ACB 037017 NO N/A

333 HK-528598 2004 1 Anthony Burns NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 037029-37030 NO Inv. File Control (37028) Request for Evidence ID Photos (37027) NO N/A NO N/A

334 HK-539094 2004 1 Antoine Ford NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 037208-37209 NO Handwritten note (37247) YES ACB 037247 NO N/A335 HK-558373 2004 1 Brandyn Anderson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 063253-63254 NO Handwritten note (63274) To-from memo (63275) YES ACB 063274, ACB 063284 YES ACB 063275, ACB 063324-63326

336 HK-564062 2004 1 Troy Frieson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 063406-63407 NO Property Inv. No. 10422889 (63560) NO N/A NO N/A337 HK-564454 2004 1

Kimothy Randall

Russell Armfield

Tyrene Nelson

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 063622-63624 NO To-from memo (63625) Handwritten note (63665) YES ACB 063665 YES ACB 063625, ACB 063678

338 HK-593970 2004 1 Tharine Partee YES YES ACB 063941-942; ACB 063944-945 NO N/A YES ACB064104 NO N/A NO N/A YES ACB 063944-63945 No Handwritten Note Daily Major Incident Log YES ACB 064103 NO N/A339 HK-598867 2004 1 Elliot Herron Joe Cobbins NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 064220-64224 NO Handwritten notes (64289, 64291, 64311) YES ACB 064289, ACB 064311 NO N/A

340 HK-628944 2004 1 Rayvonne Wilson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 064691-64692 NO To-from memos (64682-64690) NO N/A YES ACB 064682-64690

51 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 309 of 433 PageID #:15730
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

316 HK-404487 2004 1 RL Brooks317 HK406407 2004 1 Delvie Turpin318 HK416661 2004 1 Donnell Johnson319 HK431410 2004 1 William Hull320 HK440539 2004 1 Tyrone Gill321 HK-449083 2004 1

Jamell Murphy 

Melvin Williams

Noah Wilson

322 HK-457513 2004 1 Juan Rodriguez323 HK-457942 2004 1 Vincent Hudson324 HK-459545 2004 1 Somailla Green325 HK-465885 2004 1 Cuahtemoc Padilla326 HK-470751 2004 1 Verna Colbert327 HK-479167 2004 1

William Smith James Massey

Deandre Greer

Samuel Dupree

328 HK-483176 2004 1

Arthur Dent

Romelle Coleman

Ashley Miller

329 HK-487688 2004 1 Daniel Bradford330 HK-500451 2004 1 Tenaro Williams Virgil Daniel331 HK-526394 2004 1 Sheena Rucker332 HK-526818 2004 1 Juan Munoz333 HK-528598 2004 1 Anthony Burns334 HK-539094 2004 1 Antoine Ford335 HK-558373 2004 1 Brandyn Anderson336 HK-564062 2004 1 Troy Frieson337 HK-564454 2004 1

Kimothy Randall

Russell Armfield

Tyrene Nelson

338 HK-593970 2004 1 Tharine Partee339 HK-598867 2004 1 Elliot Herron Joe Cobbins340 HK-628944 2004 1 Rayvonne Wilson

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

52 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 310 of 433 PageID #:15731
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

341 HK-639684 2004 1

Christopher Walton

Michael Walton

Devon Terrell

YES YES

ACB 064841; ACB 

064932-937; ACB 064941-948; ACB 064952-958; ACB 064959-961; ACB 

064962; ACB 064980-

982; ACB 064983-84; 

ACB 064985-987; ACB 

065007; ACB 065077; 

ACB 065080-081; ACB 

065082-585; ACB 065086-087; ACB 

065093; ACB 065094

NO N/A NO N/A NO N/A YES ACB064980-982 YES ACB 064980-64982 NO

Original Case Incident Report 

Major Incident Notification Detail

Court Complaint

Photos – Scene/Body 

NO N/A NO N/A

342 HK-647145 2004 1 Markiesha Wells NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 065193 NO Inv. File Control (65191) Daily Major Incident Log (65192) NO N/A NO N/A

343 HK-663121 2004 1 Antoine Burton NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 065334-65335 NO Handwritten note (65424) YES ACB 065361, ACB 065424 NO N/A

344 HK-669797 2004 1 Morrell Steele Larry Steele NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 065515-65516 NO Inv. File Control (65511) Daily Major Incident Log (65512-65514) NO N/A NO N/A345 HK-683108 2004 1 Robert Curry NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 065645-65646 NO 25 GPRs in file, 24 listed on Inventory NO N/A NO N/A

346 HK-701076 2004 1 Harold Ivey NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 065848-65850 NO Handwritten note (65889) YES ACB 065889, ACB 065893, ACB 065994 NO N/A

347 HK-746784 2004 1 Andrew Binion NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 066139-66141 NO Inv. File Control (66137) Daily Major Incident Log (66138) NO N/A NO N/A

348 HK-763869 2004 1 Anthony Riley NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 066356-66358 NO Inv. File Control (66353) Daily Major Incident Log (66354-66355) YES ACB 066465 NO N/A

349 HK-776079 2004 1 Shevona Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 066683-66684 NO Handwritten note (66713) To-from memo (66814) YES ACB 066712-66713, ACB 066774 NO N/A

350 HK-788723 2004 1

Juan Delatorre

Steven NevarezAlejandro Mota

Jerry Rebeles

Antonio Rincon

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 067024-67027 NO To-from memos (67022-67023) Handwritten note (67176, 67245) YES ACB 067176, ACB 067245 YES ACB 067022-67023

351 HK-792194 2004 1 Iesha Walker NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 067461-67462 NO Inv. File Control (67587) Daily Major Incident Log (67610) NO N/A NO N/A

352 HK-798753 2004 1 Dantony R. Chamblis NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 067810-67813 NO Handwritten notes (67871-67874, 68059, 68070, 68079) Yes

ACB 067871-67874, ACB 

068059, ACB 068070, ACB 068079, ACB 068119, ACB 

068120, ACB 068142

YES ACB 067984-67985, ACB 068156

353 HK-811031 2004 1 Max McCoy NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 068220-68221 NO Inv. File Control (68159) Daily Major Incident Log (68217-68219) NO N/A YES ACB 068222354 HK-811135 2004 1 Darryl Conway NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 068377 NO Inv. File Control (68344) Daily Major Incident Log (68375-68376) NO N/A NO N/A

355 HK-823687 2004 4 Fernando Noguez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 068449 NO

Homicide File Supervisor's Check List (68448)

Inv. File Control (68450)

Subpoenas (68451-68454)

NO N/A NO N/A

356 HL-202732 2005 1 Curtis Viverette NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 042238-42239 NO Major Incident Notification Detail Handwritten Note YES ACB 042327 NO N/A

357 HL-219488 2005 1 Muhammad Faheem NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 042490-42492 NO

Biz Card

To-From Memos

Scene/Body Photos

NO N/A YES

ACB 042480-481

ACB 042482ACB 042483ACB 042484

358 HL-227322 2005 1 Patrice Black NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 042800 NO

Handwritten Notes

Photos- Scene/Body

Daily Major Incident Notification Detail

YES

ACB 042799ACB 042837ACB 042838

NO N/A

359 HL-236577 2005 1 John Smurlo NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 042952-42953 NO Major Incident Notification Detail Photos- Scene/Body NO N/A NO N/A

360 HL-242938 2005 1 Daniel Olivares NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 043151-43153 NO

Photos – Persons

Photos – Scene/Body 

Major Incident Notification Detail

Handwritten Notes 

ISP Forensics Lab Report

GPRs

Supp. Report

YES

ACB 043287ACB 043357ACB 043358ACB 043379ACB 043382

NO N/A

361 HL-260858 2005 1 Eduain Foster Marshall Simmons NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 068553-68555 NO

Handwritten Notes

Supp. Report 

Daily Major Incident Log

Photos- Scene/Body

YES

ACB 068680ACB 068757ACB 068761ACB 068765

NO N/A

362 HL-291491 2005 1 Michael Parish NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 068935-68936 NO

Handwritten Notes

Supp. Report 

Major Incident Notification Detail

Photos- Scene/Body

2nd GOCR same except Data Enter DD Area 1 

stamp

YES ACB 068978 NO N/A

363 HL-307618 2005 1 Christopher Butler Robert Kennedy NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 069142-69144 NO Receipt Major Incident Notification Detail Photos- Scene/Body NO N/A NO N/A

364 HL-326591 2005 1 Brian Weston Travis Weston NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 069434-69439 NO Handwritten note Major Incident Notification Detail Photos - Scene/Body YES

ACB 069537ACB 069611ACB 069612ACB 069776ACB 069777

NO N/A

365 HL-336784 2005 1 Leroy Wilson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 069969-69972 NO

Handwritten note

Moving of Arrestee 

Major Incident Notification Detail

Photos Scene/Body

YES

ACB 070014ACB 070113ACB 070206ACB 070229

NO N/A

366 HL-355032 2005 1 Antwan Rogers NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 086596-86597 NO Major Incident Notification Detail Photos- Scene/Body NO N/A NO N/A

53 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 311 of 433 PageID #:15732
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

341 HK-639684 2004 1

Christopher Walton

Michael Walton

Devon Terrell

342 HK-647145 2004 1 Markiesha Wells343 HK-663121 2004 1 Antoine Burton344 HK-669797 2004 1 Morrell Steele Larry Steele

345 HK-683108 2004 1 Robert Curry346 HK-701076 2004 1 Harold Ivey347 HK-746784 2004 1 Andrew Binion348 HK-763869 2004 1 Anthony Riley349 HK-776079 2004 1 Shevona Thomas350 HK-788723 2004 1

Juan Delatorre

Steven NevarezAlejandro Mota

Jerry Rebeles

Antonio Rincon

351 HK-792194 2004 1 Iesha Walker352 HK-798753 2004 1 Dantony R. Chamblis

353 HK-811031 2004 1 Max McCoy354 HK-811135 2004 1 Darryl Conway355 HK-823687 2004 4 Fernando Noguez356 HL-202732 2005 1 Curtis Viverette357 HL-219488 2005 1 Muhammad Faheem358 HL-227322 2005 1 Patrice Black359 HL-236577 2005 1 John Smurlo360 HL-242938 2005 1 Daniel Olivares361 HL-260858 2005 1 Eduain Foster Marshall Simmons

362 HL-291491 2005 1 Michael Parish363 HL-307618 2005 1 Christopher Butler Robert Kennedy

364 HL-326591 2005 1 Brian Weston Travis Weston

365 HL-336784 2005 1 Leroy Wilson366 HL-355032 2005 1 Antwan Rogers

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

54 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 312 of 433 PageID #:15733
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

367 HL-361793 2005 1 Kevin Smith NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 086725-86726 NO Major Incident Notification Detail Photos- Scene/Body YES ACB 086783 NO N/A

368 HL-370043 2005 1 Levester Hill NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 086982-86984 NO

Major Incident Notification Detail

Photos- Scene/Body

Biz. Card

Handwritten Notes

Subpoena (copy but with different handwritten 

notes)

To-From Memos

Release of Liability

YES

ACB 087039ACB 087041ACB 087044

YES ACB 086879 ACB 086985

369 HL-371164 2005 1 Armon Bailey NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 087227-87229 NO

Major Incident Notification Detail

Receipt 

Subpoena (copy but with different handwritten 

notes)

NO N/A NO N/A

370 HL-373670 2005 1 Milton Howard NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 087431 NO

Photos- Scene/Body

Supp. Report

Major Incident Notification Detail

NO N/A NO N/A

371 HL-385610 2005 1 Charles Littlejohn NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 070320-70321 NO

Major Incident Notification Detail

Handwritten Note

Machinist Lodge Schedule

YES ACB 070387 NO N/A

372 HL-387017 2005 1 Brian Fields Carl Warren NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 070529-70530 NO Moving of Arrestee Photos- Scene NO N/A NO N/A

373 HL-393632 2005 1 Larry Carter NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 070708 NO

Subpoena (Copy of one in file with different 

handwritten notes)

Major Incident Notification Detail

Photos – Scene/Body

NO N/A NO N/A

374 HL-399677 2005 1 Louis Lashley NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 070875-70876 NO

Handwritten Note

Photos – Scene/Body

Original Case Incident Report

To From Memo

Major Incident Notification Detail

NO N/A NO N/A

375 HL-407548 2005 1 Antoine Evans NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 071050-71053 NO Photos- Scene/Body YES ACB 071346 YES

ACB 071068ACB 071069ACB 071070

376 HL-448514 2005 1 Jarrell Brown NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 071417; ACB 071422; ACB 071438; ACB 071449; ACB 071455; ACB 071459; 

ACB 071462; ACB 071481

NO

Supervisory Homicide Audit 

Photos-Scene

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

NO N/A NO N/A

377 HL-484055 2005 1 Raul Lopez Michael Nieto NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 071541; ACB 071551; ACB 071575; ACB 071584; ACB 071604; ACB 071608; ACB 071625; ACB 071680; ACB 071699; 

ACB 071707; ACB 071765; ACB 071780

NO

Major Incident Notification Detail

Homicide Case Folder Table of Contents

Crime Scene Processing Report

Handwritten Notes 

Property Inventory

YES ACB 071741 ACB 071751 NO N/A

378 HL-484812 2005 1 Francisco Quezada NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 072201; ACB 072213; ACB 072229; 

ACB 072244; ACB 072253; ACB 072281; 

ACB 072288

NO

Photos – Scene/Body

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

CPD Criminal Histories

Supervisory Homicide Audit Review

NO N/A NO N/A

379 HL-486965 2005 1 Jeremiah Fallon NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 072372; ACB 072377; ACB 072420; ACB 072430; ACB 072459; ACB 072462; ACB 072470; ACB 072476; ACB 072517; 

ACB 072533; ACB 072540; ACB 072578

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Photos- Scene/Body

Supervisory Homicide Audit Review

NO N/A NO N/A

380 HL-489874 2005 1 Sergio Mendoza Jesus Mendoza NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 087533; ACB 087538; ACB 087638; ACB 087650; ACB 087662; ACB 087666; ACB 087670; ACB 087687; ACB 087717; ACB 087763; ACB 087771; ACB 087775; ACB 087787; ACB 087830; ACB 087841; ACB 087895; ACB 087924; ACB 087961; ACB 087998; ACB 088019; ACB 088023; 

ACB 088047

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Photos- Scene/Body

Supervisory Homicide Audit Review

Handwritten notes

YES ACB 087814 ACB 087818 NO N/A

381 HL-504078 2005 1 Julio Guerrero NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 088074; ACB 088099; ACB 088113; ACB 088121; ACB 088131; ACB 088138; 

ACB 088145; ACB 088190

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Biz. Card

Supervisory Homicide Audit Review 

Photos – Person

Photos – Scene/Body

NO N/A NO N/A

382 HL-509628 2005 1 Reginald Webb NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 072627; ACB 072636; ACB 072652; ACB 072663; ACB 072680; ACB 072697; 

ACB 072711; ACB 072724; ACB 072752

NO

Major Incident Notification Detail 

Biz. Card

Photo – Scene/Body

Supervisory Homicide Audit Review

NO N/A NO N/A

383 HL-516150 2005 1 Tony Moore NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 072899; ACB 072905; ACB 072920; ACB 072933; ACB 072847; ACB 072952; ACB 072955; ACB 072971; ACB 072982; 

ACB 072988

NO

Supp. Reports

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Handwritten Notes 

Supervisory Homicide Audit Review 

Photos – Scene/Body

YES ACB 072990-004 NO N/A

384 HL-519786 2005 1 Marcos Garcia NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 073056; ACB 073085; ACB 073096; ACB 073123; ACB 073131; ACB 073134; ACB 073141; ACB 073175; ACB 073185; 

ACB 073192; ACB 073207; ACB 073213

NO

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

General Offense Case Report 

Photos – Scene/Body

NO N/A NO N/A

385 HL-526827 2005 1 Deangelo Norwood NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 073355; ACB 073362; ACB 073470; ACB 073483; ACB 073491; ACB 073499; ACB 073505; ACB 073517; ACB 073525; 

ACB 073530; ACB 073566

NO

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Receipt 

Supervisory Homicide Audit Review

YES ACB 073536 ACB 073547 NO N/A

386 HL-527629 2005 1 Timothy Fountain NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 073651; ACB 073660; ACB 073749; 

ACB 073772; ACB 073817-73818; ACB 

073850; ACB 073864; ACB 073909; ACB 

073914

NO

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Photos – Scene/Body

Handwritten Note

ID Card

YES ACB 073866 ACB 073868 YES ACB 073893 ACB 073896 ACB 073897

55 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 313 of 433 PageID #:15734
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

367 HL-361793 2005 1 Kevin Smith368 HL-370043 2005 1 Levester Hill369 HL-371164 2005 1 Armon Bailey370 HL-373670 2005 1 Milton Howard371 HL-385610 2005 1 Charles Littlejohn372 HL-387017 2005 1 Brian Fields Carl Warren

373 HL-393632 2005 1 Larry Carter374 HL-399677 2005 1 Louis Lashley375 HL-407548 2005 1 Antoine Evans376 HL-448514 2005 1 Jarrell Brown377 HL-484055 2005 1 Raul Lopez Michael Nieto378 HL-484812 2005 1 Francisco Quezada379 HL-486965 2005 1 Jeremiah Fallon380 HL-489874 2005 1 Sergio Mendoza Jesus Mendoza

381 HL-504078 2005 1 Julio Guerrero382 HL-509628 2005 1 Reginald Webb383 HL-516150 2005 1 Tony Moore384 HL-519786 2005 1 Marcos Garcia385 HL-526827 2005 1 Deangelo Norwood386 HL-527629 2005 1 Timothy Fountain

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

56 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 314 of 433 PageID #:15735
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

387 HL-534365 2005 1 Michael Thorpe NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 073946; ACB 073953; ACB 073973; ACB 073979; ACB 073984; ACB 073988; ACB 073998; ACB 074048; ACB 074052; ACB 074055; ACB 074095; ACB 074108; 

ACB 074140; ACB 074148

NO

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review

Photos- Scene/Body

NO N/A NO N/A

388 HL-543584 2005 1 Clara Taylor NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 074217; ACB 074221; ACB 074242; ACB 074249; ACB 074256; ACB 074260; 

ACB 074270; ACB 074277; ACB 074311

NO

To-From Memos

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Handwritten Notes 

Photos – Scene/Body

YES

ACB 074281-284

ACB 074293ACB 074294ACB 074297ACB 074299

ACB 074301-305

ACB 074313

YES

ACB 074212ACB 074213ACB 074214

389 HL-543691 2005 1 Enedino Callegos NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 043442; ACB 043450; ACB 043494; ACB 043507; ACB 043508; ACB 043548; 

ACB 043563; ACB 043568 ; ACB 043580; 

ACB 043609; ACB 043613; ACB 043617; 

ACB 043624; ACB 043663

NO

Request for Identification of Photos

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review

YES ACB 043628 ACB 043655 NO N/A

390 HL-555606 2005 1 Jamaal Collier NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 043691; ACB 043696; ACB 043729; ACB 043742; ACB 043750; ACB 043757; ACB 043764; ACB 043785; ACB 043812; 

ACB 043849

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Handwritten Notes

Supervisory Homicide Audit Review 

Photos- Scene/Body

YES ACB 043833 NO N/A

391 HL-567137 2005 1 St Patrick Trusty NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 043908; ACB 043922; ACB 043942; ACB 043952; ACB 043963; ACB 043970; ACB 043975; ACB 043984; ACB 043991; 

ACB 044019

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Handwritten Notes 

Photos – Persons 

Photos – Scene/Body

YES ACB 044012 NO N/A

392 HL-573690 2005 1

Darnell Crume

Thomas Curtis

John Shields

Marvin Stone

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 044105; ACB 044118; ACB 044160; ACB 044171; ACB 044178; ACB 044182; ACB 044218; ACB 044238; ACB 044252; 

ACB 044258; ACB 044266; ACB 044314

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Photos – Scene/Body

YES ACB 044240 ACB 044294 NO N/A

393 HL-604727 2005 1 Justin Love NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 074364; ACB 074371; ACB 074403; ACB 074408; ACB 074419; ACB 074427; ACB 074435; ACB 074449; ACB 074476; 

ACB 074483; ACB 074507

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Photos – Scene/Body

Supervisory Homicide Audit Review

NO N/A NO N/A

394 HL-612170 2005 1 Jose Elizondo NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 074612; ACB 074624; ACB 074658; ACB 074664; ACB 074697; ACB 074705; 

ACB 074710; ACB 074736; ACB 

074801;ACB 074813

ACB 074819; ACB 074822; ACB 074871

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Photos – Scene/Body

To-From Memo

Handwritten Notes

YES

ACB 074837-838

ACB 074841

ACB 074848-849

ACB 074855ACB 074865

YES ACB 074604

395 HL-617116 2005 4 Apolinar Hernandez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES Area Central Basement 0000003 NO

Homicide File Supervisor’s Check List

GPRs

General Offense Case Report

NO N/A NO N/A

396 HL-619201 2005 4 Andres Rojas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES Area Central Basement 0000002; Area Central Basement 0000004 NO

Homicide File Supervisor’s Check List

Subpoenas APD and ASA 

Handwritten Notes 

Photos- Scene/Body

Photos- Person

YES Area Central Basement 0000099 NO N/A

397 HL-628024 2005 1 Wardell Nugen NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 074896; ACB 074899; ACB 074916; ACB 074921; ACB 074931; ACB 074939; 

ACB 074945; ACB 074953

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review 

Photos- Scene

NO N/A NO N/A

398 HL-641342 2005 1 Jose Salcedo NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 075025; ACB 075031; ACB 075059; ACB 075062; ACB 075086; ACB 075098; ACB 075101; ACB 075119; ACB 075127; 

ACB 075133; ACB 075136; ACB 075157

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Photos- Video Stills

Photos – Scene/Body

Supervisory Homicide Audit Review

NO N/A NO N/A

399 HL-656289 2005 1 Brian Goolsby NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 075221; ACB 075227; ACB 075282; ACB 075297; ACB 075316; ACB 075327; 

ACB 075330; ACB 075348; ACB 075356

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Handwritten Notes

Aerial Map

Supervisory Homicide Audit Review 

Photos – Scene/Body

YES ACB 075377 NO N/A

400 HL-662200 2005 1 Raul Gomez NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 075496; ACB 075502; ACB 075529; ACB 075556; ACB 075614; ACB 075620; ACB 075626; ACB 075649; ACB 075656; 

ACB 075713

NO

Major Incident Notification Detail

Homicide Case Folder Table of Contents

Photos- Scene/Body 

Subpoena

Handwritten Notes 

Supervisory Homicide Audit Review

YES ACB 075663-664 ACB 075751-755 NO N/A

401 HL-669557 2005 1

Emil Kozeluh

Christopher 

Kronenberger

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 075891-75894 NO

Personal Court Notification Details

Major Incident Notification Detail 

Handwritten Notes

YES

ACB 075973

ACB 076102-103

ACB 076107ACB 076115

YES ACB 075911 ACB 075929

402 HL-673823 2005 1 Dasmen Thomas NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 076310; ACB 076320; ACB 076363; ACB 076370; ACB 076393; ACB 076406; ACB 076421; ACB 076442; ACB 076462; ACB 076471; ACB 076475; ACB 076486; 

ACB 076510

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Court Complaint Transmittal Listing 

Photos – Scene/Body

NO N/A NO N/A

403 HL-710670 2005 1

Daniel Zavala

Alfonso Ochoa

Jesus Sandoval

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 076641; ACB 076649-76650; ACB 

076817; ACB 076832; ACB 076842; ACB 076869; ACB 076876; ACB 076894; ACB 076902; ACB 076914; ACB 076923; ACB 

076941

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review 

Photos – Scene/Body

NO N/A NO N/A

404 HL-722490 2005 1 Jonathan Brooks NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 077003; ACB 077047; ACB 077058; ACB 077071; ACB 077080; ACB 077087; 

ACB 077093

NO

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

To-From Memo 

Supervisory Homicide Audit Review 

Photos – Person

Photos – Scene/Body

NO N/A YES ACB 076998-999

57 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 315 of 433 PageID #:15736
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

387 HL-534365 2005 1 Michael Thorpe388 HL-543584 2005 1 Clara Taylor389 HL-543691 2005 1 Enedino Callegos390 HL-555606 2005 1 Jamaal Collier391 HL-567137 2005 1 St Patrick Trusty392 HL-573690 2005 1

Darnell Crume

Thomas Curtis

John Shields

Marvin Stone

393 HL-604727 2005 1 Justin Love394 HL-612170 2005 1 Jose Elizondo395 HL-617116 2005 4 Apolinar Hernandez396 HL-619201 2005 4 Andres Rojas397 HL-628024 2005 1 Wardell Nugen398 HL-641342 2005 1 Jose Salcedo399 HL-656289 2005 1 Brian Goolsby400 HL-662200 2005 1 Raul Gomez401 HL-669557 2005 1

Emil Kozeluh

Christopher 

Kronenberger

402 HL-673823 2005 1 Dasmen Thomas403 HL-710670 2005 1

Daniel Zavala

Alfonso Ochoa

Jesus Sandoval

404 HL-722490 2005 1 Jonathan Brooks

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

58 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 316 of 433 PageID #:15737
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

405 HL-808159 2005 1 Michael Nieto NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 088300; ACB 088304; ACB 088321; ACB 088332; ACB 088340; ACB 088345; 

ACB 088363; ACB 088378; ACB 088386

NO

Major Incident Notification Detail

Handwritten Notes 

Supervisory Homicide Audit Review

YES ACB 088408-413 NO N/A

406 HM- 100890 2006 1 Lonnell Payne NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 077232-77233; ACB 077288; ACB 

077303; ACB 077325; ACB 077332; ACB 077340; ACB 077426; ACB 077433; ACB 077447; ACB 077450; ACB 077498; ACB 

077551

NO

Photos – Scene/Body

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Handwritten Notes

Receipt

Supervisory Homicide Audit Review

YES

ACB 077354ACB 077494

ACB 077513-520

ACB 077544ACB 077545

NO N/A

407 HM- 148888 2006 1 Nicholas Izguerra NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 077647; ACB 077656; ACB 077683; ACB 077693; ACB 077711; ACB 077716; ACB 077738; ACB 077754; ACB 077775 NO

ASA Subpoena for Streetfiles

Photos – Scene/Body

Photos - Persons

Major Incident Notification Detail

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

NO N/A NO N/A

408 HM- 182777 2006 1 Ariel Bueno NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 077817; ACB 077825; ACB 077842; ACB 077848; ACB 077862; ACB 077866; ACB 077873; ACB 077881; ACB 077886; 

ACB 077891

NO

Criminal History 

Investigative Alert

Photos – Person 

Photo – Scene

Major Incident Notification Detail

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

NO N/A NO N/A

409 HM- 199438 2006 1 Christopher Sodaro NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 088477; ACB 088487; ACB 088517; ACB 088522; ACB 088536; ACB 088542; ACB 088545; ACB 088565; ACB 088613; 

ACB 088626; ACB 088635

NO

Supplement Report 

Photos – Person

Photos – Scene 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Handwritten Notes

YES

ACB 088562; ACB 088586; ACB 088638; ACB 088649; 

ACB 088651; ACB 088654-

655; ACB 088665; ACB 

088668; ACB 088673; ACB 

088681; ACB 088686-687; 

ACB 088691-694

NO N/A

410 HM- 208287 2006 1 Derrick Lemon NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 088787; ACB 088796; ACB 088832; ACB 088846; ACB 088858; ACB 088864; ACB 088872; ACB 088905; ACB 088915; ACB 088918; ACB 088921; ACB 088948; 

ACB 088957

NO

Photos – Scene/Body

Major Incident Notification Detail

Homicide Case Folder Table of Contents

NO N/A NO N/A

411 HM- 231046 2006 1 Jennifer Reeves NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 089046; ACB 089053; ACB 089098; ACB 089123; ACB 089136; ACB 089149; ACB 089164; ACB 089174; ACB 089180; ACB 089195; ACB 089198; ACB 089264; 

ACB 089290

NO

Photos- Scene/Body 

Polygraph DVD 

Digital Recording of DVD Receipt

Major Incident Notification Detail

Homicide Case Folder Table of Contents

Handwritten Note

Supervisory Homicide Audit Review

YES ACB 089209 NO N/A

412 HM- 232296 2006 1 Marlin Garner Frederick Deese NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 077964; ACB 077974; ACB 077995; ACB 078001; ACB 078015; ACB 078027; ACB 078060; ACB 078071; ACB 078080; 

ACB 078127

NO

Facsimile Message 

SOS Search 

Court Notification Summary Report 

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review 

Photos – Person

YES

ACB 078097ACB 078101ACB 078102

YES

ACB 078115ACB 078116ACB 078117ACB 078118

413 HM- 264904 2006 1 Eddie Fenton Tytiyana Underwood Jameelah Williams NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 078151; ACB 078164; ACB 078182; ACB 078203; ACB 078251; ACB 078357; ACB 078428; ACB 078432; ACB 078436; ACB 078443; ACB 078511; ACB 078523; 

ACB 078596; ACB 078608- 

 609

NO

IDOC Inmate Searches

Bureau of Invest. Services Deployment 

Operations Center

Criminal Histories

Clear Data Warehouse Charges & Photos

DL/ID Image Retrieval

Arrest Report 

Investigative Alerts

Photos – Person

Handwritten Note 

CCDOC Inmate Report

 CHESS Memo

 Memo

 Photos – Scene 

 Major Incident Notification Detail

 Homicide Case Folder Table of Contents

YES ACB 078310 ACB 078460 NO N/A

414 HM- 278309 2006 1 Bruce Ervin NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 078885; ACB 078901; ACB 078929; ACB 078938; ACB 078961; ACB 078973; ACB 079009; ACB 079025; ACB 079029; 

ACB 079032; ACB 079038; ACB 079104

NO

Handwritten Notes 

Photos – Scene/Body

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review

YES ACB 078897 ACB 079060 NO N/A

415 HM- 304212 2006 1 Ariel Bueno NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 079191; ACB 079195; ACB 079221; ACB 079227; ACB 079281; ACB 079287; ACB 079291; ACB 079299; ACB 079306; 

ACB 079337

NO

Photos – Scene/Body

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review

NO N/A NO N/A

416 HM- 307550 2006 1 Jorge Flores NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 079407; ACB 079419; ACB 079440; ACB 079453; ACB 079476; ACB 079487; ACB 079496; ACB 079503; ACB 079511 NO

Photos – Person 

Photos – Scene/Body 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review

NO N/A NO N/A

417 HM- 318752 2006 1 David Aguilera NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 079623; ACB 079634; ACB 079663; ACB 079667; ACB 079677; ACB 079685; ACB 079690; ACB 079699; ACB 079715; 

ACB 079732; ACB 079738; ACB 079775

NO

Request for Evidence from ERPS

Attorney Cards 

Photos – Scene/Body

Major Incident Notification Detail 

Homicide Case Folder Table of Contents 

Supervisory Homicide Audit Review

NO N/A NO N/A

59 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 317 of 433 PageID #:15738
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

405 HL-808159 2005 1 Michael Nieto406 HM- 100890 2006 1 Lonnell Payne

407 HM- 148888 2006 1 Nicholas Izguerra

408 HM- 182777 2006 1 Ariel Bueno

409 HM- 199438 2006 1 Christopher Sodaro

410 HM- 208287 2006 1 Derrick Lemon

411 HM- 231046 2006 1 Jennifer Reeves

412 HM- 232296 2006 1 Marlin Garner Frederick Deese

413 HM- 264904 2006 1 Eddie Fenton Tytiyana Underwood Jameelah Williams

414 HM- 278309 2006 1 Bruce Ervin

415 HM- 304212 2006 1 Ariel Bueno

416 HM- 307550 2006 1 Jorge Flores

417 HM- 318752 2006 1 David Aguilera

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

60 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 318 of 433 PageID #:15739
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

HAS 

CRIMINAL 

DEFENSE 

ATTORNEY 

FILE BEEN 

PRODUCED?

ARE 

INVESTIGATIVE

MATERIALS 

MISSING FROM 

THE DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

INVESTIGATIVE 

MATERIALS

DOES THE 

DEFENSE 

ATTORNEY 

FILE 

CONTAIN AN 

INVENTORY 

SHEET?

DOES THE 

INVENTORY 

SHEET IN THE 

DEFENSE 

ATTORNEY FILE 

MATCH THE INVENTORY 

SHEET IN THE 

BASEMENT FILE?

ARE GENERAL 

PROGRESS 

REPORTS 

FROM THE 

BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

GENERAL 

PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING 

HANDWRITTEN 

NOTES

ARE TO-FROM MEMOS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

DEFENSE 

ATTORNEY 

FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS

DOES THE 

BASEMENT 

FILE INCLUDE 

AN 

INVENTORY?

BATES NUMBER FOR INVENTORY

IS THE 

INVENTORY COMPLETE?

EXAMPLES OF ITEMS MISSING FROM 

INVENTORY

ARE THERE 

HANDWRITTEN 

NOTES IN THE 

FILE?

BATES NUMBERS FOR 

HANDWRITTEN NOTES

ARE 

THERE TOFROM 

MEMOS IN 

THE FILE?

BATES NUMBERS 

FOR TO-FROM 

MEMOS

INVESTIGATIVE FILE INFORMATION IDENTIFYING INFORMATION CRIMINAL DEFENSE ATTORNEY FILE COMPARISON Items in the Investigative File missing from the Criminal Defense Attorney File

418 HM- 341097 2006 1

Prince Ford

Antonio RushBruce Garrett

Juan Booker

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 079863; ACB 079873; ACB 079910; ACB 079915; ACB 079952; ACB 079970; ACB 079982; ACB 079999; ACB 080089; 

ACB 080110; ACB 080120; ACB 080157

NO

•Investigative Alert 

Criminal History 

Handwritten Note

ISP Forensics Lab Reports

Memo 

Photos – Scene/Body

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

YES ACB 080057 NO N/A

419 HM- 353304 2006 1 Ronald Livingston NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 080265; ACB 080271; ACB 080371; ACB 080378; ACB 080415; ACB 080444; ACB 080448; ACB 080466; ACB 080486; 

ACB 080497; ACB 080526; ACB 080542

NO

ASA Subpoena for Streetfiles 

Copy Request Inventory Disk 

Photos – Scene/Body 

ISP Laboratory Report 

Major Incident Notification Detail 

Supervisory Homicide Audit Review

No N/A NO N/A

420 HM- 366735 2006 1 Benjamin Cooley NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 080620; ACB 080629; ACB 080678; ACB 080683; ACB 080701; ACB 080713; ACB 080735; ACB 080746; ACB 080753; 

ACB 080785

NO

Handwritten Notes

Supervisory Homicide Audit Review 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Photos - Scene/Body

Yes

ACB 080617ACB 080755ACB 080769

NO N/A

421 HM- 367019 2006 1 Lewis Robinson NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 044429; ACB 044437; ACB 044461; ACB 044464; ACB 044475; ACB 044484; ACB 044499; ACB 044507 NO Supervisory Homicide Audit Review Major Incident Notification Detail Homicide Case Folder Table of Contents

Photos- Scene/Body

No N/A NO N/A

422 HM- 372012 2006 1 Daniel Avitia NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 044590; ACB 044600; ACB 044625; ACB 044632; ACB 044669; ACB 044676; ACB 044685; ACB 044721; ACB 044751; 

ACB 044762; ACB 044812

NO

Photos – Scene/Body

Major Incident Notification Detail

Homicide Case Folder Table of Contents 

Handwritten Note

Yes ACB 044779 NO N/A

423 HM- 414793 2006 1 Lorenzo Wilson Paris Gosha Erika Ray NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 044907; ACB 044926; ACB 044978; ACB 045005; ACB 045018; ACB 045027; ACB 045046; ACB 045067; ACB 045073; ACB 045118; ACB 045124; ACB 045130 NO Major Incident Notification Detail Homicide Case Folder Table of Contents Photos- Scene/Body Supp. Report NO N/A NO N/A

424 HM- 419168 2006 1 Edwon Carter NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 045187; ACB 045203; ACB 045260; ACB 045265; ACB 045301; ACB 045317; ACB 045322; ACB 045349; ACB 045374; 

ACB 045382

NO

•Handwritten Notes 

Receipts

Photos – Scene/Body

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

YES

ACB 045387ACB 045388ACB 045447ACB 045448

NO N/A

425 HM- 445290 2006 1 Clarence Mosely NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 045500; ACB 045512; ACB 045543; ACB 045559; ACB 045619; ACB 045626; ACB 045640; ACB 045654; ACB 045696; 

ACB 045711; ACB 045717; ACB 045733

NO

•Handwritten Notes

Photos - Scene

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

NO N/A NO N/A

426 HM- 449389 2006 1 Darnell Lane NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 045819; ACB 045830; ACB 045868; ACB 045905; ACB 045919; ACB 045936; ACB 045969; ACB 045973; ACB 045979; 

ACB 046022

NO

•Handwritten Notes 

Photos – Scene/Body 

DVD 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

YES

ACB 045983ACB 045996ACB 045998

NO N/A

427 HM- 478600 2006 1 Jose Soto NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES ACB 046117; ACB 046125; ACB 046151; ACB 046177; ACB 046191; ACB 046222; ACB 046249; ACB 046255; ACB 046263 NO

Handwritten Notes 

Photos – Persons 

Photos – Scene/Body 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

YES ACB 046275 ACB 046276 NO N/A

428 HM- 492478 2006 1 Jermaine Lewis NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 046430ACB 046445ACB 046471ACB 046476ACB 046492ACB 046503

NO

Crime Scene Processing Report 

Towed Vehicle Disposition 

ISP Telephone Coversation Record

Handwritten Notes 

GPRs

Line Up Sheets

Attorney ID Cards 

Photos – Persons 

Photos – Scene/Body 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

YES

ACB 046525ACB 046540ACB 046559

NO N/A

429 HM- 501773 2006 1 Carlos Rivera NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES

ACB 046640; ACB 046646; ACB 046685; ACB 046691; ACB 046708; ACB 046721; 

ACB 046724; ACB 046736; ACB 046743; 

ACB 046782

NO

Photos – Persons 

Photos – Scene/Body 

Major Incident Notification Detail 

Homicide Case Folder Table of Contents

Supervisory Homicide Audit Review

NO N/A NO N/A

61 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 319 of 433 PageID #:15740
RECORDS 

DIVISION 

NUMBER

YEAR AREA DEFENDANT(S)

IDENTIFYING INFORMATION

418 HM- 341097 2006 1

Prince Ford

Antonio RushBruce Garrett

Juan Booker

419 HM- 353304 2006 1 Ronald Livingston

420 HM- 366735 2006 1 Benjamin Cooley

421 HM- 367019 2006 1 Lewis Robinson

422 HM- 372012 2006 1 Daniel Avitia

423 HM- 414793 2006 1 Lorenzo Wilson Paris Gosha Erika Ray

424 HM- 419168 2006 1 Edwon Carter

425 HM- 445290 2006 1 Clarence Mosely

426 HM- 449389 2006 1 Darnell Lane

427 HM- 478600 2006 1 Jose Soto

428 HM- 492478 2006 1 Jermaine Lewis

429 HM- 501773 2006 1 Carlos Rivera

HAS A 

PERMANENT 

RETENTION 

FILE BEEN 

PRODUCED?

IS THE 

INVESTIGATIVE 

FILE 

INVENTORY IN 

THE 

PERMANENT 

RETENTION 

FILE?

DOES THE INVENTORY IN THE PERMANENT 

RETENTION FILE MATCH THE INVENTORY 

IN THE BASEMENT FILE?

ARE THE 

GENERAL 

PROGRESS 

REPORTS FROM 

THE BASEMENT 

FILE MISSING 

FROM THE 

PERMANENT 

RETENTION 

FILE?

BATES NUMBERS FOR MISSING 

GENERAL PROGRESS REPORTS

ARE 

HANDWRITTEN 

NOTES FROM THE 

BASEMENT FILE 

MISSING FROM 

THE PERMANENT 

RETENTION FILE?

BATES NUMBERS FOR 

MISSING HANDWRITTEN 

NOTES

ARE TO-FROM 

MEMOS FROM THE 

BASEMENT FILE 

MISSING FROM THE

PERMANENT 

RETENTION FILE?

BATES NUMBERS 

FOR MISSING TOFROM MEMOS OTHER INVESTIGATIVE MATERIAL FROM THE BASEMENT FILE MISSING FROM THE PERMANENT RETENTION FILE

PERMANENT RETENTION FILE COMPARISON

Items in the Investigative File missing from the Permanent Retention File

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

NO N/A N/A N/A N/A N/A N/A N/A N/A N/A

62 of 62

Fields v. City of Chicago, Index of Basement Files, 1983-1989, 1999-2006

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 320 of 433 PageID #:15741
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT I 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 321 of 433 PageID #:15742
1 

Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

James Kluppelberg v. Jon Burge and City of Chicago, et al. 

No. 1:13-cv-03963 

Report of Plaintiff’s Expert – Michael D. Brasfield 

January 5, 2016 

A. Introduction 

Gayle Horn with the law firm of Loevy & Loevy, representing the plaintiff in this matter, 

contacted and retained me to review the appropriateness of the actions of numerous employees of 

the City of Chicago, specifically as they relate to matters stemming from the arrest and eventual 

incarceration of James Kluppelberg for allegedly setting fire to a residential structure on March 

24, 1984 that resulted in the deaths of 6 individuals. These events cover a 29-year period, 

beginning in March 1984 and ending in August 2013 when Kluppelberg was exonerated and 

declared innocent of the crimes for which he was convicted. 

Based on my review of the materials provided to me, I have concluded to a reasonable 

degree of professional certainty that certain individual defendants and the City of Chicago failed 

to conduct even a cursory investigation of the facts prior to arresting Mr. Kluppelberg and 

causing him to be charged. Physical abuse, including assault, was utilized to obtain a false 

confession. Additionally, based on false evidence from Duane Glassco and others, the evidence 

in the record leads me to conclude that the defendants manufactured and falsified evidence and 

manipulated witnesses using improper police interrogation tactics, all in violation of accepted 

police procedures. 

Defendants also withheld critically relevant information from Kluppelberg and his 

counsel, In fact, it was not until August 2014, during this civil litigation, that the City produced 

the investigative file created by the Area 3 detectives in 1984. That file, referred to as the “New 

File,” contained exculpatory information and was not disclosed to Kluppelberg prior to his 

criminal trial. 

In my opinion, the City of Chicago created an environment where officers could ignore 

police department policies, proper police practices, and the law with impunity and that such 

behavior was not only tolerated, but also encouraged. The evidence from this case demonstrates 

that even though the Chicago Police Department ("CPD") had formal written standards for 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 322 of 433 PageID #:15743
2 

homicide investigations, as a matter of unofficial policy or widespread practice, the defendants in 

this case were permitted to repeatedly violate those written standards and other commonly 

accepted police investigative practices. My opinions and the facts upon which I base my 

opinions are discussed in greater detail below. 

I have been an active-duty municipal and/or county law enforcement official for 

approximately 39 years. I retired from active governmental service in 2009. I have served as the 

Chief of Police of the Fort Lauderdale Police Department, the Assistant Chief of the Seattle 

Police Department, and the elected Sheriff of Jefferson County, Washington. Over the last 20 

years I have also been actively engaged as a consultant, trainer, and case reviewer in matters 

related to law enforcement. An overview of my qualifications follows in a later portion of this 

opinion. Over the past nine years, I have testified and been qualified as a police practices expert 

in numerous state and federal courts for both plaintiffs and defendants. My testimony has been 

both on behalf of and against law enforcement personnel. 

I set forth the FRPC 26 list of cases in which I have testified as Attachment A; the 

material I reviewed with respect to this case in Attachment B; my rate of compensation in 

Attachment C; and my detailed resume in Attachment D. 

I reserve the right to alter and supplement my opinions and/or form additional opinions 

regarding this case upon disclosure to me of any further information or documentation related to 

this case. 

B. Expert Witness Qualifications 

I began my 41-year law enforcement career in 1968 as a patrol officer with the City of 

Mercer Island, Washington. In 1969, I joined the Seattle Police Department and served Seattle 

as a police officer, detective, sergeant, lieutenant, captain, major, and assistant chief. In addition 

to uniformed patrol, my investigative assignments as a detective included traffic, homicide 

investigation, burglary and theft, and vice (gambling and prostitution). As a sergeant, I served in 

patrol, the tactical squad, and internal investigations. As a lieutenant, I served as a watch 

commander in charge of 50 patrol officers, and later as the commander of the Washington State 

Criminal Justice Training Commission's Basic Law Enforcement Academy for 2 years. This 

academy was responsible for developing and providing the initial law enforcement training for 

all commissioned law enforcement officers in Washington State. As a captain, I served as 

commander at both the downtown and north precincts, with responsibility for over 125 officers 

at each location. I also served as the commander of the Internal Investigations section of the 

Seattle Police Department for 2 years. I was the major in command of the inspectional services 

division for 4 years. This division was responsible for developing, implementing, and 

monitoring departmental policies and procedures. This division was also responsible for 

developing and administering a budget in excess of $120 million. My last 5 years with the 

Seattle Police Department were served as assistant chief in command of the support services 

bureau. I was responsible for, and oversaw the activity of, nine uniquely different divisions 

including: internal investigations; training; personnel, intelligence; crime prevention; 

communications; records & evidence; data processing; and fiscal, property, & fleet management. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 323 of 433 PageID #:15744
3 

In this capacity I routinely served as the acting Chief of Police. I retired from the agency in 

1995. 

I was selected by the City of Fort Lauderdale as its Police Chief in 1995. The 33-squaremile city has a full time resident population of 165,000. An estimated additional 60,000 "snow 

bird" residents return to second homes in the city during the 6-month winter season. Fort 

Lauderdale serves as the seat of government for the county of 1.5 million and is in the heart of a 

diverse tri-county (Dade, Broward, and Palm Beach) population of 4 million. As one of the 

premier tourist destinations in South Florida, over 12 million passengers come through the 

airport each year. The ocean port handles the second largest number of cruise ship sailings in the 

world. Fort Lauderdale serves as the governmental and business hub of the County. The Fort 

Lauderdale Police Department had a budget of $60 million and consisted of 500 sworn positions 

and 300 civilian positions. In 2000, the department received 600,000 calls for service, 

dispatched over 200,000 of those calls, made over 20,000 arrests, and issued 65,000 traffic 

citations. The Department is now nationally recognized as an innovative leader in the field of 

community policing and was one of only a handful of cities nationwide to be selected as a 

Community Policing Demonstration Site by the Department of Justice. I oversaw the operation 

of the only municipal jail in the state of Florida. Under my tenure, Fort Lauderdale became the 

first major agency to obtain accreditation. After over 6 years as the police chief of Fort 

Lauderdale, I retired from law enforcement a second time and returned to the Seattle area in the 

fall of 2001. 

After retiring as Chief of the Fort Lauderdale Police Department I returned to my 

retirement home in Washington State. After a year and a half I chose to run for, and was elected 

to, the office of Jefferson County Sheriff. I served in that capacity for over 6 years, and retired 

from active-duty law enforcement for the third (and final) time in the spring of 2009. 

As both a Police Chief (6 years) and Sheriff (6 years), I have reviewed and approved 

policy and procedures of every kind. These included (but are not limited to) criminal 

investigations, maintenance of police records, complaints against police officers, training, 

supervision, and discipline. I believe that of specific relevance to this case is that I was the chair 

of the Washington State Board on Law Enforcement Training, Standards, and Education. 

Through that position I regularly examined and reviewed issues and criteria that define standards 

and norms related to the practice and administration of law enforcement practices and operations. 

I also served 2 years as Commander of the Washington State Basic Law Enforcement Academy 

in Burien, Washington. In that position I was responsible for the administration of the training 

program provided to all Washington State Law Enforcement Officers. This was also my role as 

the Assistant Chief of the Seattle Police Department responsible for in-service and advanced 

training at the Academy over a subsequent 5-year period. Finally, for 6 years, I was the 

Commander of the Seattle Police Department's Inspectional Services Division and responsible 

for the development, formulation and updating all police policy and procedures, including those 

involved in proper investigation procedures. 

As an independent consultant and sub-contractor, I have completed on-site visits to 

analyze 6 major U.S. city police agencies (Boston, Baltimore, Memphis, Oxnard, Cleveland & 

Seattle) to evaluate community policing in public housing. I have also served as a visiting 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 324 of 433 PageID #:15745
4 

management assessor for the cities of New Orleans (LA), Columbus (OR), Portland, (OR), San 

Francisco (CA), Bremerton (WA). Upon my return to Seattle in 2001, I provided contract 

professional services as a consultant and program director for the non-profit South Downtown 

Foundation. I had responsibility for administering several million dollars for improving public 

safety in the International District, SoDo, and Pioneer Square neighborhoods of Seattle. In this 

capacity I coordinated efforts with the City of Seattle, the Seattle Police Department, and various 

interest and civic groups in the area. 

As Sheriff of Jefferson County, I held a gubernatorial appointment to the Washington 

State Sentencing Guidelines Commission, serving as the only law enforcement official on this 

body of judicial, legislative, and executive-branch representatives. I also chaired the Washington 

State Criminal Justice Training Commission's Board on Law Enforcement Training, Standards, 

and Education. Members of this board monitored and evaluated the training of police officers 

and participated in law enforcement decertification hearings. 

Over the last 40 years I have received extensive, specialized professional training in 

nearly all areas of law enforcement. There has been particular emphasis in the areas of training, 

internal investigations, criminal investigations, traffic homicide investigations, use of force, 

ethics, and police liability. I was awarded "life member" status with the International 

Association of Chiefs of Police in 2005. I was also awarded "life member" status with the 

Washington Association of Sheriffs and Police Chiefs in 2009. I am also a "life member" of the 

National Sheriffs Association. I have also been a member of the Washington State Sheriffs 

Association and served on the executive board of that organization. 

During my career, I have been required to investigate and/or review hundreds of internal 

investigations. I have supervised hundreds of officers, and have had to review their compliance 

with standards of behavior and integrity. As both a supervisor, and later a commander of internal 

investigations with the Seattle Police Department, I have reviewed and evaluated the 

thoroughness of well over hundreds of such investigations. As a police chief and as a sheriff, I 

have had the ultimate responsibility of passing judgment on such actions by law enforcement 

officers in situations ranging from traffic stops to fatal shootings. 

I received a Bachelor of Arts degree in Criminal Justice from the University of 

Washington in Seattle. I also am a graduate of the Senior Management Institute for Police 

(SMIP) of the Police Executive Research Forum. 

I have been retained in over 65 lawsuits as a police practices expert witness - 

approximately 66% for law enforcement defendants and 33% for civil rights plaintiffs or 

individuals claiming injury by law enforcement officers. These include federal district courts in 

Illinois, Pennsylvania, Florida, Washington State, Idaho, Oregon, Colorado, and Louisiana, and 

state courts in Washington, Alaska, California, Oregon, Arizona, Pennsylvania, Florida, 

Wyoming, Texas, and Kentucky. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 325 of 433 PageID #:15746
5 

I. Background Facts Relating to Fire at 4448 S. Hermitage and Subsequent 

Investigations 

A. Brief Overview of Facts Relating to Investigation of James Kluppelberg and Fire 

at 4448 S. Hermitage 

In the early morning hours of March 24, 1984, a fire erupted in the vacant first floor of a 

three-story apartment building on Chicago’s South Side. 

The fire ripped through the building, killing 28 year old Elva Lupercio and her five 

children, Santos, 10; Sonia, 8; Christobel, 6; Yadira, 4; and Anabel, 3, who lived on the second 

floor. Elva’s husband, Santos, managed to escape, but suffered a fractured skull and severe 

burns. 

The fire destroyed the building, located at 4448 South Hermitage Avenue, as well as an 

adjacent building and damaged another, but no one else was injured. The cause of the fire was 

listed as undetermined due to extensive burning and the collapse of the building. The fire 

(investigation) was closed as “apparent accidental”1

 by detective Lawrence Tuider. 

At the time of the fire, investigations of this type were conducted by the Chicago Police 

Department (CPD) Bomb and Arson Unit. The Bomb and Arson Unit found that the cause and 

origin of the fire at 4448 South Hermitage could not be determined due to the extensive 

destruction of the building and the absence of an accelerant2

. In April of 1984 the CPD closed 

the case as non-criminal, “apparent accidental fire deaths”.3

 

On March 23, 1984, about 15 hours before the fire at 4448 South Hermitage broke out, a 

house nearby at 4504 South Marshfield burned to the ground4

. The fire then spread to the 

buildings adjacent to 4504 South Marshfield. To even the most casual observer, the similarities 

between the fire at 4504 South Marshfield and 4448 South Hermitage (2 blocks away) are 

obvious. For instance, they both occurred within hours of each other and within 2 blocks of each 

other, and both fires were of a magnitude that they spread to adjacent buildings. Fire and Arson 

detective Wayne Micek5

 was listed as being one of the personnel assigned to the investigation of 

the Marshfield fire. 

The person responsible for setting the Marshfield fire was a woman by the name of Isabel 

Ramos6

 (age 38 at the time of the 1984 fires). Ramos lived at her aunt’s home at 4640 South 

Marshfield at the time of the fires. Ramos was also reported to have been under medical care for 

mental health issues. Ramos admitted to setting the fire at 4504 South Marshfield, for which she 

was ultimately convicted.7

 She said that she spent the next 12 hours or more wandering around 

to different bars on Ashland Avenue. Ramos was interviewed in connection with the Marshfield 



1

 National Registry of Exonerations. University of Michigan Law School. Maurice Possley. Before June 2012. 

2

 CPD #F-105-510 (CITY-KLUP_004367) 

3

 CPD Supplementary Report to #F-105-510 dated 4/13/1984 (CITY-KLUP_000562-564) 

4

 CPD #F-104-537 (CITY-KLUP_004358-4363) 

5

 Ibid, (CITY-KLUP_004361) 

6

 CPD Report - #F-105-510 (CITY-KLUP_004316) dated 3/24/1984 

7

 Ibid, (CITY-KLUP_004317) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 326 of 433 PageID #:15747
6 

fire, the fire at 4448 S. Hermitage, and yet another fire in the neighborhood that happened the 

same week as the other two fires.8

 Ramos told investigating officers during this interview that 

she “may have set” other fires besides the Marshfield fire but because of her intoxicated 

condition she could not remember specifically having set it. A number of individuals 

responsible for investigating the Lupercio/Hermitage fire were well aware of all three fires and 

that they had occurred in a short temporal and geographic proximity to each other. Information 

about Isabel Ramos being questioned regarding the 4448 S. Hermitage fire was shared with 

detectives Lawrence Tuider and McKinley9

. 

A police report10 also made reference to another possible suspect, a 13 to 14 year old 

teenager named “Ritchie” who claimed that he had helped set the fire at 4448 South Hermitage 

(Lupercio family residence) fire, and that he lived at 4437-4435 South Marshfield. 

There was also a “tip” that “James Crockenburg” might have been involved in the 

Lupercio fire11. This “tip” was also referenced in his arrest report for the Lupercio fire.12

In November of 1987, over three and a half years after the fire, an individual by the name 

of Duane Glassco (age 19 at the time of the fire) was arrested by CPD for burglary, theft, and 

violation of probation. During his interrogation by the police in December 1987, he allegedly 

volunteered a statement that he had information that James Kluppelberg had been responsible for 

starting the fatal fire that killed the Lupercio family members.13 It should be noted that Glassco 

had previously dated a woman by the name of Dawn Gramont. Gramont had later dated James 

Kluppelberg and Glassco had reason to dislike Kluppelberg. Glassco’s statement to police 

included facts that were objectively false, and appear to have been based on a desire to reduce 

jail time on his charges, and in retaliation for the Kluppelberg – Gramont relationship. 

Also in December of 1987, James Kluppelberg (age 18 at the time of the fire) reported a 

fire in which 2 vehicles had been burned at 820 West Belle Plaine Avenue on the north side of 

Chicago. Kluppelberg was a working as a security guard at the location of the vehicle fires. It 

should be noted that the car fires were over 3 years and 15 miles removed from the fires of 1984 

described above. 

Bomb & Arson Detectives Leonard Rolston and John Schmitz brought Kluppelberg in on 

a pretext to talk about the car fires. According to Kluppelberg, they actually began questioning 

him about the Lupercio/Hermitage fatality fire that occurred more than 3 years earlier. During 

their interrogation of Kluppelberg, the detectives claim that he supposedly provided a voluntary 

confession to not only the car fires, but also to the fire on South Hermitage that killed members 

of the Lupercio family. Kluppelberg initially denied involvement in the fatal fire of 1984. 

Kluppelberg alleged that he was beaten by officers during his interrogation and eventually 



8

 Micek Dep at 33 

9

 CPD Report - #F-105-510, (CITY-KLUP_004315) 

10 Chicago Police Department report contained in what has been described as the “new file”. Page 3 – BATES 

CITY-KLUP_004314 

 

13 Glassco Testimony, P544 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 327 of 433 PageID #:15748
7 

confessed to avoid further abuse. His beating by the police was litigated in a motion to suppress, 

which the criminal court granted.14

MR. STOIOFF: Is the Court passing on the credibility of the officers visa vie (sic) their 

saying they did not beat him? 

THE COURT: Of course. It is obvious the defendant was mistreated by the police. 

Kluppelberg’s then girlfriend, Dawn Gramont (age 18 at the time of the fatality fire), was 

also taken into custody by the police. She informed them that Kluppelberg could not have 

started the fatal fire, because he was with her at the time. However, after continued police 

interrogation (which she claimed included physical assault) she then allegedly volunteered a 

statement implicating Kluppelberg in the fire. 

In January of 1988, Kluppelberg was charged with arson and 6 counts of murder. In 

November of 1988, as noted above, Kluppelberg’s alleged confession was suppressed by a Cook 

County judge based on objective medical evidence of serious injury to Kluppelberg believed to 

be caused by CPD investigators at the time of his interrogation. The judge noted that there was 

bruising around Kluppelberg’s kidney area and that he was urinating blood when he was 

screened at the jail after his police interrogation. The judge concluded that Kluppelberg had 

been beaten by police and that his confession was coerced.15

In January 1989, Kluppelberg was placed on trial. The prosecution asked for the death 

penalty. In July 1989, a Cook County Circuit Judge Loretta Hall Morgan found him guilty in the 

non-jury trial. At sentencing in March 1990, Judge Morgan rejected the prosecution’s request 

for the death penalty, but did sentence him to life in prison without parole. 

After unsuccessful appeals Kluppelberg filed a post-conviction petition in May 2008, 

based on a significant disclosure of new evidence, both scientific, objective, and witness related. 

Over the next 3 years, attorneys for Kluppelberg worked within the courts for his exoneration. 

The State’s Attorney continued to resist these efforts, but finally in May 2012 they declared that 

they did not feel that they could meet the burden of proof against Kluppelberg. A Cook County 

Circuit Court Judge then vacated the convictions and the charges were dismissed. 

At the end of May 2012, after nearly 25 years in prison, Kluppelberg was released. In 

August 2013 Kluppelberg was granted a “Certificate of Innocence” by Judge Michael Hale. 

In my experience, neither prosecutors nor criminal courts judges lightly vacate homicide 

convictions or enter declarations that a previously convicted murderer is in fact completely 

innocent of the crimes for which he had been convicted. 



14 Motion to suppress findings (P000221) 11/15/1988 

15 Ibid 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 328 of 433 PageID #:15749
8 

B. Detailed Timeline and Overview of Individuals Involved in Case 

On March 23, 1984 there was a fire in the area of 4504 South Marshfield Avenue. The 

fire began at approximately 3:45 pm, and continued sporadically through the afternoon, evening, 

and into the following early morning hours. The suspect in the fire at 4504 S. Marshfield, Isabel 

Ramos, was not arrested by police until 10:15 am on the morning of March 24, 1988. 

On March 23, 1984 there was an arson fire at 1840 West 46th Street. The suspect in this 

fire was identified as Steven Slepawic. This fire was reported at approximately 11:15 pm. 

Both the “Ramos” fires and the “Slepawic” fire were within a few blocks of the 

Lupercio/Hermitage fire. 

CPD patrol officers Bakanski and McGuire and others began producing the initial 

reports16 related to the Lupercio/Hermitage fire on March 24, 1984 at 4:00 am. That initial 

report as well as companion reports generated and included in the “permanent retention file” 

provided detailed lists of those governmental (police, fire, medical examiner, etc.) officials 

present during the response and immediate investigation efforts. It should be noted that nowhere 

in the detailed lists do the names of fire officials William Alletto or Frances Burns (defendants) 

appear. Deputy Fire Commissioner Alltman is listed as the fire official in charge17. Detectives 

(defendants) George Jenkins, John Nelson, and Lawrence Tuider are listed.18

A death investigation report19 of the Lupercio/Hermitage fire was prepared by CPD 

Bomb and Arson detective George Jenkins on March 25, 1984. In his report he stated while 

doing a canvas of the fire location, “a citizen” had informed him that an individual in the crowd 

watching the fire was overheard to say that he had been involved in starting the fire. The 

“citizen” told Jenkins that the person was Richard Shields (age 13). Detective Jenkins, along 

with detective John Nelson later interviewed Shields and his mother at the 9th precinct. The 

detectives determined that what Shields had actually said was related to earlier television reports 

describing a woman running around in the area of the fire with a gasoline can. No further steps 

were taken and the detectives indicated that they had no other investigative leads and requested 

that the investigation be reassigned to another watch. 

Another report was prepared by CPD Bomb and Arson detective Kenneth Urbon on a 

CPD Bureau of Investigative Services form submitted on March 26, 1984.20 In this report Urbon 

stated that due to the extensive burning and collapse of the building the cause and origin of the 

fire could not be determined. He went on to state that there was no indication of an extremely 

hot fire since there was no beading to the copper wires in the building. The building owner was 

interviewed and he stated that he had never had any problems with any of the tenants and that to 

his knowledge no one in the building was having any problems, and knew of no reason why 

anyone would want to set fire to the building. Urbon’s investigative partner was Dennis Guest. 



16 CPD Reports - #F-105-510 (CITY-KLUP_000539-548) 

17 CPD Bomb and Arson Supplementary Report #F-105-510 (CITY-KLUP_000550) 

18 Ibid, (CITY-KLUP_000550) 

19 Ibid, (CITY-KLUP_000551-552) 

20 CPD Bureau of Investigative Services (CITY-KLUP_000553-000556) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 329 of 433 PageID #:15750
9 

An additional supplementary report21 was prepared on April 4, 1984 by CPD Bomb and 

Arson detective E. O’Donnell. In the report, O’Donnell indicates that 2 separate tips had been 

received. One anonymous caller claimed that the person responsible for the Lupercio/Hermitage 

fire was a Ricardo Rodriguez, a “Streets” gang member. Rodriguez agreed to take a polygraph 

examination. The examiner determined that Rodriguez was not responsible and had no 

knowledge of the fire. The other anonymous tip was received through the CPD “We-Tip” 

program and claimed that the person responsible was a James Kluppelberg.22 Kluppelberg was 

also picked up but claimed he had nothing to do with the fire and was in a nearby home with his 

girlfriend, Dawn Gramont. O’Donnell reported that although Kluppelberg refused to take a 

polygraph, Gramont confirmed that he had been home with her at the time of the 

Lupercio/Hermitage fire. O’Donnell closed his report with the statement “At this time there is 

not any evidence to indicate that either Ricardo Rodriguez or James Kluppelberg was responsible 

for the (Lupercio/Hermitage) fire.” 

Another supplementary report23 was written by Officer David Allen on April 10, 1984. 

He was dispatched to Holy Cross Church to recover an anonymous threatening letter that had 

been sent to Oscar Siller, a surviving victim of the Lupercio/Hermitage fire. The unsigned letter, 

written in Spanish, had a Chicago postmark. The letter writer claimed that Siller was responsible 

for the fire and that he would be both dead and turned into immigration. 

A supplementary report24 of the Lupercio/Hermitage fire was also prepared by CPD Area 

3 Violent Crime detective Lawrence Tuider on April 13, 1984. The report category is checked as 

“non-criminal” and reviews the investigatory steps taken, including examination of the scene, 

CPD laboratory evidentiary test results, medical examiner’s reports, interviews with fire and 

police involved, etc. The report concluded that there was no evidence in the laboratory results of 

any type of accelerant25, no evidence of arson, and that on scene CPD bomb and arson 

investigators had no idea as to the cause of the fire. A canvas of the neighborhood had been 

done, and there were no indication of foul play. Detective Tuider requested that the case be 

classified as “closed, apparent accidental fire deaths.” The report was approved on April 14, 

1984 by a Sergeant Owen. 

In December 1987, Glassco spoke with police about the 4448 S. Hermitage fire, 

approximately three and a half years after it occurred. He was in jail, facing charges. 

In January of 1988, detectives Rolston and Schmitz brought Kluppelberg into the police 

station for questioning about the 4448 S. Hermitage fire. He had been working at a security 

guard at the time and had reported two car fires at work. He was brought to the station 

purportedly to be interviewed about those fires. After he was brought to the station, Kluppelberg 

alleges that he was beaten and forced into providing a false confession to the arson-murder. 



21 CPD Supplementary Report to #F-105-510 dated 4/4/1984 (CITY-KLUP_000557-559) 

22

23 CPD Supplementary Report to #F-105-510 dated 4/10/1984 (CITY-KLUP_000560-561) 

24 CPD Supplementary Report to #F-105-510 dated 4/13/1984 (CITY-KLUP_000562-564) 

25 CPD #F-105-510 (CITY-KLUP_004367) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 330 of 433 PageID #:15751
10 

On January 27, 1988 detectives Rolston and Schmitz produced a supplementary report26

that stated that James Kluppelberg had been indicted by the Cook County Grand Jury for 18 

Counts of Murder, 7 Counts of Attempted Murder, and 3 Counts of Arson for the 

Lupercio/Hermitage fire. An arrest warrant was issued for Kluppelberg on the charges and the 

warrant was delivered to the Cook County Jail where Kluppelberg was currently being held. 

On January 29, 1988 detectives Foley and Kelly produced another supplementary report27

that served to conclude the investigative efforts of the CPD in the Lupercio/Hermitage fire. The 

report lists detectives Foley, Kelly, Rolston, Schmitz, J. Smith, and J. Rusnak as arresting 

officers. The report lists CFD Battalion Chief William Alletto and CFD Deputy Chief Frances 

Burns (both of the Office of Fire Investigations) as having been interviewed. The report also 

indicates that an “oral statement” was taken from Kluppelberg, and that both oral and written 

statements were taken from Gramont and Glassco. The detectives stated that when they 

originally attempted to interview Kluppelberg, he had spoken with a lawyer and refused to talk 

with the detectives. Foley and Kelly claim in their report that they “had occasion” to attend a 

meeting (no date given) with ASA Warnick, ASA Rather, detectives Rolston and Schmitz. 

Foley and Kelly claim that as a result of that meeting they “had occasion” to interview fire 

officials Alletto and Burns. Alletto and Burns orally claimed that on the night of the 

Lupercio/Hermitage fire they conducted their own investigation (to which they were neither 

assigned nor authorized) and had concluded (but never reported to anyone) that the 

Lupercio/Hermitage fire was an incendiary arson fire. Foley and Kelly also included oral 

statements attributed to Gramont and Glassco that they knew, or should have known, to be false. 

They concluded their report stating that the case was “Cleared and Closed”. 

On March 24, 1988 Area 3 Violent Crimes detectives Thomas Ptak and Michael Duffin 

produced a supplementary report28 claiming remarks made by Kluppelberg while they were 

doing an in-custody transport of Kluppelberg. The alleged remarks had no objective relationship 

to the Lupercio/Hermitage fire, but appeared to have been solicited in an attempt to enhance the 

case against Kluppelberg. 

On February 2, 1989 detectives Foley and Kelly produced yet another supplementary 

report29 claiming that they had been contacted by Thomas Brittain and that he had additional 

information regarding Kluppelberg’s involvement in the Lupercio/Hermitage fire. Thomas 

Brittain claimed that he had been in the Cook County Jail with Kluppelberg sometime in March 

of 1988, and that while Brittain, Kluppelberg, another unknown male, and a 4th man (only 

described as Hispanic) were sharing a cell, the Hispanic man had a newspaper clipping about the 

Lupercio/Hermitage fire and he asked Kluppelberg if he had done it. According to Brittain’s 

alleged story, Kluppelberg denied any involvement, but when the other 2 men left the cell, 

Kluppelberg stated that he started the Lupercio/Hermitage fire by accident and also claimed 

responsibility for the 2 car fires while he was a security guard. It should be noted that Brittain 

never provided this information to the detectives earlier, and that the detectives never obtained 

any type of written or recorded statement from Brittain. 



26 CPD Supplementary Report to #F-105-510 dated 1/27/1988 (CITY-KLUP_000575) 

27 CPD Supplementary Report to #F-105-510 dated 1/29/1988 (CITY-KLUP_000576-582) 

28 CPD Supplementary Report to #F-105-510 dated 3/24/1988 (CITY-KLUP_000583-584) 

29 CPD Supplementary Report to #F-105-510 dated 2/2/1989 (CITY-KLUP_000585-586) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 331 of 433 PageID #:15752
11 

C. The New File 

In August 2014, the City produced a New File. That New File was not disclosed to the 

prosecutor prior to Kluppelberg’s criminal trial and therefore was not disclosed to Kluppelberg 

either.30

 The New File was the original Area 3 1984 Investigative File for the investigation into 

the fire and deaths at 4448 S. Hermitage. 

 The New File contains significant material not in the permanent retention file or in the 

1988 Area 3 Investigative File. For example, it includes an unsigned and undated handwritten 

investigative note31, in which a neighbor (Minerva Harast) living at 4452 South Hermitage 

Avenue stated that the Lupercio/Hermitage building had “extension cords all over basement floor 

in home where fire had killed the people – used to get hot when it rained – people last lived in 

the basement about 2 months ago”. In a continuation of the investigative note32, a resident of the 

Lupercio building (Oralya Siller) was quoted as saying “thinks fire stated [sic] in basement, 

doesn’t know how”. 

Also in the New File, there was, on an interview form,33 a note was made by an officer 

(signature unreadable, possibly star #7699 or #7649), that an unnamed individual identified Nain 

Saadeh as possibly having had an argument with one of the Lupercio/Hermitage fire victims. On 

another interview form,34 a note was made by apparently the same officer, that an unnamed 

individual identified Abda Kater as possibly having had an argument with one of the 

Lupercio/Hermitage fire victims. Yet another interview form35 was produced by a sergeant (star 

#1347), indicating that an unknown Arab youth had created friction between his family and the 

Siller family. 

The New File also contained information about an additional possible suspect36 identified 

as Steven M. Slepawic. He was arrested for an arson fire which occurred at 1840 West 46th

Street at about the same time and just a few blocks from the Lupercio/Hermitage fire. 

Finally, the New File contained information about Isabel Ramos. Specifically, the New 

File contains an internal memo, sometimes referred to as a “to-from,” from Detectives Smith and 

Brankin to Detectives Tuider and McKinley giving an update on their efforts to gather 

information about Isabel Ramos.37 Other documents in the New File indicate that Area Three 

detectives interviewed Ramos about the 4448 S. Hermitage fire, and demonstrated that she was a 

suspect in that fire who in total had been interviewed at least two times by the Chicago Police 

Department. 



30 City’s Resp. to Plaintiff’s Third Set of Request to Admit Nos. 4, 8, 12, 16, 20, 24, 28, 32, 36, 40, 44, 48, 52, 56, 

60, 64. 

31 New File, (CITY-KLUP_004329) 

32 Ibid, (CITY-KLUP_004330) 

33 Ibid, (CITY-KLUP_004347) 

34 Ibid, (CITY-KLUP_004350) 

35 Ibid, (CITY-KLUP_004354) 

36 Ibid, (CITY-KLUP_004355-4356) 

37 Smith Dep 50-51, 99 -100. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 332 of 433 PageID #:15753
12 

D. James Kluppelberg (age 18 at time of Lupercio/Hermitage fire) 

Over 3 and a half years after the Lupercio/Hermitage fire, James Kluppelberg was 

working as a security guard in Chicago. He reported38 2 separate car fires to the CPD in 

December of 1987. Kluppelberg was later arrested and charged with 2 counts of arson in 

connection with these car fires. Detectives Leonard Rolston and John Schmitz completed a 

Bomb and Arson Worksheet report39 on January 12, 1988. 

Subsequently, detectives Leonard Rolston and John Schmitz produced a report40 on 

January 13, 1988 claiming that while they had Kluppelberg in their custody they obtained a 

verbal statement of guilt from him related to the Lupercio/Hermitage fire. Although the report 

does not specifically give the date of Kluppelberg’s alleged oral statement, the report indicates 

that Kluppelberg repeated his statement to ASA Larry Axelrood on January 12, 1988. The 

detective’s report of Kluppelberg’s “confession” consisted entirely of a 25 line, 1 paragraph 

“verbatim” recounting of his alleged oral statement. A copy of the report was routed to Area 3 

Violent Crimes detectives. The supplementary report also claims that an anonymous tip had 

been received in 1984 that Kluppelberg was responsible for the Lupercio/Hermitage fire.41

However, Kluppelberg claims that during his interrogation he was severely beaten while 

he was handcuffed with his hands behind his back.42 Kluppelberg claims that Rolston and 

Schmitz threw him to the floor and punched him in the back and kicked him in the kidney area. 

Kluppelberg claims that the detectives threatened to continue their assault on him unless he 

confessed. He claims to avoid any further beating, he falsely confessed. 

In addition to his own sworn testimony43, support for Kluppelberg’s claim of being 

beaten comes from corrections officer Francis Huber44, attorney Marshall Weinberg45, and exwife Bonnie Hileman.46 This is further supported by the finding of Judge Robert Collins in the 

ruling47 to suppress made by Kluppelberg to the police based on the mistreatment of him by the 

police. 

After the supposedly “voluntary” confession obtained by Rolston and Schmitz, 

Kluppelberg was processed at the jail for his arrest related to the Lupercio/Hermitage fire. While 

in the jail, Kluppelberg was found doubled over and urinating blood. The doctor that treated him 

diagnosed him with trauma and a hematoma to his lower back and kidneys.48 This information 



38 CPD RD’s #J 545-732 and J 545-864 referenced in CPD Bomb and Arson Worksheet Report #F-105-510, dated 

1/12/1988 (CITY-KLUP_000587) and CPD Supplementary Report #F-105-510 dated 1/13/1988 (CITYKLUP_000608) 

39 CPD Bomb and Arson Worksheet Report to #J 545-732; #J 545-864; #F-105-510, dated 1/12/1988 (CITYKLUP_000587) 

40 CPD Supplementary Report to #F-105-510 dated 4/13/1984 (CITY-KLUP_000565-566) 

41

42 James Kluppelberg deposition (3/31/15), page 83 

43 James Kluppelberg motion to suppress testimony (P186-199) 

44 Francis Gerard Huber motion to suppress testimony (P157-161) and Deposition at 85-88 on 4/29/2015 

45 Marshall Weinberg motion to suppress testimony (P161-174) and deposition at 74-86 and 102-104 on 5/20/2015 46 Bonnie Hileman (Kluppelberg) motion to suppress testimony (P174-182) and deposition at 59-61 on 5/14/2015 47 Motion to suppress findings (P000221) 11/15/1988 

48 Cook County Jail medical record (CITY-KLUP_3289-3290) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 333 of 433 PageID #:15754
13 

was presented at his motion to suppress, which led the court to exclude his so-called 

“confession”. 

On January 18, 1988, detectives Rolston and Schmitz submitted another supplementary 

report49 indicating that they had been directed (no date or time of request shown) by ASA Jeff 

Warnick, the head of the special prosecutions arson unit, to interview 15 additional individuals, 

in particular the 5 individuals that were supposed to be in the apartment located at 1748 West 

45th Street on the night of the Lupercio/Hermitage fire. Those 5 individuals were 1) James 

Kluppelberg; 2) Duane Glassco; 3) Dawn Gramont; 4) Michel Brittain; and 5) Don Brittain. The 

other 10 were either individuals that lived near the scene of the fire, individuals that had known 

Kluppelberg, his ex-wife, his mother, and employer, etc. It is apparent from reading the 5-page 

report that the information sought by ASA Warnick flowed from information provided to him by 

either/or both detectives (Rolston and Schmitz). None of the interviews were recorded in any 

manner, and were provided directly by the detectives in their report. The detectives claimed that 

they were all obtained at separate times and locations, but no times or locations were included in 

the report. 

Kluppelberg's alleged oral and unrecorded statement contained glaring factual errors that 

could not have been true and/or conflicted with objective facts, known information, and other’s 

statements. For example, Kluppelberg’s scenario of how the fire started – in the living room 

with a bunch of papers – is physically impossible as demonstrated by Dr. Ogle.50 In addition, 

Santos Lupercio testified that the back door to the first floor apartment was locked on the night 

of the fire, and there is nothing in Kluppelberg’s confession to explain how he was able to open a 

locked door.51 

E. Duane Glassco (age 19 at time of Lupercio/Hermitage fire) 

On the night of the Lupercio/Hermitage fire, Duane Glassco was visiting with Dawn 

Gramont and James Kluppelberg in their apartment located at 1748 West 45th Street. He 

acknowledged that he had been drinking and had taken drugs. He was interviewed during the 

1984 investigation of the fire, but at no time did he implicate James Kluppelberg as being 

involved in the fire. James Kluppelberg did not participate in taking drugs or alcohol.52

As stated earlier, in November of 1987 Glassco was arrested by CPD for burglary, theft, 

and violation of probation. According to his trial testimony, in December 1987 Glassco 

allegedly volunteered a statement that he had information that James Kluppelberg had been 

responsible for starting the Lupercio/Hermitage fire. 

Glassco subsequently recanted his statements and gave a sworn affidavit stating that he 

had not seen Kluppelberg coming and going from the Lupercio/Hermitage building. He also 

stated that it would have been impossible to see the building from his attic apartment because 



49 CPD Supplementary Report to #F-105-510 dated 1/18/1988 (CITY-KLUP_000567-571) 

50 Dr. Russell Ogle Expert Report (08/03/2015) pages 17-18; Dr. Russell Ogle Expert Report (5/23/08) at pages 6-7. 

51 Santos Lupercio Deposition (05/15/2015) pages 34-35 52 Kluppelberg Dep 340-41; Michelle Brittain Dep. 16-17; JGS 723- July 9, 2013: Kluppelberg COI testimony 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 334 of 433 PageID #:15755
14 

another building stood in the way. Aerial photographs confirmed that his original claim of what 

he saw would have been impossible. 

Glassco also later admitted that Kluppelberg had never said that he had set the fire and 

that Glassco agreed to implicate Kluppelberg to escape prison time on the charges he was facing 

at the time.53 He also said he was angry at Kluppelberg at the time because he had begun dating 

Glassco’s former girlfriend. 

Glassco lied during Kluppelberg’s trial. Some specific examples include: 

x Testimony of Charles Petrosus at motion for new trial54 details the relative sizes of 

dwellings relative to the Lupercio/Hermitage fire. Establishes that Glassco could not 

have observed anyone (including Kluppelberg) from the attic window. 

x Testimony of Ronald Cerevic at motion for new trial55 details that Glassco could not 

have observed anyone (including Kluppelberg) from the attic window. 

x Testimony of Dawn Gramont at motion for new trial56 details that the attic window 

was actually boarded up at the time of the Lupercio/Hermitage fire. 

x Aerial photos57 of buildings in and around the Lupercio/Hermitage fire demonstrate 

Glassco’s inability to see what he claimed to have seen from the attic window. 

x Testimony of Duane Glassco58 himself, including acknowledgement59 to an Assistant 

State’s Attorney that aerial photographs indicated that he could not have seen what he 

claimed to have seen from the attic window. Similar admissions were contained in a 

subsequent interview60 with the same Assistant State’s Attorney. 

Glassco’s original statement given to Foley and Kelly (as well as the ASAs) contained 

glaring factual errors that could not have been true and/or conflicted with objective facts, known 

information, and other’s statements. 

During his deposition in this litigation, Glassco recanted his recantation and went back to 

his original trial testimony. That testimony, however, is implausible for the reasons identified 

above; namely, that he could not have seen what he said he saw from the attic window. 

F. Dawn Gramont (age 18 at time of Lupercio/Hermitage fire) 

After Kluppelberg was taken to the police station initially and interrogated about the 

4448 S. Hermitage fire, detectives Rolston and Schmitz interviewed his one-time girlfriend, 

Dawn Gramont. According to their brief summary of her statements, she told them that she and 

Kluppelberg had a fight and that she observed him leaving the house, “shut[ing] off” the street 

lights, and then returning home and saying there was a fire.61 



53 Affidavit of Duane Glassco 5/17/2008 Exhibit 02 

54 Motion for new trial (P607-830) 3/16/1990, pages 731-762 

55 Ibid, pages 776-777 

56 Ibid, pages 792-794 

57 Glassco deposition exhibits 3 and 4 

58 Affidavit of Duane Glassco 5/17/2008 Exhibit 01 

59 Branigan Investigative Report - Exhibit 05 (P5825-5827) 6/23/2010 page 2 

60 Branigan Investigative Report - Exhibit 06 (P5823-5824) 9/13/2010 pages 2-3 

61 CPD Supplementary Report to #F-105-510 dated 1/18/1988 (CITY-KLUP_000567-571) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 335 of 433 PageID #:15756
15 

About a week and a half after Kluppelberg’s arrest by Rolston and Schmitz, Gramont was 

interviewed again, this time by Area 3 Violent Crimes detectives William Foley and William 

Kelly. The “interview” does not indicate the actual date of the interview. 

the interview apparently took place on January 22, 1988. 

The detectives memorialized an oral statement allegedly made by her in a CPD Supplementary 

Report63 with a submittal date of January 24, 1988. A copy of the report was routed to Bomb 

and Arson investigator Leonard Rolston. The 3-page report claims that the detectives (Foley and 

Kelley) had “re-interviewed” Gramont, and “...after apprising her of the facts and circumstances 

of this investigation...” she allegedly claimed that she had not originally told all of the facts and 

that she now wanted to tell everything. In the report, the detectives claim that Gramont 

described knowledge of Kluppelberg’s involvement in the Lupercio/Hermitage fire. The report 

goes on to say that after the interview Gramont was taken to the office of ASA Bruce Rather 

(assigned to Bomb and Arson cases), and that she was then taken to testify in front of a grand 

jury. The detectives did not prepare and/or produce any signed written statement by Gramont. 

Gramont’s alleged oral and unrecorded statement given to Foley and Kelly (as well as the 

ASA’s) contained glaring factual errors that could not have been true and/or conflicted with 

objective facts, known information, and other's statements. 

 

 

 

 



62

63 CPD Supplementary Report to #F-105-510 dated 1/24/1988 (JGS 3216) 

64

 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 336 of 433 PageID #:15757
16 

 

.

67

There are also other supporting references to corroborate that Gramont was coerced: 

x Her testimony68 at trial refuting her grand jury testimony; 

x Her explanation69 of the circumstances relating to her grand jury testimony; 

x Her testimony70 regarding her OPS complaint; 

x Bonnie Hileman deposition71 testimony; 

x Her original statement to police, during the 1984 interview, which did not implicate 

James Kluppelberg in the fire; 

x

 

From the time of initially learning of Gramont’s claim that she had been forced to lie in 

front of the grand jury, 

 

 

 



 2 

68 Transcript of Kluppelberg’s trial dated 7/14/1989 (PL448-454) 

69 Ibid, (P475-477) 

70 Ibid, (P477) 

71 Bonnie Hileman deposition 5/14/2015, pages 83-86 

 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 337 of 433 PageID #:15758
17 

G. Donald Brittain (age 14 at time of Lupercio/Hermitage fire) 

Detectives claim that Donald Brittain stated that he was with the Kluppelberg, Gramont, 

Glassco, and his sister, Michelle Brittain on the night of the fire, and that during that night 

Kluppelberg left the apartment once or twice and that he was carrying pliers. He couldn't 

remember if the streetlights were out, however. He remembered that Dawn Gramont and 

Kluppelberg had an argument earlier in the evening and said they were throwing pots and pans at 

each other. He stated that after Kluppelberg entered the apartment, he waited about 10 minutes 

and walked to the kitchen window and pulled back the curtains telling everyone “there's a fire”. 

He confirmed that he and the other men assisted Gramont's landlord out of his building. 

Donald Brittain was listed as a person to be interviewed in the supplementary report76

that detectives Foley and Kelly produced to document their interview with Gramont. 

Donald Brittain did not testify at Kluppelberg’s criminal trial. 

H. Michelle Brittain (age 17 at time of Lupercio/Hermitage fire) 

Detectives claim that Michelle Brittain stated that she was with Kluppelberg, Gramont, 

Glassco, and her brother, Donald Brittain on the night of the fire. According to the detectives’ 

version, she remembered Kluppelberg leaving the apartment and then later returning. A few 

minutes later, she heard fire engines. Kluppelberg told the group that there was a fire. She stated 

that she immediately looked outside and observed a fire at 4448 South Hermitage with flames at 

least 20 feet high. Michelle stated to Kluppelberg “you act like you started that fire”, and 

Kluppelberg just smiled at her. She stated that she did not remember whether the streetlights 

were off or on. She stated that the fire was just too big for someone to have come into the house 

without seeing it. She also stated that on the night of the fire she thinks Kluppelberg tried to get 

some board-up business. 

At her deposition, however, Michelle Brittain testified that she had no information that 

Kluppelberg had ever set the fire at Hermitage and he had never told her that he had set the 

fire.77 She further denied that she ever spoke to Kluppelberg about the fire or saw him smiling 

when discussing the fire.78 She also expressly disavowed ever telling the police that: (a) 

Kluppelberg started the fire; (b) that she ever said to Kluppelberg that “you act like you started 

that fire;” (c) that Kluppelberg smiled at her when she said that; and (d) that she saw 

Kluppelberg trying to get some board up business that night.79 Michelle Brittain said that when 

she spoke to the police about the fire they told her that Kluppelberg had been in jail before for 

starting fires and that Kluppelberg was responsible for the Hermitage fire.80

As such, Michelle Brittain’s statement given to Foley and Kelly contained glaring factual 



76

77 Michelle Brittain Deposition (01/14/2015) page 7. 

78 Ibid 37, 39, 42 

79 Ibid 50-52, 55-57. 

80 Ibid 52-53. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 338 of 433 PageID #:15759
18 

errors that were not true and/or conflicted with objective facts, known information, and others’ 

statements. 

I. Battalion Chief William Alletto and Deputy Chief Frances Burns 

Alletto and Burns related that they had occasion to conduct an investigation into the 

cause and origin of the fire that occurred at 448 South Hermitage Street on March 24, 1984.81 

They claimed that their investigation revealed that the fire was an incendiary fire and that this 

was evidenced by the volume and intensity of the fire, as well as the burn patterns found at the 

scene. The also stated that they eliminated any other cause of the fire and that the absence of any 

fire load and the volume and intensity and speed of the fire led then to the conclusion that this 

was an incendiary fire, arson. In conclusion they related that they were of the opinion that the 

point of origin was the rear 2/3rds of the first floor of the building located at 4448 So Hermitage 

Street. Alletto and Burns then turned over to the detectives a series of photographs taken the day 

of the fire, these photographs were of the scene and the victims as they appeared on the date of 

this incident. 

Although the CPD Bomb and Arson investigation had clearly stated that the fatality fire 

did not indicate the presence of an accelerant82, and because of the total destruction of the 

building no cause could be determined, questionable and unscientific statements were garnered 

from 2 fire officials (William Alletto and Frances Burns). Neither Alletto nor Burns were 

actually assigned to the fatality fire at the time. Nonetheless, they both provided oral statements 

4 years later that claimed that they had observed burn patterns and that the fatality fire was the 

result of arson. 

II. Background on City’s File Creation, Maintenance and Preservation Policies 

A. Organization of Chicago Police Department in the 1980s 

In 1980, the Bureau of Investigative Services in the CPD was reorganized.83 The Bureau 

of Investigative Services housed the Detective Division (in addition to Organized Crime, Youth 

Division and an administrative section).84 

As a result of the reorganization, the Detective Division was now split into six 

geographical areas (Areas One through Six) and two subject matters (i.e., Violent Crimes, 

Property Crimes).85 The geographical areas were consolidated into two Field Groups: Field 

Group South consisted of Areas 1, 2 and 3 and Field Group North consisted of Areas 4, 5 and 

6.86



81 CPD Supplementary Report to #F-105-510 dated 1/29/1988 (CITY-KLUP_000576-582) 

82 CPD #F-105-510 (CITY-KLUP_004367) 

83 Hickey 64. Unless otherwise noted, all references to Hickey are to his July 2014 deposition. 84 City Klup 2208 

85 Brezcek Test. P4530-31 

86 City Klup 2205-08 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 339 of 433 PageID #:15760
19 

From January 1981 through 1988, the Bureau of Investigative Services was headed by a 

Deputy Superintendent.87 The Detective Division was headed by a Chief; each Field Group was 

headed by a Deputy Chief; and each Area was headed by an Area Commander.88 

In addition to the two Field Groups, the Detective Division also included a Special 

Activities Group. A Deputy Chief was in charge of Special Activities. Special Activities 

included Bomb & Arson, which was headed by a Commander.89 

B. Street Files 

1. Definition/Usage: 

“Street files” – also referred to as “working files,” “running files” or even “unit files” – 

were separate investigative files maintained by detectives in each area.90 Street files were 

considered the personal property of the detectives working on the case. There was no formal 

place to keep a street file: some would be kept on tables, coat racks and some in filing cabinets or 

desk drawers.91 

Street files were used by detectives to communicate steps taken, steps to be taken and the 

personal opinions of one detective to another.92 The files contained notes, memos and bits of 

information on the case.93 The files also contained “other Case and Supplementary Reports 

pertaining to non-related cases which are utilized in suspect elimination and identification.”94

Finally, the files contained victims’ personal papers (e.g., a telephone book) or messages (e.g., 

telephone messages).95

The City’s witness, James K. Hickey, testified that the practice of using working files 

existed at least since 1977 when he arrived at Area 1 homicide in August 1977.96 Similarly, John 

Stibich testified at the Palmer hearing that when he was a commanding officer in Area 4 (from 

December 1974 to December 1977), Area 4 homicide had a practice of creating and using a 

working file.97 Following Hickey’s sampling of the various violent crimes units in 1982, Hickey 

determined that each of the Area violent crimes units used street files.98



87 Hickey 49 

88 City Klup 2208 

89 Hickey 49; City Klup 2208 

90 Brady & Tolliver, P2458; Stibich Test. P4463 

91 Brady & Tolliver, P2458; Hickey 112 

92 Brady & Tolliver, P2458; Stibich Memo, P2455-56; Hickey 196-197, 214-18 

93 Brady & Tolliver, P2458-59; Stibich Memo, P2455-56; Stibich Test. P4499-4500; Hickey 163, 214-18 

94 Brady & Tolliver, P2459; Stibich Memo, P2455-56, Hickey, 164-66, 214-18 

95 Brady & Tolliver, P2459; Hickey 195 96 Hickey 187 

97 Stibich Test. P4460-65 

98 Hickey 187, 219-20 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 340 of 433 PageID #:15761
20 

2. The George Jones Prosecution 

In 1981, 12 year-old Sheila Pointer was raped and bludgeoned to death; her 10 year-old 

brother Purvy was beaten unconscious in their homes.99 George Jones – a senior at a nearby 

high school, editor of the school newspaper and nicknamed “Bookworm” – was ultimately 

arrested and prosecuted for the crime. During the CPD investigation of the Pointer murder, 

detectives learned numerous pieces of information that would have been exculpatory or 

impeaching of witnesses accusing Jones but each of which was placed in the street file and not 

disclosed to the prosecutor.100 

In particular, one detective, Frank Laverty, documented information including that (1) 

Purvy told him there were two assailants and both were wearing stocking masks and (2) that 

there was strong evidence that someone other than Jones committed the crime.101 Laverty had 

thought that the prosecution of Jones had been abandoned but in the Spring of 1992, Laverty 

read about it in the newspaper.102 Laverty went to his Commander to tell him that an innocent 

person was being prosecuted, but got no response. He then went directly to Jones’ criminal 

defense attorney and told the attorney about the street file. The State’s Attorney then dropped all 

charges against Jones.103 Rather than commend Laverty, he was charged with a disciplinary 

infraction for failing to advise the State’s Attorney that he was going to testify for the defense, 

transferred out of the detective division, ostracized by his peers and given a series of menial 

tasks. 

After the charges against him were dismissed, Jones filed a civil lawsuit. He was awarded 

a substantial amount in damages for the violation of his rights. Notably, among other things, the 

jury found that the City was liable to Jones for its custom of maintaining “street files” that were 

withheld from the State’s Attorney and therefore unavailable as a source of exculpatory 

information.104 

3. The Palmer Litigation 

On April 16, 1982, shortly after Jones’ prosecution, plaintiffs filed a class action seeking 

to prevent the use of street files.105 Immediately following the filing, the plaintiffs moved for a 

temporary restraining order (TRO). A TRO was issued on April 20, 1982 and then amended on 

September 24, 1982 to require CPD to preserve all street files and documents formerly placed in 

street files.106 The TRO was amended after allegations arose that the detectives were violating 



99 Jones v. City of Chicago, 856 F.2d 985, 988 (7th Circuit 1988) 100 Ibid (at 988-991) 101 Ibid (at 990-91) 102 Ibid (at 991) 103 Ibid. (at 991) 104 Ibid. (at 995-96). 105 Palmer v. City of Chicago, No. 82 C 2349 at P2648-69. 106 Ibid (at P2649-50) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 341 of 433 PageID #:15762
21 

the letter and spirit of the initial TRO by keeping investigative writings and files as their personal 

property and therefore not subject to CPD control.107 

Judge Shadur oversaw the preliminary injunction hearing. Judge Shadur found the 

following (among other things): 

x CPD has never provided its detectives or other personnel with guidelines as to the 

extent to which Official Reports (which Judge Shadur defined as case reports, 

supplementary reports, closing reports, etc.) had to embody information in 

Unofficial Reports (defined as notes, witness interviews, Major Crime 

Worksheets, memoranda, etc.). In particular, Judge Shadur found that “Official 

Reports have sometimes been prepared from the perspective of what fits the 

preparer’s concept of the crime, so they omit information that – though highly 

relevant and sometimes exculpatory of the defendant charged with the offense – 

the preparer does not deem ‘pertinent’”108 

x Existence of Unofficial Reports was well known throughout CPD. Files 

containing these Reports were referred to as “street files,” “running files,” “office 

files” or “working files.” 

x Not all potentially exculpatory information contained in the investigative 

materials is necessarily included in Official Reports. There has been and is no 

police rule, regulation, procedure or practice that specifically required all 

exculpatory information to be placed in Official Reports and transmitted to the 

Records Division for permanent retention.109 Nor was or is there a satisfactory 

procedure for monitoring whether all exculpatory information is transmitted to 

Central Records. 

x Prior to the Palmer litigation, the CPD responded to requests for documents as 

follows: 

o In response to a subpoena, CPD produced only Official Reports 

maintained at headquarters along with photographs and lab reports. CPD 

did not produce Unofficial Reports maintained at the Area or in the 

possession of individual detectives.110 

o In response to a defendant’s discovery motion, Assistant State’s Attorneys 

(ASAs) ordered by phone Official Reports. Records Division employees 

responded to these requests and made no effort to contact individual Areas 

or other units or divisions of the CPD for Unofficial Documents.111 

Judge Shadur ruled that the exclusion of potentially exculpatory information from 

Official Reports “was not random or infrequent.”112 In fact, by the City’s admission, there were 

over 300 street files at various Areas. Judge Shadur likewise found that the use of street files 

created a “grave risk” of non-disclosure of exculpatory information and granted the preliminary 

injunction. 



107 Ibid (P2650). 108 Ibid P2652-53 

109 Ibid P2655 110 Ibid P2657 111 Ibid P2657 112 Ibid P2658 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 342 of 433 PageID #:15763
22 

On appeal, the Seventh Circuit reversed Judge Shadur in part, although it did order the 

CPD to preserve and produce street files for those plaintiffs who had been convicted of 

felonies.113 It vacated the preliminary injunction in all other respects because the court either 

found that the plaintiffs lacked standing or should ask for relief in the state courts. It did not 

dispute the actual factual findings that Judge Shadur made. 

C. Chicago Police Department Response to the Problem of “Street Files” 

1. Teletype 

Immediately after the courts issued a TRO in the Palmer litigation, on April 20, 1982, the 

CPD issued a teletype.114 The teletype parroted the language of the TRO and stated that “the 

contents of all police department investigative files known as office, unit, or working files and 

sometimes referred to as ‘street or running’ files will be kept intact. No documents, materials, or 

notes shall be removed from these files.”115 As noted above, the Court later amended the 

language of the TRO when the plaintiffs claimed that detectives were maintaining investigative 

writings and files as their personal property to avoid the mandate of the TRO. 

2. Detective Division Notice 82-2 

 In addition, the CPD issued Detective Division Notice 82-2 on April 19, 1982.116 This 

was the first written directive to the CPD on the subject of working files and only went out to the 

Detective Division.117 As Hickey has explained, Notice 82-2 was “a quick and dirty document” 

designed to implement the TRO but was “not very workable”.118 The thrust of Notice 82-2 was 

preservation: it created a term called Unit Investigative File and mandated that Files had to be 

preserved. But Notice 82-2 was silent about what had to go into that File; it did not require 

detectives to put notes or memos into Unit Investigative Files; and it did not specify whether 

detectives had to preserve notes or memos that were not in the file.119 

In fact, Commander Stibich explained that it was the prevailing view that if a detective 

kept his own personal notes or memos – or considered those to be his personal property – then 

those notes or memos did not have to be put in the file and detectives could do whatever they 

wanted with those notes or memos, including destroying them. 120 Based on this and other 

testimony, Judge Shadur found that the CPD response to Notice 82-2 was to apply the TRO in 

“an improperly restrictive and grudging manner, under which detectives could consider their 

investigative writings as their personal property (and thus not ‘under Detective Division control’) 

and therefore outside the preservation requirements of Notice 82-2.”121 



113 Palmer v. City of Chicago, 755 F.2d 560 (7th Cir. 1985); Special Order 83-2A at City Klup 4884. 114 Hickey 201 115 P2454 116 P2450-52; Hickey 212 117 Hickey 212 118 Hickey 221, 224; Brzezcek Test. P4560 

119 P2450-52; Hickey 212-13 120 Stibich Test. P4511-13 121 P2658-59 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 343 of 433 PageID #:15764
23 

 3. Special Order 83-1 

 Detective Division Notice 82-2 was replaced by Special Order 83-1. Special Order 83-1 

applied only to Violent Crimes field investigations.122 According to Hickey, it covered Bomb 

and Arson was well as of January 13, 1983.123 Special Order 83-1 defined certain terms and 

created procedures for documenting and preserving documents relating to an investigation. 

Special Order 83-1 defined the term “Investigative File” and created something called an 

Investigative File Case Folder to secure documents relating to a criminal investigation. 

According to the terms of Special Order 83-1, an Investigative File Case Folder was to be 

created either when certain categories of violent crimes occurred or when a violent crime 

investigation resulted in an arrest and approval of felony charges.124 Special Order 83-1 also 

created an “Investigative File Inventory Sheet” to identify documents placed in the Investigative 

File.125 Serving as an index, the Inventory Sheet was to be forwarded to the Records Division 

anytime felony charges were lodged.126 Finally, Special Order 83-1 created General Progress 

Reports (“GPRs”).127 GPRs were to be used to write handwritten notes and memoranda. 

 Unlike Notice 82-2, Special Order 83-1 created an affirmative obligation for detectives to 

submit handwritten notes or investigative materials for review and inclusion in the investigative 

file. It also mandated that detectives transcribe relevant information previously recorded on a 

GPR, Major Incident Worksheet or other miscellaneous document on an official Department 

case report form (supplementary, general offense case reports).128

 In reviewing Special Order 83-1, Judge Shadur identified several deficiencies with the 

Special Order, including: 

x Unless the crime being investigated fit one of the categories identified in V(A)(1), a 

Violent Crime supervisor did not have to create an Investigative Case File Folder 

unless and until the offender was arrested and felony charges were approved. 

According to Judge Shadur, this continued to pose the same type of risk that 

information would not be retained and disclosed because there was nothing to prevent 

against selective retention he found.129 

x Special Order 83-1 did not provide any guidance or mandate that detectives record all 

relevant investigative information in V(B).130 

x Special Order 83-1 did not include information to ensure that any detective who has 

or receives information relating to a violent crime field investigation not assigned to 

him will forward the information to the assigned detective for investigation and 

inclusion in the Investigative File Case Folder131; and 



122 P2472-76 123 Hickey 224, 243 124 Special Order 83-1, V(A)(1) & (2) 125 Special Order 83-1 IV(D) 126 Special Order 83-1, IV(D) 127 Special Order IV(E); Hickey 170 128 Special Order V(B)(1) & (2), P2474-75 

129 P2663 130 P2663 131 P2664 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 344 of 433 PageID #:15765
24 

x Special Order 83-1 omits any provision defining the CPD’s duty or procedure in 

responding to a criminal subpoena or request by the State’s Attorney to produce 

information relating to a criminal proceeding.132

4. Special Order 83-2 

On May 2, 1982, Special Order 83-2 was issued. According to Hickey, Special Order 83-

2 was designed to “tighten up on the procedures [in Special Order 83-1] and actually improve it 

where possible.”133 Three of the changes in Special Order 83-2 were (1) a requirement that 

detectives create records reflecting all relevant information, V(B)(1); (2) a requirement that 

where a detective receives information about another crime, he or she pass that information 

along to the detective investigating that other crime, V(B)(6); and (3) that a copy of the 

Investigative File Inventory Sheet will be transmitted to either the Office of Legal Affairs (in 

case of a subpoena from a criminal defendant) or the State’s Attorney’s Office (in case of a 

discovery motion) so that one copy of the Inventory Sheet is disclosed to defense counsel in a 

criminal case, V(B)(6).134 Hickey also testified that one of the improvements of Special Order 

83-2 was the creation of an Investigative File Control Card, IV(F).135 This Control Card was 

supposed to act like a library card so that the Investigative File could be accounted for. 

While Special Order 83-2 clarified some issues left unaddressed by 83-1, there were still 

liabilities in the failure to mandate certain actions. For example, there is nothing in the language 

of Special Order 83-2 about the content of supplementary reports; that is, what information you 

have to include in a supplementary report beyond that which is “relevant.”136 Relevance, is of 

course, subjective and as Commander Stibich testified, what is relevant to one detective may not 

be relevant to another.137 In fact, Hickey testified that a detective would only have to put 

information in a supplemental report if the detective deemed it pertinent at the time that detective 

wrote the supplemental report – and not at the time that he received it.138

In addition, like its predecessors, Special Order 83-2 provided no guidance on how 

information should be communicated or documented when one detective learns something about 

a crime being investigated by another detective; or when one unit learns something about a crime 

that is also being investigated by another unit. While V(B)(6) codifies the obligation to 

“forward” information about a crime to the assigned detective, it does not require either detective 

– the detective passing along the information or the receiving detective – to create a document 

with the information.139 Relatedly, Hickey testified that CPD policy did not require suspects who 

had been eliminated through investigative activity to be documented in any way.140 Similarly, 

even where the detective passing along the information may have created a document 



132 P2664 133 Hickey 228 134 City_Klup_3149-53 135 Hickey 228-29 136 Hickey 238; Hickey [2015] 20 137 Stibich P4517 138 Hickey [2015] 24-25, 33 

139 Hickey 236-37 140 Hickey 237-38 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 345 of 433 PageID #:15766
25 

memorializing that information – e.g., a memorandum or GPR – there is no requirement in 

Special Order 83-2 that that memorandum or GPR be distributed to other detectives or units 

investigating that crime.141 

Finally, while the Investigative File Inventory Sheet is designed to be used as an index of 

documents in the file, that Sheet must be sent to records or distributed beyond the Area/Unit only 

if felony charges are placed IV(D); V(B)(6)). So in a case like Kluppelberg’s, even if the policy 

were followed, the inventory for the 1984 Area 3 investigative file would not have been sent to 

Records in 1984 (although one should have been sent in 1988). In addition, if the Inventories 

only have to be filled out and sent at the issuance of charges – as opposed to filled out 

contemporaneously – there is a risk that documents will be left off the inventories that the 

detective no longer deems relevant or that are potentially harmful to the prosecution’s case. That 

leaves far too much discretion to the individual detective on what to include once the 

investigative story is complete. Likewise, if any investigation is done after charges have been 

lodged, there is no provision in 83-2 to require the detective to fill out or send an additional copy 

of the updated inventory to Records. Finally, 83-2 was still limited to “violent crimes field 

investigations” so the inventory that was created would only include documents created or 

received by the Violent Crimes Unit (and since there were no provisions for sharing documents –

Violent Crimes would potentially receive little else apart from official documents from the 

Crime Lab, Medical Examiner, etc.). As such, the inventory was a woefully inadequate 

document for ensuring that parties received notice of documents generated during a criminal 

investigation. 

5. Special Order 86-3 

 Effective May 29, 1986, the CPD issued Special Order 86-3. Special Order 86-3 largely 

replicates its predecessor with some minor adjustments, most of which actually limited, rather 

than expanded, the safeguards for ensuring complete disclosures to prosecutors and defense 

attorneys. For example, it more explicitly limits the creation of Investigative File Case Folders to 

homicides and where felony charges have been approved; it eliminates the forwarding of the 

Investigative File Inventory Sheet to the Office of Legal Affairs or State’s Attorney upon receipt 

of a criminal subpoena or discovery motion; it eliminates the requirement that handwritten notes 

or other investigative materials be submitted “promptly (normally at the end of each tour of 

duty)” and just states that they must be turned in; and modifies the retention schedule. 

Special Order 86-3 creates VI, titled “Inspection.” That section requires “[e]xempt 

members of the Detective Division” to “conduct periodic, unscheduled inspections of the subject 

files to ensure compliance.” According to Stibich, however, even prior to Special Order 86-3 (or 

its prior iterations), supervisors were supposed to review files to make sure all pertinent 

information is included.142 But he had no idea when, how often or in what manner such 

inspections were conducted. Likewise, the City has produced no documentation that any such 

inspections were ever conducted or how they could be conducted by exempt members with no 

knowledge of individual cases without spending a substantial amount of time reviewing files and 



141 Hickey [2015] 39, 43, 46 142 Stibich Test. P4504-05 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 346 of 433 PageID #:15767
26 

comparing documents. The City’s Rule 30(b)(6) representative testified that no audits were done 

subsequent to Special Order 82-2.143

6. Standard Operating Procedures (SOP) 1988 

In 1988, Chief of Detectives John Townsend wrote a Standard Operating Procedures. 

Chapter 18 deals with Investigative Files. Chapter 18 contains "no substantive changes of any 

kind" from Special Order 86-3.144 Indeed, as Hickey explained, there are different schools of 

thought on whether to have Special Orders or one large manual and this SOP codifies for 

investigative files the policy that was already in place from Special Order 86-3.145 It was not 

intended to effect a policy change. 

III. Professional Homicide Investigation Standards

Homicide cases and investigations in police agencies across the United States are given 

priority and resources not normally provided to other types of investigations. More experienced, 

trained and knowledgeable detectives are assigned. Their investigations result in detailed 

documentation, commonly referred to as “murder books” in some jurisdictions. These 

investigative records provide a step by step record of all evidence gathered, all witnesses 

interviewed, statements taken, leads followed (whether productive or not), medical records, 

autopsy photographs and reports, photographs of the crime scene, wound descriptions, weapon 

(gun, bullet, shell, knife, vehicle, objects, etc.) analysis, chain of custody and evidence logs, 

vehicle impounds, search warrant applications and returns. It is not uncommon for a typical 

murder investigation to contain many hundreds (and often times thousands) of pages – even if 

there is thought to be a “known” suspect. There are well-established criteria and a broad range 

of literature for these practices. Relying entirely on a single “eyewitness” as a basis for police 

presenting a charge of homicide is an indication of an unprofessional homicide investigation. 

Professional investigation and documentation are critically important for a number of 

reasons, some of which include but are not limited to:

x Case integrity 

x Continuity of investigation 

x Supervisory oversight 

x Facilitation of case management 

x Inclusion of investigative notes and investigators actions 

x Ensuring thoroughness of the investigation 

x Allowing other investigators to assist or replace initial investigators 

x Providing a “paper trail” of what steps were taken (or not taken) 

x Focusing on important aspects of the case 

x Identifying what remains to be done and what has already been done and by whom 

x Eliminating suspicion from some possible initial suspects

x Providing sufficient information to identify and arrest a suspect 

 143 Hickey Dep 213. 144 Hickey Rivera, pages 250-51 145 Hickey 178-180; SOP, Chapter 18 at P6497-6502 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 347 of 433 PageID #:15768
27 

x Providing insight for prosecutor considering charges 

x Providing an objective basis for charging and trying the suspect 

x Providing an objective basis for the court to determine challenges 

x To have a single document for discovery and disclosure (Brady rule) 

These standards were in place by 1984. 

IV. Individual, Supervisory & Institutional Failures in Kluppelberg Investigation 

The “investigation” of Kluppelberg by the Chicago Police Department, and the named 

defendants, including various police officers and supervisors employed by the City was: 1) 

conducted in such a manner that it necessarily produced the wrongful arrest, charging and 

conviction of James Kluppelberg, and/or; 2) was conducted in a manner so unprofessional and 

unconcerned about finding out what actually happened as to ensure the same outcomes. Even by 

the most forgiving of standards, practice, and criteria, the investigative documents of the Chicago 

Police Department in this matter were lacking any semblance of a professional and thorough 

investigation. 

Opinion #1: Detectives Rolston and Schmitz Unlawfully Coerced a Confession From Mr. 

Kluppelberg 

I have learned through my professional experience that false or coerced confessions are 

obtained - intentionally or inadvertently - in a three-step process. First, investigators misclassify 

an innocent person as guilty; they next subject him to a guilt-presumptive, accusatory 

interrogation that invariably involves lies about evidence and often the repeated use of implicit 

and explicit promises and threats as well; and then, once the investigator has elicited a false 

admission, they pressure the suspect to provide a post admission narrative that they jointly shape, 

often supplying the innocent suspect with the (public and nonpublic) facts of the crime. These 

have been referred to as the misclassification error, the coercion error, and the contamination 

error.146

A closer examination of the purported "confession" of Kluppelberg to the 

Lupercio/Hermitage fire highlights for me the way in which these errors occurred in this case, as 

well as the statements of Glassco and Gramont. In this particular case, the misclassification error 

is simply put, the investigators at once deciding, without any objective or scientific evidence, 

that Kluppelberg was guilty. The coercion error consists of the extended, unprofessional 

interrogations where the detectives proceeded to utilize coercive techniques that eventually left 

the individuals in this case to feel that they had no alternative but to either falsely confess, or 

give false testimony regarding Kluppelberg. The contamination error involved the detectives 

pressuring each individual to finally agree to a particular scenario by offering specific 

information about the fire and the activities surrounding them. 

Mr. Kluppelberg was one among a number of people who was coerced into giving a false 

confession at Area 3. A 1990 review by the City was initiated and concluded that there was 



146 Garrett B: Judging innocence. Colum L Rev 108:55–142 (2008); Leo R: Police Interrogation and 

American Justice. Harvard University Press (2008). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 348 of 433 PageID #:15769
28 

systematic abuse and torture of at least 118 detainees between 1971 and 1982 in Areas 2 & 3.147 

The investigation detailed specific instances involving “shocking”, “hanging”, and “bagging” of 

detainees. 

“In the matter of alleged physical abuse, the preponderance of the evidence is that abuse 

did occur and that it was systematic. The time span involved covers more than ten years. The 

type of abuse described was not limited to the usual beating, but went into such esoteric areas as 

psychological techniques and planned torture. The evidence presented by some individuals 

convinced juries and appellate courts that personnel assigned to Area 2 engaged in methodical 

abuse. 

The number of incidents in which an Area 2 command member is identified as an accused 

can lead to only one conclusion. Particular command members were aware of the systematic 

abuse and perpetuated it either by actively participating in same or failing to take any action to 

bring it to an end. This conclusion is also supported by the number of incidents in which the 

Area 2 offices are named as the location of the abuse.”148

The review and investigation was supported and endorsed by the Chief Administrator of 

the Office of Professional Standards, and forwarded to the Superintendent of the Chicago Police 

Department.149 The transmittal memorandum to the Superintendent concludes by stating: 

“Both investigators have done a masterful job of marshalling the facts in this intensive 

and extensive project and their conclusions are compelling.”150

Like the allegations in the 1990 review, here, Kluppelberg was physically coerced into 

giving a false confession: He was beaten so badly that he was later urinating blood. Using 

physical abuse to secure a confession is not only contrary to professional standards, but also 

unlikely to produce a reliable or factually accurate statement. Indeed, here, the “facts” in 

Kluppelberg’s confession were physically impossible or contrary to the evidence. For example, 

as Dr. Ogle has explained, the fire could not have started in the front room as Kluppelberg 

confessed. Nor does Kluppelberg’s confession explain in any way how he would have gotten 

into a locked back door to set the fire. 

Finally, the detectives’ claims that he spontaneously volunteered a confession to this fire 

years later is further undermined by the fact that when Kluppelberg was interviewed under noncoercive settings in 1984, he was willing to answer all questions and did not implicate himself in 

any way in the fire. He was interviewed by both O’Donnell and Rolston in 1984, but released 

without any charges being filed against him.151



147 History of Allegations of Misconduct By Area 2 Personnel – Chicago Police Department, Sanders-Goldston 

(1990) P007167-P007278 

148 Ibid, page P007172 

149 Ibid, page P007167 150 Ibid, page P007167 151 Rolston Testimony P285; Rolston Dep, page 215 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 349 of 433 PageID #:15770
29 

Based on the foregoing, the conduct of Rolston and Schmitz is not consistent with what a 

reasonable police officer would have done. No reasonable police officer would have coerced 

Kluppelberg into giving a false confession and sought permission for felony murder and arson 

charges based on that coerced confession. Likewise, and as described more fully below, no 

reasonable police officer would have coerced Dawn Gramont and relied on that false, coerced 

statement to seek felony charges. Finally, reasonable police practices would have involved 

scrutinizing Glassco's statements heavily, in light of his numerous vulnerabilities as a witness, 

and seeking out reliable corroborating evidence before relying on it as evidence of guilt.

Opinion #2: It was Improper for the Defendants to Coerce Dawn Gramont 

In addition to coercing Kluppelberg, I reviewed evidence in this case that Gramont 

alleged that she was also coerced. In particular, Gramont alleged that Detective Foley threatened 

her and her children at the police facility and then shoved and struck her at the ASAs office. 

It is improper to threaten and physically assault a witness. Any detective in 1988 would 

have known as much. Doing so not only undermines the veracity of the witness’ information, but 

also the entire investigation. If detectives need to resort to coercion to corroborate evidence that 

their suspect committed a crime, then they are not conducting a proper investigation. 

In addition, Gramont alleged that Foley told her in detail what she was going to say in 

front of the Grand Jury to implicate Kluppelberg. It is also improper to feed a witness 

information and fabricate their testimony. This is against all basic policing standards. 

As noted above, Gramont’s coerced statement included facts later objectively proven as 

false, and they also included bizarre and implausible facts such as that James Kluppelberg 

climbed up the street light pole to disconnect it. 

Opinion #3: The Detectives in 1988 Failed to Follow-Up on Leads From 1984 

The original finding of the cause of the Lupercio/Hermitage fire was appropriately 

classified as “noncriminal” and “apparent accidental” deaths. However, when detectives decided 

to re-open a closed case it was professionally and legally incumbent on them to consider at least 

the other 8 possible suspects, not just Kluppelberg. Based on the original (1984) records they 

included: 



152 Goldston/Sanders Report, P7167-7264 (finding systemic pattern of abuse notwithstanding numerous unfounded 

or not sustained OPS complaints).

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 350 of 433 PageID #:15771
30 

x Isabel Ramos153

x Richard Shields154

x Oscar Siller155

x Ricardo Rodriguez156

x Nain Saadeh157

x Abda Kater158

x Steven Slepawic159

x Unknown Arab youth160

It is particularly important in investigating cold cases to at least consider suspects that have been 

previously identified. In fact, one of the first things the defendants should have done is review 

the written record that was created in 1984. That would have led them to identify these 

individuals. 

They also failed to investigate further the witness statements indicating that there were 

accidental causes of the fire, such as dangerous wiring. 

In this case, the detectives handling the case in 1988 testified that they would have 

searched for and reviewed all available documentation from the 1984 investigation into the case. 

The New File would have been available to them because depositions and documentation 

indicate that it was still at Area 3 when the detectives re-investigated the case.161 There is 

certainly no evidence that the New File was removed from Area 3 at any time prior to James 

Kluppelberg’s prosecution, and in fact, it is likely that the New File remained at Area 3 until the 

area closed in 1992 and all of its boxes were shipped to the records division for storage. 

As a result, the failure to conduct any meaningful investigation into any of these 

individuals or alternate causes upon re-opening the case was improper. Likewise, the failure to 

disclose the identities of any of these potential alternative leads or suspects to the prosecutor was 

also improper. 

Opinion #4: The Defendants Failed to Fully and Properly Document and/or Record Their 

Investigation 

Throughout the investigation, the Defendants failed to fully and properly document 

and/or record their investigation. Those failures included the following: 



153 “new file” (CITY-KLUP_004358-4364) 154 “new file” (CITY-KLUP_004314) 155 CPD Supplementary Report to #F-105-510 dated 4/10/1984 (CITY-KLUP_000560-561) 156 CPD Supplementary Report to #F-105-510 dated 4/4/1984 (CITY-KLUP_000557-559) 157 “new file” (CITY-KLUP_004347) 158 “new file” (CITY-KLUP_004350) 

159 “new file” (CITY-KLUP_004355-4356) 160 “new file” (CITY-KLUP_004354) 161 Michael Colander deposition, (6/24/2015) pages 29-30 and 44; Andrew Robertson Deposition (6/25/2015) pages 

32-34; Joseph Perfetti deposition (6/11/2015) pages 90-93; Janet McCarthy Deposition (12/09/2015) pages 53-54, 

62-63; Rolston Test. at Pretrial P301 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 351 of 433 PageID #:15772
31 

x Failure to fully and properly conduct, document, and/or record interviews 

x Missing and merging of investigative dialogue often precludes ability to actually 

know which officer (who) did what, when, where, how and why 

x Failure to accurately (if at all) identify dates, times, locations, and individuals present 

for significant events (statements, investigatory actions, etc.) 

x Investigative “tunnel vision” by Rolston and others 

x No signed or recorded Miranda warnings 

x No documentation of Kluppelberg’s or “witnesses” statements, either audio, visual, or 

written 

x Reliance on witness as sole evidence in investigation, arrest and charging 

x Failure to examine, document, and photograph “line of sight” positions and angles 

x Virtually no chronological documentation of investigative steps taken 

x No review or retention of incoming 911 call recording(s) 

x No review or retention of dispatch or responding unit call recordings 

x No signed and sworn statements by the investigating officers 

x Missing and merging of investigative dialogue often precludes ability to actually 

know which officer (who) did what, when, where, how and why 

x Failure to document removal and use of investigative notebook (“green card”) 

x Failure to maintain and complete investigation contents (“yellow card) 

In addition to those very basic failures, the Defendants also failed to include in 

supplementary reports and therefore, in the permanent retention file or in the 1988 Area 3 

investigative file, information about other crimes that might be related, or even other possible 

suspects, which the Defendants allegedly eliminated. This includes no documentation that: 

x Detective Micek told B&A detectives working on the Hermitage investigation that 

Ramos said she may have set other fires but she was too drunk to remember. This 

information was not memorialized in any supplemental or other report in any file 

relating to the Hermitage Fire investigation. Defendant Micek testified that he would 

have disclosed this information to both B&A detectives working on the Hermitage 

fire as well as the Area 3 detectives investigating the Hermitage fire.162

x The Defendants were aware of two other fires close in time and proximity to the 

Hermitage fire: the “Ramos” fire at 4504 S. Marshfield and the “Slepawic” fire at 

1840 W 46th Street. No documentation of these fires was included in a supplemental 

report or other document in the permanent retention file or 1988 A3 Hermitage Fire 

files. 

x Supplementary reports expressly omitted critical information contained in the 

handwritten notes about the case. For example, Detective Tuider’s closing report did 

not contain any information contained in Dets. Smith and Brankin’s internal memo to 

him. 



162 Wayne Micek Deposition (06/10/2015) pages 27, 29-30, 48-49, 58-59. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 352 of 433 PageID #:15773
32 

 Police files should include information about alternative suspects or information about 

how certain suspect’s were allegedly eliminated. That is particularly true in case like 

Kluppelberg where one of the suspects does not deny that she may have set the fire at 4448 S. 

Hermitage, but simply said she was too drunk to remember. That information was exculpatory. 

The fact that the Defendants alleged that they discounted it for inexplicable reasons (which are 

not documented in the police file) does not make it less exculpatory or eliminate the duty to 

document and communicate that information in the Hermitage file. 

Similarly, the Defendants failure to include information that Minerva Harast provided the 

detectives about the dangerous wiring in the basement in any supplementary report or on an 

official form was improper. That is because by failing to put that information into a 

supplementary report or on an official police form the Defendants failed to ensure that it would 

be retained and disclosed to the prosecution. In fact, in this case what was disclosed to the 

prosecution regarding Minerva Harast was misleading: In Detective Tuider’s report, he stated 

that Harast knew nothing, when in fact she knew about the dangerous wiring – a potential source 

of an electrical fire.163 He was apparently never reprimanded for this mischaracterization. And, 

actually, his decision to handle the Harast statement by omitting and misrepresenting it in the 

supplementary report was made possible by the inadequate special orders put into effect after the 

street files litigation. 

Opinion #5: The Defendants Failed to Follow-Up on and Attempt to Corroborate Duane 

Glassco’s Statement 

Duane Glassco gave his statement, grand jury testimony, and testimony at trial in 

exchange for what appear to be two deals: one on his possession of a stolen motor vehicle 

burglary charge in 1988 and another on his violation of probation in 1989.164 Whenever a 

witness is getting a benefit in exchange for his testimony, the police need to be very careful in 

analyzing whether what he or she is saying is true and can be corroborated. That is no less true 

for Duane Glassco. 

It is also apparent that when a witness is giving a statement about a crime years later, the 

police must be careful to corroborate it as memories can fade over the years and it raises a red 

flag about why the information was not communicated sooner. 

Instead of doing follow up to determine whether Glassco’s statement could be 

corroborated, the Defendants coerced a statement out of Dawn Gramont and a false confession 

out of James Kluppelberg. 

Had the Defendants instead done even a cursory investigation, they would have figured 

out that what Glassco was saying was physically impossible; that is, that you could not see the 

back door of 4448 S. Hermitage from the attic window at 1748 W. 45th Street. In fact, even 

visiting the scene – which would be ordinary protocol in a cold case investigation – would have 

shown them as much. So would talking to Charles Petrosus or any of the other persons who lived 



163 Dr. Russell Ogle Expert Report (Aug. 3, 2015) 164 Theodore Adams Expert Report (Aug. 3, 2015); Glassco Trial Testimony, at P497-498, 545-548 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 353 of 433 PageID #:15774
33 

in the area at the time of the fire. The inability to see the back door should have in turn raised red 

flags about what Glassco was saying and the truth of what he was alleging. 

In addition, according to Defendant Rolston’s testimony during pretrial motion hearings, 

the 1984 arson worksheet had Glassco’s name on it. The detectives were interviewing a lot of 

people in 1984, and very likely interviewed Glassco. Had Glassco said anything inculpating 

Kluppelberg (or even anything of value), the detectives would have documented it. But no such 

documentation exists. 

The detectives’ failure to do this basic investigation was improper. It demonstrates not 

only a lack of appropriate follow-up, but also tunnel vision in seeking out the conviction of 

Kluppelberg. 

Opinion #6: The Defendants Failed to Disclose Exculpatory and Impeaching Information 

In 1988 and 1989 (and in 1984), the police were aware of their duties to disclose 

exculpatory and impeaching information. That was a basic police requirement. 

Here, the Defendants failed to comply with that requirement. In particular, Defendants 

Rolston and Kelly failed to disclose: (a) the New File; (b) information about Isabel Ramos and in 

particular, the statement that she may have set additional fires but was too drunk to remember; 

(c) the information that Minerva Harast provided to the police about dangerous wiring; (d) the 

names of other alternate suspects contained in the New File; and (d) any notes that Burns 

allegedly took. 

All of that information should have been turned over because it would not only have been 

relevant to the case, but also exculpatory and/or impeaching. 

For example, in the New File, there was evidence of potential alternative perpetrators: 

Not only did the New File discuss Isabel Ramos, but it also discussed individuals named: Abda 

Kater and Nain Saadeh, who had arguments with the Lupercio/Hermitage fire victims; and 

Steven Slepawic who was arrested for an arson at 1840 W. 46th Street. Information about 

alternative suspects should be routinely turned over because it is exculpatory. Similarly, Ramos’ 

statement that she may have set other fires but was too drunk to remember was obviously 

exculpatory and should have been turned over to the prosecutor as a matter of course. Because 

Ramos was credibly linked to a nearby fire, said she may have set other fires, and was not able to 

deny responsibility for the fire, her identity and statements were particularly valuable and may 

have been introduced as credible, non-speculative evidence of an alternate suspect. 

There was also evidence in the New File that would have impeached Burns’ trial 

testimony that he eliminated all electrical causes of the fire. The same would be true of any notes 

that Burns took at 4448 S. Hermitage. 

The fact that the New File was not turned over can be explained in part because it fit all 

of the criteria of a “street file.” As described above, “street files,” alternatively called “working 

files” or “running files,” were files that were kept by the detectives and not disclosed to the 

prosecutors. According to the Department, street files typically included “various notes, memos 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 354 of 433 PageID #:15775
34 

and bits of information on the case . . . which are used to communicate steps taken, steps to be 

taken, and personal opinions of one Detective to another.”165

In particular, “the main component of a ‘Street File’ is the memorandum sheet or 

‘memo.’”166 “Additionally, the ‘Street Files’ contain other case and supplementary reports 

pertaining to non-related cases which are utilized in suspect elimination and identification.”167

“Personal notes of the Detectives, used to compile the investigation, are also inserted into the 

‘Street File.’”168

Street files were used “[a]s a forum for different detectives to give their respective view 

points, opinions, conjectures, suppositions and ‘gut feelings’”; to document “the [sic]

creditability of witnesses and/or suspects;” to document “[a] listing of leads undertaken 

(sometimes false) (not included in official reports); to document “[a] listing of information which 

later proves to be erroneous or given to detectives for self-serving purposes;” and “to document 

“[a] listing of information that later proves to be worthless and does not become an integral part 

of the investigation/court presentation.”169 

Based on CPD’s own definition of a “street file,” I opine that the New File was a street 

file. It contained “Case and Supplementary Reports” pertaining to both Isabel Ramos and Steven 

Slepawic: two other suspects who were reportedly identified and eliminated. It also included the 

identification of suspects Abda Kater and Nain Saadeh. Further, the New File contained personal 

notes of the Detectives, including notes relating to Minerva Harast and the extension cords all 

over the basement. Finally, it contained at least two memoranda relating to the case, which 

demonstrated some of the steps taken and to be taken. None of these documents were included in 

the files that were disclosed to the prosecutor nor was any of this information put into a 

supplementary report and thereby made part of the permanent retention file. In short, it was all 

kept secret, just as a street file would be. 

That failure to disclose the New File or even the information in it was particularly 

troubling for two reasons: (1) as discussed above, it would have been available to Area 3 

detectives re-investigating the case in 1988 and the detectives doing the 1988 investigation 

would have reviewed it if it was available; and (2) even apart from the New File, the information 

contained therein – particularly about Isabel Ramos – would have been available to B&A 

detectives re-investigating the Hermitage fire in 1988. 

As to point (1), Detective Kelly testified that when he investigated the case in 1988 he 

would have gone and looked for any documents on the case – that would include viewing the 

Area investigative file, ordering the Records Division file, and seeking out the old investigative 

file.170 That is expected and understandable, as detectives handling homicide cases will seek to 

familiarize themselves with the investigation that occurred on the case, what evidence and 

witnesses were gathered, what suspects were eliminated, what leads were not followed up on, 



165 Memo to Raymond Clark from Sgt. Thomas Brady, at P2457-58 166 Memo to Raymond Clark from Sgt. Thomas Brady, at P2459. 167 Ibid 168 Ibid 

169 Memo to Raymond Clark from John Stibitch, at P2455. P2455-56 170 Kelly Dep. [2015] pages 28-30 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 355 of 433 PageID #:15776
35 

etc. I am aware that the City of Chicago is claiming that the New File would have been removed 

from Area 3 prior to 1988. However, I do not believe this is the case. There is no evidence in the 

record to support that claim, such as disposal applications, disposal certificates, or any label that 

the file or the box contained it were marked for destruction. As a matter of standard police 

procedure, records from a criminal investigation would not simply be destroyed without careful 

procedures being followed. It is a serious business to destroy police records, even pursuant to 

retention schedules, and departments have rules to follow, such as ensuring that the applicable 

state records commission authorized the scheduled destruction, that the file is appropriate labeled 

prior to destruction, and that someone has reviewed the file and confirmed that it should be 

purged. There is testimony that Area 3 kept closed files in its office.171 It also appears that 

investigative files regarding violent crimes investigations were not normally purged.172 The RD 

file for this case was not subject to permanent retention until it was re-classified in 1988 as a 

homicide, and yet the department did not take any steps to purge the RD file between 1984 and 

1988, which further indicates that there was no routine purging that affected the records 

pertaining to the Hermitage fire investigation. 

There is other evidence that the Area 3 detectives investigating the fire in 1988 obtained 

recordsf beyond what was in the Records Division file. The Area 3 file that was produced in this 

litigation, which was identified as being from the 1988 investigation, contains police reports 

from 1984 that do not bear the “permanent retention” or “records division” stamps on them, 

which indicates that these copies did not come from the permanent retention file. For instance, 

the copies of the reports by Detectives Urbon and Jenkins in the Area 3 file contain only a 

“Bomb & Arson” stamp on them. 

The record strongly indicates that Kelly and his partner Foley had access to the 

documents in the New File. 

With regard to point (2), Detective Rolston testified during Kluppelberg’s pretrial 

proceedings that he had done work on the fire in 1984.173 He further testified that he reviewed 

some reports from 1984 around the time he questioned Kluppelberg in 1988 – including the wetip report, which is not in the permanent retention file and was created in 1984.174 In addition, 

Rolston testified to having reviewed in 1988 three pages of notes from B&A Detective 

O’Donnell and Stan Cerdaj; those also would not have been the type of document to be a part of 

a unit RD or permanent retention file and in fact are not in the permanent retention file for the 

Hermitage fire.175 Finally, Rolston would have known about Isabel Ramos in 1984, when he was 

working on the Hermitage case. This is because the Hermitage fire was a major investigation in 

1984, and much of the department was at one point or another working on it.176 Rolston testified 

at the suppression hearing that he canvassed the neighborhood looking for information.177 The 

detectives in Bomb & Arson were well aware that a woman had been brought to the station as a 



171 McCarthy Dep 113 172 Colander Dep 39; Robertson Dep 66; McCarthy Dep 165-166 173 P272 174 P285-86 175 P295 176 P272 177 P303 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 356 of 433 PageID #:15777
36 

suspected serial arsonist, to be interviewed about the Hermitage fire and the other area fires.178 It 

is reasonable to infer that Rolston – when re-investigating the Hermitage fire in 1988 –had 

access to whatever investigative file B&A created in 1984.179

The City has not produced in this litigation any investigative file for Bomb & Arson. 

According to Detective Micek, that file should and would have included information 

about Isabel Ramos. Micek testified that he would have told B&A detectives investigating the 

Hermitage Fire about Ms. Ramos and the information that she provided to him.180 There is no 

reason, therefore, why this information was not disclosed to the prosecutor. 

Opinion #7: Failure to Attempt to Resolve Differences Between B&A and Office of Fire 

Investigations (OFI) Regarding the Cause and Origin of the Fire 

When the Hermitage Fire was originally investigated in 1984, the B&A Unit – who was 

in charge of conducting that investigation – found that the cause of the fire could not be 

determined due to the total destruction of the building. In addition, the B&A found that there was 

no sign of an accelerant used. 

Four years later, B&A was still in charge of making cause determinations. Nonetheless, 

when the Hermitage fire was re-investigated in 1988, instead of relying on B&A for that cause 

determination, the Defendants sought out OFI. This was particularly strange because Defendant 

Rolston had been part of the B&A team that investigated the Hermitage Fire in 1984 (and 

determined that the cause and origin could not be determined). It was also strange because it 

appeared that B&A and OFI had a strained relationship, as both were covering the same turf. 

B&A thought that OFI was quick to find a fire incendiary; and OFI thought that B&A was ruling 

too many fires undetermined.181

Moreover, I saw nothing in the materials I reviewed that suggested that B&A and OFI 

ever tried to resolve the differences in their cause determinations. According to OFI’s policies, 

whenever there was a dispute between OFI and B&A about a cause and origin determination, the 

two units were supposed to meet so that they could reach a mutual agreement.182 No such 

discussion occurred here. Rather, B&A (Rolston) simply accepted OFI”s contrary conclusion 

notwithstanding the fact that he – as part of the B&A 1984 Hermitage team – had reached a 

contrary finding four years earlier. There was no new evidence in 1988 that would have enabled 

OFI to reach a contrary determination about the cause of the fire without being in direct conflict 

with what the 1984 Hermitage team found: in fact, the burn patterns were all apparent and 

available to the B&A detectives at the scene in 1984. Failing to try to account for these differing 

conclusions was in error – especially because B&A and not OFI was in charge in 1984. 



178 Micek Dep at 58-59 

179 P301 180 Micek Dep 58-59 181 Alletto Dep 73-75 182 Memo, April 18 1986: JGS 7012-7018 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 357 of 433 PageID #:15778
37 

Summary: Officers’ deficiencies in this investigation include, but are not limited to:

x incomplete and misleading reports 

x Failure to complete necessary reports 

x Intentional and willful actions reflective of “tunnel vision” against the criminal 

defendant 

x Intentional and willful omissions designed to protect the case that the detectives were 

building 

x Bogus documentation 

x Criminal conspiracy 

No explanation or justification was given for the lack of continuity in this homicide 

investigation. Bomb and Arson detectives began the investigation, but it was soon being 

investigated by Violent Crime detectives. There was no supervisory oversight, other than 

signing documents. Detectives exchanged information but there did not appear to be any 

coordination of these efforts, nor any policy requiring that information be stored in each area’s 

investigative files or across relevant RD numbers. 

The defendants will undoubtedly claim that any “minor” oversights, inconsistencies, or 

mistakes were unimportant. The truth of the matter remains that they create a cumulative portrait 

on either incompetence or malice. Any reviewing supervisor should have immediately noted the 

telltale signs of such. 

There exists a broad range of literature, accepted policies and practices, and professional 

references that accentuate many of these shortcomings. A small sampling of organizations 

involved with these efforts includes, but is not limited to: 

x International Association of Chiefs of Police (IACP) 

x Police Executive Research Forum (PERF) 

x National Sheriffs' Association (NSA) 

x Commission on Accreditation for Law Enforcement Agencies (CALEA) 

x National Institute of Justice (NU) 

x Americans for Effective Law Enforcement (AELE) 

x Bureau of Justice Assistance (BJA) o Program Evaluation 

x Community Oriented Policing Services (COPS) 

x Municipal Services and Research Center (MSRC) 

x Police and Law Enforcement Performance Standards and Levels of Service 

x National Security Standards (NSS - previously the Law Enforcement Standards 

Office) 

V. The Role of the Chicago Police Department 

In my opinion the City of Chicago and the Chicago Police Department have 

demonstrated the following deficiencies in this specific case, as well as across similar cases such 

that the deficiencies amount to a pattern and practice: 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 358 of 433 PageID #:15779
38 

x Failure to establish clear and unequivocal standards for investigations 

x Failure to apply standards department wide for all divisions and units 

x Deficient policies and practices 

x Failure to investigate 

x Failure to train 

x Failure to supervise 

x Failure to track and monitor 

x Failure to discipline 

Each will be discussed in more detail below. 

Opinion #8: Failure to Train on Homicide Investigations 

Training is one of the most important responsibilities in any law enforcement agency. 

Among other things, training serves a number of basic objectives: 

x Well-trained personnel are better prepared to act professionally and correctly 

x Training results in greater efficiency and effectiveness 

x Training encourages agency internal cooperation and compliance with policies 

x Ensures appropriate police actions 

x Provides safeguards for being legally accountable for actions of personnel relative to: 

o Individual rights 

o Evidence control 

o Brady disclosure 

o Documentation 

o Investigation integrity 

The officers involved in the arrest and prosecution of Kluppelberg were not provided 

with the training necessary for their duties and responsibilities. Of all the defendants, only Ptak’s 

record shows that he actually attended a homicide investigation class, and that was in 1969. He 

is also credited with a homicide investigation “in-service” training in 1980. However Ptak was 

only peripherally involved in 1988 by way of producing a dubious and non-investigatory 

supplementary report.183 Of the remaining officers, only Jenkins’ and Vega’s records list credit 

for an “in service” homicide investigation class in 1984. Neither Rolston nor Schmitz had any 

recognized homicide investigation training. 

In particular, detective Rolston acknowledged in his deposition that he had only been 

involved in only a few (1-3) prolonged investigations while he was an arson investigator184 over 

a 12-year period.185



183 CPD Supplementary Report to #F-105-510 dated 3/24/1988 (CITY-KLUP_000583-584) 184 Rolston deposition 5/8/2015, pages 110-111 185 Ibid, page 120 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 359 of 433 PageID #:15780
39 

Similar to other state and agency standards, the Illinois Law Enforcement Training and 

Standards Board rules, Sec. 10.11 (50 ILCS 705110.11), states: 

“Training; death and homicide investigation. The Illinois Law 

Enforcement Training and Standards Board shall conduct or approve a training 

program in death and homicide investigation for the training of law enforcement 

officers of local government agencies and coroners. Only law enforcement 

officers and coroners who successfully complete the training program may be 

assigned as lead investigators in death and homicide investigations and coroner's 

investigations, respectively. Satisfactory completion of the training program shall 

be evidenced by a certificate issued to the law enforcement officer or coroner by 

the Illinois Law Enforcement Training and Standards Board.” 

Although this Illinois standard may or may not have been in place at the time, a review of 

the detectives’ training records suggests that no such certificate was ever issued to the detectives 

in this case by the Illinois Law Enforcement Training and Standards Board, as required by 

Illinois law. Also, based on the detectives’ descriptions of their training from their depositions, it 

appears that little, if any, specialized (as opposed to “on the job”) homicide investigation training 

was ever provided to them prior to their undertaking the murder investigation in this case. 

In 1984, and 1988, the need for such training would have been obvious, as would the fact 

that the failure to do so would lead to egregious errors. That is particularly true because without 

any formal training, the only training that detectives would get would be on-the-job training from 

other detectives who themselves had had no formal training; in other words, they would just be 

learning and then repeating the mistakes of their predecessors. 

Opinion #9: Failure to Supervise and Intervene 

In this case, supervisors failed to actively monitor, review, direct and control the 

unfolding re-opening of the “investigation” of the Lupercio/Hermitage fire being conducted by 

multiple organizational units under their respective CPD commands (including involvement of 

the Chicago Fire Department, although in a quasi-official capacity). 

CPD’s supervisors and leadership knew, or should have known, of the improper and 

unacceptable methods of practices of their detectives in general, and of these specific detectives 

at issue in this case in particular. These supervisors failed to intervene, control, cause to cease, 

restrain, correctively train, or otherwise cause the misconduct to cease. 

Three practices stand out in particular: First, the failure to require the detectives to put 

any information about Ramos or Harast into a supplementary report that would become part of 

the file. According to the Special Orders, the detectives were required to transcribe from 

memoranda or handwritten notes information that was relevant onto a supplementary report. 

There can be no legitimate dispute that information that someone else may have set the fire or 

that there may have been an alternative cause of the fire was relevant within the meaning of the 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 360 of 433 PageID #:15781
40 

Special Orders. Yet, at no time did a supervisor request that this information be put onto a 

supplemental report. 

Second, Sergeant Olivieri was the same Bomb and Arson sergeant overseeing both the 

Hermitage and Marshfield fires. At a minimum, Sergeant Olivieri should have put Detective 

Micek’s report regarding Isabel Ramos’ oral statement into the file for the Hermitage fire. This is 

particularly so because according to the detectives’ testimony – and in particular, Rolston’s 

testimony during Kluppelberg’s pretrial proceedings – the B&A investigation of the Hermitage 

Fire was never closed. Sergeant Olivieri should have also had B&A detectives investigating the 

Hermitage fire write a supplementary report about Micek’s conversation with Ramos and her 

confession that she may have set other fires, since Hickey testified that a supplementary report 

with a different RD number would never go into the permanent retention file. By having the 

detectives write up a separate supplementary report under the Hermitage fire RD number, the 

information would be sure to end up in the RD file for the Hermitage fire. 

Third, there was no discipline and oversight of Detective Rolston during the time that 

Kluppelberg was fighting against the murder and arson charges. Rolston had 11 CR files lodged 

against him including: 

x CR 1021145: CR alleging that Rolston threatened to kill a civilian 

x CR 195704: CR alleging that Rolston failed to submit a supplementary report for 

an arson to which he was assigned and failed to interview a victim or seek out 

witnesses. This CR was sustained. 

x CR 172573: CR alleging that Rolston conducted a warrantless search and 

physically assaulted and threatened complainant and her daughter; 

x CR 205961: CR alleging that Rolston filed a false report. This CR was sustained. 

x CR 231334: CR alleging that Rolston coerced complainant’s son into signing a 

false confession by physically assaulting him with a shock device and giving him 

a black eye 

x CR 243166: CR alleging that Rolston physically assaulted a suspect, including 

punching in the chest and pushing up against a wall, and denied suspect his right 

to an attorney 

x CR 254170: CR alleging that during an interrogation, Rolston choked, pointed a 

gun, grabbed a suspect’s arm and threw him to the floor and denied suspect 

medical attention. 

x CR 268507: CR alleging that Rolston wrote out a false report. This CR was 

sustained. 

x CR 293963: CR alleging that Rolston falsely arrested a suspect and coerced him 

into singing a false confession. Note: In this CR, Rolston stated that he did not 

remember the incident due to an ongoing medical condition, which impacts his 

memory. 

These CRs demonstrate that Rolston had a repeated pattern of assaulting suspects and 

witnesses and filing false reports. While he was disciplined on three occasions, he should have 

been subject to much stronger and more aggressive corrective action. This is particularly true in 

light of the seriousness of the allegations against him – including physically assaulting suspects 

as he did with Kluppelberg, failing to submit a supplementary report, and writing false reports. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 361 of 433 PageID #:15782
41 

Failing to impose sufficient discipline will lead detectives to believe that they can commit 

additional misconduct without facing real consequences. 

Opinion #10: The City’s Practice of Keeping Parallel “Street Files” Is Improper 

The practice of street files as described above was extremely problematic. It meant that 

detectives kept parallel files in their possession or in the Area that had different documents and 

potentially different information in them. As demonstrated by the Jones and Palmer litigation, 

that information could be highly exculpatory or at a minimum, impeaching and therefore was 

required to be disclosed to the criminal defendant. By keeping a separate set of files over which 

the CPD had insufficient control, there was no guarantee that information would be turned over 

to the prosecutor, and therefore turned over to the defendant. To the contrary, Judge Shadur 

found that the parallel file system was creating a “grave risk” of non-disclosure. 

It is also worth noting that according to testimony of both Stibich and Hickey, the 

practice of using street files appears to have been entrenched within the Department. Stibich 

testified that the practice existed when he started at Area 4 in 1974, and Hickey testified that it 

was in existence in 1977 when he started at Area 1. As Hickey explained, the mindset was not to 

turn over notes, and not to put certain investigative materials in the working file into the Records 

Division file.186 When Hickey conducted his sampling of files at the Areas, he found that all of 

the Areas had a practice of using a working file and not retaining that file.187 In fact, Hickey 

testified that the practice of using street files was a citywide practice and that street files were 

used on a regular basis.188 For that reason, perhaps, Judge Shadur found that the street files 

practice was not infrequent or irregular. 

I have become professionally familiar with these issues in my examination of this and 

other cases in which I have been retained. Although regularly put on notice through lawsuits and 

depositions, the CPD has made only superficial attempts to resolve the street files problem, and 

unsurprisingly, those attempts have proven to be unsuccessful in remedying these issues. They 

include: 

x Detective Division Notice 82-2 (Detective Division Notice - File Control)189

x Special Order 83-1 (Detective Division Special Order – File Control)190

x Special Order 83-2 (Detective Division Special Order – Investigative Files)191

x Special Order 86-3 (Detective Division Special Order – Investigative Files)192



186 Hickey 171 187 Hickey 187 188 Hickey 219-20 

189 Special Order 82-2.pdf 

190 Special Order 83-1.pdf 

191 Special Order 83-2.pdf 

192 Special Order 86-3.pdf 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 362 of 433 PageID #:15783
42 

I will discuss the deficiencies in the Special Orders in greater detail below. 

These issues have been noted in the past by the courts when they have discussed the 

problem of street files and identified problems with Special Order 83-1, for example. The 

discussions in the Palmer v. City of Chicago case193 are representative and consistent with my 

professional experience, as well as my observations in this specific case: 

x The maintenance of multiple, separate investigative files - "Official Files" (Permanent 

Retention) vs. "Street Files" (Personal, and/or Working, and/or Street Files); 

x Lack of file integrity and security of files; 

x Insufficient or non-existent chain of evidence and/or custody; 

x Willful failure to disclose and produce all records to prosecutors, defense attorney, 

and court (Brady Rule) - not only in the initial process and trial, but in subsequent 

"re-investigations" and appeals, as well as in civil litigation; and 

x The continual utilization of unit or division specific directives, notices, and special 

orders fails to recognize the involvement of other CPD entities that may, or may not, 

be bound by those directives. 

These deficiencies are contrary to the generally accepted practices for an essential aspect 

of police control, which is monitoring, accountability, and following written policies. The 

material that I have reviewed allows me to opine that any reasonable officer or supervisor in the 

Chicago Police Department would reasonably believe that it was acceptable for them to ignore 

any written policies that did exist. Street file supplementary reports194 all show the continued 

use of street files after the Special Orders were enacted, as is further discussed below. This is 

further shown in CPD Assistant Director James Hickey’s deposition. 

What has been identified by the parties as the “New File” provides further evidence of 

this. Certain acknowledgements by the defendants195 make it clear that in this case disclosure 

was problematic. Key documents contained in the New File were never given by the police to the 

prosecutor or the criminal defendants’ attorneys. Deposition testimony196 197 198 and 

documents199 indicate that the “New File” was sent to the Records Division in 1992 when Area 3 

closed (and was not sent prior and was also not scheduled for destruction as the City claimed 

earlier). This is important because it means that the “New File” was in Area 3 when the 

Lupercio/Hermitage fire was investigated in 1988. 

Documents200 201 in the “New File” did not conform to Special Order 83-2 and in 

particular to section V. – B. relative to handwritten notes, “To/From” memos, and the backs of 

Major Incident Work Sheets not being in a supplemental report. In addition, inventories were 



193 Judge Milton Shadur opinion in Palmer v. Negron. 3/31/1983 (P2648-2669) pages 1-22. 

194 Dockets 212-3 and 212-4 

195 City’s Responses to RTA No. 3 (Nos. 5,8,9,12,13,16,21,24,25,28,57, 60, 61, 64) 

196 Joseph Perfetti deposition, (6/11/2015) pages 90-92 

197 Michael Colander deposition, (6/24/2015) pages 29-30 and 44 

198 Andrew Robertson deposition, (6/25/2015) pages 28-34 

199 Plaintiff’s Motion for Extension of Fact Discovery Regarding New File and Area 3 boxes, Exhibits K & L 200 James Hickey deposition, (6/9/2015) pages 222-223 201 City’s Fourth Amended Responses to Seventh Set of Interrogatories 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 363 of 433 PageID #:15784
43 

incomplete and there was no indication that they were ever sent to records for inclusion in the 

permanent retention file. A full review of my findings is below. 

A. Homicide and Pallet File Review 

 The failure to properly document and turn over the critical investigative materials in 

Kluppelberg was not an anomaly. Rather, it was an example of the Chicago Police Department’s 

widespread practice of maintaining multiple files and relying on informal and unofficial notes to 

document investigations. 

It is my understanding that the City produced a total of 660 post-January 1, 1983 

homicide investigative files from Area 3, covering 619 RD numbers, and that those files were 

produced to Plaintiff on a rolling basis. Of those 660 files, I reviewed approximately 25%, 

which consisted of 164 investigative files provided to me by Plaintiff’s attorneys, and which 

spanned 1983 – 1991 the entire period of time covered by the City’s production (post-January 1, 

1983, when the relevant special orders came into effect). I was given corresponding permanent 

retention files for fifteen investigative files, which I also reviewed. In my experience, a sample 

of this size is sufficient to analyze and draw conclusions about police practices. 

My charge was to examine each of these files, not necessarily for the quality (or lack 

thereof) of the individual investigations, but for any observations and conclusions that I might 

make as to material deviations from the relevant CPD policies. As important was to evaluate this 

material in the context of normal and accepted police practices designed to ensure that all 

material produced during major criminal investigations is readily accessible, complete, 

discoverable, and in a format as to be actually useful and discoverable. 

Based on my review, it is apparent that systematic and widespread practices within the 

Chicago Police Department did not comply with the new policies promulgated after the Palmer 

litigation. Specifically, detectives routinely documented critical investigative materials solely on 

unofficial forms, did not complete the prescribed official forms designed to ensure file integrity, 

and kept incomplete inventories of the investigative file. In my professional opinion, the files 

both individually and in aggregate, support my opinions that from 1983 onward, there was (a) 

inadequate and deficient policies pertaining to records standardization, integration, maintenance, 

retention, indexing, and discovery; (b) no apparent department-wide meaningful effort to provide 

training on those policies that were promulgated; (c) no thorough, methodical, and regular 

monitoring for adherence to those policies; (d) no corrective action, either administratively or 

through discipline, for any violations of those policies, and; (e) a clear pattern and practice of 

condoning, if not encouraging these failures. These practices precluded meaningful discovery by 

defendants. 

1. Repeated instances of not using official forms to ensure file integrity 

Nearly every case I reviewed had handwritten notes, on blank pages rather than on 

official forms. Moreover, those notes were consistently undated, provided no context for how 

they were acquired, and contained no signature to identify the author. (e.g. City-Klup_49820). 

The use of official police reports is critical to ensuring that investigative information is 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 364 of 433 PageID #:15785
44 

discoverable, and the failure to use official reports undermines the integrity of the investigative 

files: As discussed above, if material is not actually documented and included in official police 

reports, there is no way to know that it ever existed, how it was acquired, who acquired it, where 

it was acquired, and when it was acquired. As importantly, there is no chain of custody and no 

case integrity. The material is then susceptible to manipulation, interpretation, and loss. 

In addition to the above-described routine failures to record material information on 

official police reports, such that they would be discoverable, my review of the 164 files revealed 

other failures to implement CPD policy, creating additional opportunities for materials to be lost 

or manipulated, and thus withheld from the criminal defendant. Though the Chicago Police 

Department had designed certain forms to ensure file integrity, the files reveal that there was a 

widespread practice of disregarding these forms. 

1) Major Crime Worksheet (example at Bates 38802): These forms are a creature of the 

Detective Division Violent Crimes Unit. They provide the “who, where, what, when” 

(but not necessarily the why). They provide the starting point and one of the best sources 

of initial discovery. The Major Crime Worksheet is missing from a significant number of 

the cases that I reviewed, establishing a clear negative pattern and practice of disregard. 

2) Investigative Case File Control (example at Bates 38755): This form is designed to 

maintain case integrity and chain of custody of investigative files. It is common during 

an investigation for a file to be routinely removed for a multitude of legitimate reasons 

(crime lab, consultation with other units, review by prosecutor, court appearances, etc.) 

The case file control form documents the file’s movements so that it is clear whether and 

when information may have been copied or removed. In most of the cases that I 

reviewed they are either missing, have so few entries as to be unbelievable, or have not 

entries at all – an impossibility. This is another critically important form for discovery 

purposes because it should reveal all the individuals that may have contributed to the file, 

including from other divisions or units. The failure to systematically utilize them 

properly, and the concurrent institutional failure to enforce compliance, indicates a 

pattern and practice. 

3) Supervisory (Chain of Command) Review (example at Bates 52919 / 53066): This 

form is designed to document that the chain of command responsible for overseeing the 

investigation and compliance with relevant departmental policies and procedures has 

actually done so. Most of the files that I reviewed either was missing the form, had only 

a single signature, or in the example had no signatures as all. That is, there is essentially 

no documentation of supervisory review in the investigative files. This clearly 

demonstrates a willful disregard among supervisors for ensuring that detectives were 

following the policies. 

4) Detective Division Personnel Form (example at Bates 59648): This sheet is designed to 

quickly track and identify detective division employees, where they are assigned, 

working hours, and equipment. It does not necessarily account for officers from other 

units. Regardless, in the majority of the cases reviewed, this form is missing altogether. 

This prevents realistic and effective discovery of potential police witnesses. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 365 of 433 PageID #:15786
45 

5) Case Assignment Slip (example at Bates 38531): The Case Assignment Slip is designed 

to document initial detective(s) assigned and conclusion status. These are key individuals 

to seek out in discovery for depositions. Again, enough of these forms are missing to 

demonstrate a clear pattern and practice of disregard for the policy. 

Nothing in the material that I have reviewed indicates that these patterns and practices were 

ever identified, acted upon, or corrected. While there are rare exceptions where the material is 

much better preserved and presented, they are the distinct minority. If you were to randomly 

access any of the files that I reviewed, you will find the deficiencies are across the board and 

form a pattern and practice that demonstrates an institutional decision to ignore the requirements 

put in place after Palmer. 

2. Material information was repeatedly omitted from official police reports. 

The failure to use official forms properly, as described above, prevents material 

information from making its way to the criminal defendants. The case files I reviewed (100%) 

are replete with examples of handwritten pages and informal memos between detectives 

containing potentially exculpatory information. These handwritten notes contained critical 

investigative information, including: 1) Leads on different or additional avenues of investigation 

(Bates 120228; 120374202); 2) Names or descriptions of possible alternative suspects (Bates 

118848); 3) Names or descriptions of additional witnesses (Bates 120368; 120386203); 4) Names 

or descriptions of possible alibi witnesses; 5) References to other CPD or outside law 

enforcement involvement in the investigation; and 6) Handwritten diagrams, scene and area 

maps, evidence locations. (Bates 128084; 120221). These citations are examples and not an 

exhaustive list of instances where these trends were seen. 

Even more troubling, in the vast majority of the cases that I reviewed, there is no 

companion entry on official CPD forms that documents this critical information, leaving this 

potentially exculpatory information solely in handwritten notes or in informal memos. Some 

examples of these omissions include: 

x Frank Rhodes was murdered on May 27, 1985 and the investigation of that homicide was 

assigned Records Division number F-417-457. As part of their investigation, officers 

conducted a lineup with six witnesses in an attempt to identify the offender. The official 

Supplemental Report describing the lineup states that two of the witnesses positively 

identified James Williams, the suspect. See Bates 068528-29. The investigative file, at 

Bates 68550-51, however, also contains an informal to/from memo between detectives 

discussing the lineup. That informal memo describes how Ivan Massey, another witness 

who viewed the lineup, expressly stated that Williams was not the offender. The official 

police reports, however, contain no record of Massey’s statement. 



202 Handwritten Notes state that a witness, Kevin Williams was to be interviewed. 203 Handwritten notes list Myron Coleman as a witness to the shooting. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 366 of 433 PageID #:15787
46 

x In the investigation assigned Records Division number G-197-882, an informal to/from 

memo at Bates 90817, dated August 24, 1985 describes a statement from a witness 

named Fred Ward implicating an alternate suspect. Specifically, Ward told the detectives 

that Eddie Flowers murdered the victim as retaliation for the victim’s earlier theft of a 

major drug dealer, Melvin Summers. Another to/from memo at Bates 90845 and 90862 

describes a statement from Lamont White, in which he similarly describes a contract on 

the victim’s head by White. It does not appear that these witness accounts were 

reproduced in the official Supplemental Reports. In fact, it appears that the only other 

mention of Flowers is in a second to/from memo at Bates 90923 and in handwritten 

General Progress Report notes created on May 27, 1985—five weeks before the to/from 

memo containing Ward’s statement—but that report does not describe Flowers’ potential 

involvement in the murder. See Bates 90988-89 

x In the homicide investigation assigned Records Division number H-045-796, several 

handwritten notes and an informal to/from memo seem to implicate three people in the 

murder: Cheryl Williams, Darryl Smith, and Victor Dennis. (Bates 92423, 92427, 92502, 

and 92573). Yet, it appears that their connection the investigation is never explained in 

the official reports. Similarly, a handwritten note at Bates 92478 describes a woman 

named “Birdie” making the 911 call to report the homicide. The reporting witness is 

clearly of interest to an investigator, and should always be disclosed to the defendant. 

Yet, the official reports do not appear to include any details about the 911 call or any 

description of “Birdie.” 

x The investigative file associated with the January 24, 1987 homicide of Miguel Morales, 

Records Division number J-03-340, contains several informal to/from memos 

documenting alternate suspects and critical witness information, which was not included 

in official reports. First, a memo at Bates 93037-38 documents officers’ visit to the Perez 

household. Two brothers, Carlos and Jose Perez are listed in the supplemental reports as 

witnesses. The memo lists a third brother, Thomas Perez, who assists the officers in 

locating a sawed-off shotgun within the Perez family’s apartment. Thomas’s name and 

his role in finding the shotgun appear to have been omitted from the supplemental 

reports. A second to/from memo at Bates 93042 describes an interview with Dianna 

Mayorda, the victim's girlfriend. Mayorda reported that she had previously dated a man 

named Valentino Rivera, that Rivera was jealous of the victim, and that Rivera had stated 

“he was going to get the victim” as recently as December 1986. But the supplemental 

report that purportedly documents Mayorda’s interview, omits any mention of Rivera. 

(Bates 92981-82; 93125-26) Rather, the supplemental report states that, other than 

describing her relationship with the victim, and his past difficulty with Latin King gang 

members “she could add no more” to the investigation. Bates 92982; 93126. Finally, a 

third to/from memo, at Bates 93043, states that two witnesses after looking at 

photographs, made a possible identification of Joseph Russo as the offender. It does not 

appear that Russo’s name is mentioned in the official reports, let alone the fact that he 

was identified as a potential alternate suspect. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 367 of 433 PageID #:15788
47 

x While investigating a shooting, under Records Division number G-007-315, the 

detectives took notes of an interview with a witness named Monique Lawrence on a 

General Progress Report at Bates 83132. She reported that she saw Keith Harden and a 

second man walking down 56th street. She specifically noted that both men were wearing 

“big hats like skull caps,” but she was still able to identify Harden, whom she knew. 

Neither her name nor her statement appears in the official reports. Moreover, the fact 

that both men were wearing large hats—and that their faces may have been obscured— is 

omitted from the official the official reports. 

x At Bates 44318-19, there is a handwritten statement in one person’s handwriting, likely 

the witness’s, but that statement is continued in the detective’s handwriting. And, it is 

only in the detective’s handwriting that the suspect is identified by name. 

x After investigating the November 3, 1985 murder of John Vasquez, officers charged 

Adolfo Valdez and Francisco Sanchez on a theory that Vasquez was shot as part of a 

gang rivalry. Notes from an interview with Dawn Drew, however, provide an alternative 

motive and theory. Drew reported that on Thursday, October 31, 1985 at about 2:00 AM 

the victim came to her house to talk, and though he looked beat up, he didn’t want to say 

much about what happened. Vasquez explained “that his brother went off on him” and 

that his family was kicking him out. Drew also explained that the victim was trying to get 

out of the gang and wanted to move out of state with her, but to leave the gang, he needed 

to be “violated,” that is gang members would beat him up. That was scheduled to happen 

on Saturday, on 51st street. The victim was shot at 5116 S. Throop at 2:40 AM Sunday, 

November 3rd. Those notes of Drew’s statement are contained only at Bates 84648, in an 

informal to-from memo between detectives, and it does not appear that Drew’s name is 

included in any of the official reports. 

3. The Investigative Files themselves are incomplete 

 The investigative files themselves are consistently incomplete and often reflect the fact 

that investigative information is contained in multiple locations, rather than in one 

comprehensive file. The police investigative role is to search for and document facts – all facts 

regardless of where those facts fit into some pre-conceived theory of the investigation. Not all 

facts, information, or individuals will necessarily enhance the prosecution of an identified 

suspect. Nonetheless, those facts have to be included in the investigation. There is nothing to 

prevent the investigators from offering explanatory information that puts that information in 

perspective. It must be included – in fairness to the victims, the prosecutor, the defense, the 

court, and the jurors. The judge will eventually rule on what is relevant and admissible. To meet 

the needs of police agencies and the courts, case files must be maintained in a manner that make 

them secure, but accessible, and the case contents should be arranged in an orderly and 

consistent manner. As a corollary, all of the information must be inventoried, indexed, or 

documented in such a manner as to be easily located and the content inventory clearly 

understood. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 368 of 433 PageID #:15789
48 

It is standard police practice for major investigations to have one lead detective who is in 

charge of compiling all investigative materials. That way, once charges are filed, everything that 

does exist from the investigation is complete, identifiable, inventoried, and maintained in its 

entirety in a central location. Whether it is referred to as a permanent retention file, a “murder 

book”, a completed investigation, an open investigation, or something else. Everything should 

be in one package that can be located and produced – for whatever reason it is needed. 

While acknowledging that investigations vary in complexity, number of victims and 

suspects (if any), volume of evidence, vehicle involved, etc., any specific investigative file would 

be expected to have at least 15 or more specific types of documents, regardless of disposition or 

arrest. To have a homicide occur, police respond, and detectives assigned would produce at least 

the following forms and/or documents, and in turn they would be placed on the investigative file 

inventory and a copy of the inventory would be placed in the permanent retention file. These 

inventoried items would include: 

1. Investigative file inventory sheet / CP 23-121 (that would be in both the IF and the PR 

files) 

2. Case Assignment & Weapon characteristics form / CPD 11-418 

3. Major Crime Worksheet / CPD 23-483 

4. Homicide File Review form / No form # 

5. Investigative File control form / CPD 23-124 

6. Case Disposition / computer generated 

7. General Offense Reports / CP 11-380 

8. Supplementary Reports / CP 11-411 

9. General Progress Reports / CPD 23-122 

10. Medical Post Mortem Report 

11. Cause of Death Report 

12. Medical Examiner Toxicology Report 

13. Medical Examiner Inventory / F-808 

14. Crime Scene Processing Report / CPD 21-949 

15. Property & Evidence Inventory forms / CPD 34-523 

16. Intra Department Envelopes (to–from tracking) / CPD 11-174 

17. CPD “rap sheets” / CPD 31-903 (chronological record of arrests by CPD of victim &/or 

suspects) 

18. State and Federal “rap sheets” 

In addition, in cases where there are identified suspects, at least the following forms 

and/or documents would be in the investigative file, and in turn they would be placed on the 

investigative file inventory and a copy of the inventory would be placed in the permanent 

retention file. These additional inventoried items would include: 

1. Arrest Warrant / No form # 

2. Arrest Reports / CPD 11-420 

3. Arrest Info Card / CPD 11-430 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 369 of 433 PageID #:15790
49 

4. Photos / arrest, in-custody, crime scene, interview, etc. 

5. Statements / No form # 

6. Court Attendance form / CP 11-555 

7. States Attorney Felony Minutes forms / Referred to as “101’s” 

In addition, in cases where there are no known suspects initially, the investigative file 

would be expected to contain at least the following forms and/or documents that would be 

inventoried in the investigative file, and in turn they would be placed on the investigative file 

inventory and a copy of the inventory would be placed in the permanent retention file. These 

additional inventoried items would include: 

1. Vehicle Tow Reports / CP 11-413 

2. Handwritten notes (not on CPD forms) / No form # 

3. Handwritten statements (not on CPD forms) / No form # 

4. To-From memos (not on CPD forms) / No form # 

5. Group line up photos / no such photos found in any files examined 

6. Field Contact Cards / CPD 21-101 

7. Fugitive Arrest Receipt form / CPD 31-273 

8. Stop and Hold paperwork / CPD 31-961 

9. Identification Sheet / CPD 22-467 

10. Criminal Records Search summary / computer generated 

11. Driver’s & Motor Vehicle Records / computer generated 

12. Juvenile Field Arrest Reports / CPD 11-421 

13. Preliminary Fired Evidence Report / CP33-405 

14. Request for Analysis – Receipt for Exhibit / CPD 33-100 

15. Crime Laboratory Reports / CPD 33-103 

16. Search Warrant Affidavits and Returns / 

17. Grand Jury Subpoenas / CR 34A 

18. Crime Pattern Reports / computer generated 

19. Offender Listing by Address / computer generated 

20. Victim Listing by Parameters / computer generated 

21. Miscellaneous Incident Exception Report / CPD 11-419 

22. Court Notifications / CPD 11-554 

23. Court Complaint Transmittal Listing form / CPD 11-551 

24. Extradition documents / no form # 

25. Xerox images of miscellaneous evidence (matchbooks, keys, vehicle registrations, family 

photos, etc.) 

The files I reviewed, however, clearly demonstrate that the investigative files do not 

serve as this central repository for information. My review of the files revealed numerous cases 

where information that should be included was absent from the investigative file, suggesting that 

it may have been lost or stored in separate files. Examples of such missing information include: 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 370 of 433 PageID #:15791
50 

x No explanation on photographs, such as when or where the photo was taken, who is 

depicted in the photograph or why the detectives believe it is relevant to the investigation. 

(e.g. 120234; 120536-120560). The missing information suggests that the paperwork, 

notes, or other investigative materials that led to the photograph was maintained 

separately from the investigative files and was not included in the investigative file. 

x Missing reports including ballistic reports, AFIS reports, crime lab reports, CAD and 911 

reports. 

x Missing forms, such as missing property inventories and Major Crime Worksheets. For 

example, RD D-304-807, Bates 09501-096049, contains no Major Crimes Worksheet. 

x Other missing forms or documents including missing medical records, missing property 

inventory forms, or missing search warrant affidavits, and missing search warrant returns 

x Lack of itemized, detailed, chronological investigative steps 

x Some cases have investigatory computer generated phone records, in others they are hand 

written by an unknown investigator but not included in official reports, suggesting that 

the original source for the phone records was stored separately or not properly retained. 

x Similarly, in some files there are handwritten summaries of criminal records (e.g. Bates 

46636), but no reference in official forms, and no official printout, implying that the 

source of the information was stored separately 

x Blank or missing chain of command homicide review forms (Bates 52919 & 53066) 

x Many, many totally illegible pages not explainable by “bad copies” (Bates 45369-45307-

45297) 

x Most missing crime scene photos, suggesting that the reports from Crime Scene 

technicians were not included in the investigative file. For example, the investigation 

under N-238-887 includes an Evidence Report at Bates 0671161 that documents 6 

different photographs taken of the crime scene. Those photographs do not appear in the 

investigative file. 

In some instances, the investigative file specifically referenced a piece of evidence, a 

statement, or other information, but the corresponding evidence or statement was not 

documented in the file. E.g. 

x References in handwritten notes to the involvement of other units or outside agencies, but 

not included in official reports, and involvement not described (“ATF dropped off info”) 

x No live lineup photos, where there are lineup reports. For example, at Bates 067136, a 

line-up report documents a live lineup for the investigation under RD N-238-887 and 

states that photographs were taken by Detective Moser, but there are no photographs in 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 371 of 433 PageID #:15792
51 

the investigative file. Under RD number G-500-512, reports at Bates 091761 and 091803 

note that photographs were taken of a lineup, but no lineup photographs appear in the 

investigative file. 

x Reports mentioned (often in handwritten notes) that were not referred to in official 

reports, and not included in file. For example, at Bates 078838 a Supplemental Report 

states that the suspect took a polygraph test and failed, yet there is no corresponding 

Crime Lab Report from the Crime Laboratory Division Polygraph Unit documenting the 

polygraph test or results. 

x Evidence reports documenting specific photographs taken as part of the investigation, but 

photographs are not included in the investigative file. In the investigation under RD N213-223, an evidence report at Bates 066853 lists photographs taken of the scene, and of 

the victim’s wounds. A crime scene report in that case, at Bates 066794, states that a 

technician was assigned to take photographs of a pair of eyeglasses and the box they were 

found in. The report lists 9 photographs taken of the glasses. None of the photos listed in 

these reports are included in the investigative file. 

x Reference to other units or outside agencies processing evidence, but no documentation 

in official reports and not results, and no chain of custody. For example, a handwritten 

note at Bates 091866 states that a technician from the Firearms Section stated that two 

metal fragments that had been recovered were “partial bullet possible ‘38” and “cannot 

be compared.” But there is no corresponding report from the Firearms Section in the 

investigative file, indicating that the documents produced by that section were maintained 

separately from the investigative file. 

x Numerous Xeroxed handwritten spacer/filler pages with A3/VC, which would indicate 

other sources for relevant documents that may, or may not, have been included (Bates 

066798; 067122; 91794). Other examples include listing detective’s names and unit 

numbers on blank pages, suggesting that information is coming from other, unidentified 

sources. (Bates 091857; 091864). 

Other, miscellaneous deficiencies in the files include: 

x Suspicious “corrections” on transcribed sworn statements. For example,Bates 59722 

includes a reference to “Miracle” the dog which, would have actually been explored in 

the interview. 

x Unrelated (Union negotiations, news articles) non-case material interspersed in folders 

These repeated and consistent failures to properly document and include all investigative 

information within the investigative file, demonstrates the Chicago Police Department’s top 

down pattern and practice of failing to seriously try to correct bad practices or overcome the 

harmful outcomes shown in prior relevant successful litigation against CPD. 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 372 of 433 PageID #:15793
52 

To further exacerbate these issues, the CPD maintains and utilizes a multitude of often 

conflicting, confusing and duplicative documents and nomenclature that make tracking and 

documenting material often difficult and/or impossible: 

x GPR (general progress reports) 

x GIS (gang information supplementary reports) 

x DDSF (detective division street files) 

x DR (daily report) 

x SR (supplemental report) 

x MIW (major incident worksheet) 

x AR (activity report) 

x GOCR (general offense case report) 

x ICFF (investigative case file report) 

x IFI (Investigative File Inventory) 

x MDR (miscellaneous document repository) 

x RD (police report) 

x “Humper” (daily activity report) 

x “Serafini” reports (ad-hoc) 

x DDSO (detective division special orders) 

x DGO (department general orders) 

x CRU (case report unit) 

4. Permanent Retention Files Contain Limited Information 

Nor can the permanent retention files, which are stored centrally within the Records 

Division, serve as the central repository for investigative information. By design, the PRFs do 

not include all investigative materials. The PRFs that I reviewed demonstrate that the PRF 

provides an incomplete picture of an investigation. 

I was provided with digital copies of 15 permanent retention (PR) files, along with the 

corresponding 15 investigative files from Area 3 – Violent Crimes. The 30 files contained a total 

of 1,867 pages. I examined, compared and contrasted the 15 permanent retention files with their 

corresponding investigative files (IF). 

Although all of the investigative files had the required inventory sheet, only 47% (7 of 

the 15) of the permanent retention files contained the required copy. 

The comparative ratio of file sizes (pages) in the permanent retention files compared to 

the investigative files ranged from as low as 11.65% to a high of 54.29%. The permanent 

retention files contained no handwritten notes, GPRs, or to/from memos between detectives, 

which means that information contained solely in those unofficial reports (and not transcribed 

onto supplementary reports) is not included in the permanent retention files. The comparative 

ratio of file sizes, and the failure to include handwritten notes, is a symptom of the unchecked 

discretion allowed individual detectives and units in determining what is, or more importantly, 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 373 of 433 PageID #:15794
53 

what is not placed into supplementary reports and the permanent retention file, regardless of the 

Chicago Police Department’s deficient policies. 

The department’s policy of failing to include handwritten notes or to/from memos and 

other internal, unofficial documents in the records division file also means that defendants may 

not be able to accurately identify the source of a statement. For example, at Bates 44318-19, 

there is a handwritten statement in one person’s handwriting, but that is continued in the 

detective’s handwriting, and that now identifies the suspect by name when the witness had not. 

The investigative file inventories that were included in the PRF were often incomplete. 

Items routinely missing from inventory lists included in the PRF included: 

Handwritten names, addresses, vehicle license plates, phone numbers, physical 

descriptions, dates, unknown abbreviations, symbols, other case numbers, and miscellaneous 

notes were found throughout most of the investigative files. These types of items were found 

written across official forms, on plain paper, and on file folder covers. Most were not referenced 

or located in any permanent retention file inventories, and may have had value for discovery 

purposes. 

Some specific noted discrepancies: 

E-467-516: The IF contained 46 pages and the PR contained 13 pages (28.26%). A copy 

of a 1-page inventory (25 entries) form was found in the Permanent Retention File as 

required. 22 items were entered by the same individual on the same date. The 

inventories in the Investigative File and PR file do not match: The Investigative File 

contains 2 pages of Inventory, and has a total of 28 items. The missing 3 items pertain to 

Court Attendance Sheets, FAX Cover Sheet, and Medical Post-Mortem. The PostMortem report would be very important for discovery. In addition, the required 

inventory sheet omitted reference to a number of other items contained in the 

investigative file. Some, but not all of the un-inventoried items included the Case 

Assignment sheet; Investigative File control; Case Disposition; Post Mortem Report; 

General Offense Report; Arrest Report; Identification Sheet; Laboratory and Evidence 

Sheets; Search Warrant Inventories; etc. All very important for discovery. 

J-433-864: NO INVENTORY SHEET IN PR. The IF contained 64 pages and the PR 

contained 15 pages (23.44%). There was a 2-page inventory (26 entries) form in the 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files that 

did not contain a copy of the Investigative File Inventory form. Therefore, a request for 

discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

J-500-287: NO INVENTORY SHEET IN PR. The IF contained 109 pages and the PR 

contained only 19 pages (17.43%). There was a 2-page inventory (40 entries) form in the 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files 

that did not contain a copy of the Investigative File Inventory form. Therefore, a request 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 374 of 433 PageID #:15795
54 

for discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

K-108-072: The IF contained 157 pages and the PR contained 26 pages (16.56%). A 

copy of a 1-page inventory (25 entries) was found in the Permanent Retention File as 

required. It itemizes 21 items as General Progress Notes; 3 items as Written Notes; and 1 

item as Diagram. All 25 items were entered by the same individual on the same date. 

The Investigative File actually contains 3 pages of Inventory, containing 70 items. Some 

of these missing items are very important to discovery, such as line-ups, crime laboratory 

reports, evidence sheets, statements, handwritten notes with names of witnesses, suspects, 

etc. Other significant items contained in the investigative file were NOT shown on the in 

the inventory Some, but not all of the un-inventoried items included the Case 

Assignment Sheet; Felony Minutes; Major Crime worksheet; Investigative File control; 

Case Disposition; Cause of Death Report; Post Mortem Report; Statements; Arrest 

Report; Arrest Warrant; Statements; Miscellaneous photos; Evidence & Lab Reports, etc. 

All would be very important for discovery. 

K-189-303: The IF contained 88 pages and the PR contained 15 pages (17.05%). A copy 

of a 2-page inventory (33 entries) was found in the Permanent Retention File as required. 

The Investigative File also contains 3 pages of Inventory, but has a total of 38 items. The 

missing 5 items pertain to the SA case disposition and Court Attendance Sheets. Other 

significant items contained in the investigative file were NOT shown on the in 

investigative file. Some, but not all of the un-inventoried items included Case 

Assignment Sheet; the Major Crime worksheet; Investigative File control; Case 

Disposition; Court Attendance Reports; Miscellaneous photos; etc. All are very 

important for discovery. 

K-369-369: The IF contained 70 pages and the PR contained 19 pages (27.14%). A copy 

of a 2-page inventory (29 entries) was found in the Permanent Retention File as required. 

It itemizes 16 items as General Progress Notes; 2 items as Written Notes; 1 as Medical 

Examiner Report, and 1 item as an evidence sheet. All 20 of these noted items were 

entered by the same individual on the same date. The Investigative File also contains 2 

pages of Inventory, but has a total of 35 items. The missing 6 items pertain to the SA 

case disposition, Court Attendance Sheets, and Report of Post-Mortem. The PostMortem report would be very important for discovery. Some, but not all of the uninventoried items included Case Assignment Sheet; Case Disposition; Court Attendance 

Reports; Preliminary Fired Evidence; etc. All are very important for discovery. 

M-049-190: The IF contained 144 pages and the PR contained 35 pages (24.31%). A 

copy of a 3-page inventory (67 entries) was found in the Permanent Retention File as 

required. However, the Investigative File Inventory has a total of 70 items. The missing 

3 items pertain to the Medical Examiner Report, SA case disposition and Court 

Attendance Sheets. The Medical Examiner Report would be very important for 

discovery. Some, but not all of those un-inventoried items included Case Assignment 

Sheet; Investigative File control; Case Disposition; Court Attendance Reports; 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 375 of 433 PageID #:15796
55 

Supplementary Reports; Grand Jury Subpoena; Crime Scene Processing Report; 

Miscellaneous photos; etc. All are very important for discovery. 

M-050-920: The IF contained 58 pages and the PR contained 19 pages (32.76%). A copy 

of a 2-page inventory (30 entries) was found in the Permanent Retention File as required. 

The first page has 20 entries with 5 empty rows. 19 items were entered by the same 

individual on the same date, and 10 items were entered by another individual on page 2 

on a different date. However, the 2nd page of the inventory with 10 items appears to be 

for an unrelated case (M-050-978). The Investigative File also contains 2 pages of 

Inventory, but has a total of 31 items. The 5 empty rows on the first page have been 

filled in (medical examiner’s report; court attendance; subpoenas; and lab reports). The 

second page has 6 pages and does not have a case file number. It contains court 

attendance documents and the SA final deposition. The omitted reference to the medical 

examiner’s report would be very important for discovery. Some, but not all of those uninventoried items included Case Assignment Sheet; Case Disposition; Court Attendance 

Reports; Post-Mortem Report; Arrest Report; General Progress Report; etc. All are very 

important for discovery. 

M-051-29: The IF contained 71 pages and the PR contained 26 pages (36.62%). A copy 

of a 2-page inventory (33 entries) was found in the Permanent Retention File as required. 

It itemizes 12 items as General Progress Notes. 25 items were entered by the same 

individual on the same date. The Investigative File also contains 2 pages of Inventory, 

but has a total of 35 items. The missing 2 items pertain to subpoenas and medical 

examiner’s report. The omitted reference to the medical examiner’s report would be very 

important for discovery. Some, but not all of those un-inventoried items included Case 

Assignment Sheet; Investigative File control; Supplementary Reports; Court Attendance 

Reports; Post-Mortem Report; Miscellaneous photos; etc. All are very important for 

discovery. 

M-227-539: NO INVENTORY SHEET IN PR. The IF contained 140 pages and the PR 

contained 31 pages (22.14%). There was a 3-page inventory (52 entries) form in the 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files 

that did not contain a copy of the Investigative File Inventory form. Therefore, a request 

for discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

M-487-817: NO INVENTORY SHEET IN PR. The IF contained 35 pages and the PR 

contained 19 pages (54.29%). There was a 1-page inventory (13 entries) form in the 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files 

that did not contain a copy of the Investigative File Inventory form. Therefore, a request 

for discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

M-490-308: NO INVENTORY SHEET IN PR. The IF contained 76 pages and the PR 

contained 22 pages (28.95%). There was a 2-page (37 entries) inventory form in the 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 376 of 433 PageID #:15797
56 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files 

that did not contain a copy of the Investigative File Inventory form. Therefore, a request 

for discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

N-180-889: NO INVENTORY SHEET IN PR. The IF contained 266 pages and the PR 

contained 31 pages (11.65%). There was a 2-page inventory (31 entries) form in the 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files 

that did not contain a copy of the Investigative File Inventory form. Therefore, a request 

for discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

N-540-560: NO INVENTORY SHEET IN PR. The IF contained 130 pages and the PR 

contained 25 pages (19.23%). There was a 3-page inventory (73 entries) form in the 

Investigative file. However, this is one of the 8 (out of 15) Permanent Retention Files 

that did not contain a copy of the Investigative File Inventory form. Therefore, a request 

for discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

P-174-126: NO INVENTORY SHEET IN PR. The IF contained 80 pages and the PR 

contained 18 pages (22.50%). There was a 2-page inventory (39 entries) form in the 

Investigative file. This is about the best inventory form of the 15 that were examined in 

this group. However, this is also one of the 8 (out of 15) Permanent Retention Files that 

did not contain a copy of the Investigative File Inventory form. Therefore, a request for 

discovery would NOT show what was purported to be in the investigative file and 

discovery would be significantly restricted. 

Finally, the Permanent Retention files do not always include all of the “official” 

documents produced in a case. For example, 

RD K-108-072: 14731: Supplemental Report that discusses the arrest of the defendant 

was not part of permanent retention file. 14755-14758: Defendant statement, that was 

not part of permanent file, including additional details of the defendant's account of the 

events on the night of the murder, as well as the fact he knew the victim as "Stony." 

RD: N-540-560: 12483: Supplemental Report that is missing from the official record. It 

discusses detectives locating the defendant in Texas and transporting him back to 

Chicago. 

 

5. Inventories incomplete or no indication sent to Records Division 

Finally, the City claims that, even if investigative information is contained in multiple 

files, rather than in a central location, the investigative file inventories serve as a backstop to 

ensure that all investigative materials are discoverable. In my opinion, however, the 

investigative file inventories are essentially worthless to ensure discovery. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 377 of 433 PageID #:15798
57 

First, as discussed above, less than half of the PRFs that I reviewed included inventories, 

undermining any inference that defendants routinely had access to those inventories. 

 Second, even if defendants did have access to the inventories, those inventories do not 

comprehensively or accurately document the contents of the files. The vast majority of the 

investigative case file inventory forms were either so generic as to be worthless, for example 

including overly generic entries, such as “GPR” with no date, number of pages, or author. 

Inventories were also incomplete as it pertains to handwritten items, or were missing all together 

(e.g.City_Klup_38750) In some instances, they cross reference another case file that is not 

included (e.g. City_Klup_53064) 

 Plaintiff’s attorneys provided me with an index of the 660 investigative files, 515 of 

which were marked as containing inventories. That index also documented whether, in the files 

that contained inventories, the inventories accurately documented the contents of the 

investigative file. In other words, whether the number and type of documents contained in the 

file matched the entries on the inventory, or whether there were documents in the file that were 

missing from the inventory. With the index sorted by RD number, I spot-checked approximately 

10% of the 515 files with inventories, by selecting one file out of every 10-15, reaching a total of 

49 files. I found the Plaintiff’s attorneys’ characterization to be accurate in each case. Based on 

the complete index of the 660 files, I conclude that 82% of the files (540/660) had an incomplete 

or missing inventory. And of the files with inventories, 76% of the inventories inaccurately 

documented the contents of the investigative file. 

I also noted that documents were often added to the inventory long after they were 

initially created. In some instances, investigative file inventories were not created until after an 

offender had been charged. For example: 

E-467-516: The defendant was arrested December 11, 1983, the same day as the offense 

and charged the next day, Dec. 12. On the Investigative File inventory there are 22 entries 

made on Dec. 28, 1983 by the same person and there are 3 more from Jan. 22, 1984. 

J-555-952: The offense took place on December 28, 1987, and began as an aggravated 

battery investigation. The victim died January 4, 1988 and the defendant was arrested the 

same day for murder. But the ASA rejected charges. It isn’t until January 7, 1988 that 

anything is entered on the investigative file inventory, and the vast majority (38/45) of 

the entries were made the same day. 

N-238-887: Offense occurred May 27, 1990 and first Supplemental Report is produced 

by May 28, 1990 (Bates 67143) documenting interviews with 5 witnesses and a canvass 

of the neighborhood. There are also several GPRs from May 27-30 (Bates 67189-

67202). Willie Benson was arrested on May 29, 1990 but was released without charging. 

Maurice Davis was arrested and charged on May 30, 1990. Officers continued 

investigating Benson, but he was never charged. Though the investigation resulted in 

charges on May 30, 1990 detectives did not begin keeping an inventory until June 6, 

when a single individual entered the first 50 entries on the inventory. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 378 of 433 PageID #:15799
58 

 The delay in creating an inventory for the investigative file reveals three problems. One, 

it again demonstrated the amount of discretion that officers could exercise when deciding what to 

put into the investigative file: if the inventory is only created after an individual is charged, 

detectives can exercise discretion over what they deem relevant at the end of an investigation. 

Second, if the documents are not logged on the inventory until after the charges are brought, that 

indicates that documents are being stored in other, undisclosed locations during the course of the 

investigations, which was precisely the problem the special orders sought to address. Finally, if 

detectives obtain additional information after charges are brought, they may add material to the 

investigative file without having to update the inventory in the Records Division. 

The same deficiencies in inventories that I saw in the homicide files infected the files in 

Kluppelberg’s case. First, there is no inventory in the Kluppelberg PRF at all. That is, there is no 

inventory from any Bomb & Arson investigative file (presuming that there was once one) nor is 

there a copy of the inventory for the Area 3 1988 investigative file. Nor does the PRF include is 

an inventory from the 1984 Area 3 investigative file—although no such inventory would have 

been required to be included in the Records Division file pursuant to Special Order 83-2 because 

no charges were lodged against Kluppelberg following the 1984 investigation. Instead, the case 

was closed as noncriminal, apparent accidental deaths. This again demonstrates how the gap in 

the policy creates a significant problem – particularly for cold cases like Kluppelberg’s where a 

re-investigation of the case is done years later (and without regard to the initial investigation). 

Because the PRF, by design, does not contain all documents in any given file, without including 

a copy of each and every inventory for each and every investigative file in the PRF, there is no 

guarantee that a criminal defendant will even be aware that other investigative files exist. 

Second, the 1988 Area 3 investigative file is incomplete. In particular 

x There are only are only 3 "written note" entries on the inventory, but 6 full 

pages with handwritten notes in the file (see pages 55, 57, 62, 66, 68, 105/108 

[same]). Plus, there are a large number of handwritten notes on scraps of 

paper/folders (e.g., pages 113-16, 119-129 (it appears that a lot of these notes 

are written on the back of case assignment slips) 

x Grand jury subpoena at pages 120-21 is not listed 

x Major Crimes Worksheet at pages 104/107 is not listed 

x Inventory lists just "photo" but there are 11 photographs (pages 136-46) 

Also, the way that the Inventory documents the 9th District supplementary reports and 

B&A reports makes it very difficult to tell if they are all included in the file. The entries for 

those reports do not list the date of the supplementary reports, and the supplementary reports are 

split up throughout the file. As such, even if the Inventory is not missing these reports, it 

certainly would have been hard for another officer or an attorney to figure out exactly how many 

and which reports are reflected on the inventory and whether they received a complete copy of 

those reports. 

Third, the inventory in the “New File” is incomplete. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 379 of 433 PageID #:15800
59 

x It lists 9 pages of "written notes" but there are at least 11 pages (pages 11/19 

[same], 18, 20-22, 24, 26-29, 49 

x It lists 2 pages of GPRs, but there are 3 pages of GPRs (pages 15-17) 

x Also, the inventory just lists "RD 104537" but there are 7 pages, comprising 2 

or 3 documents with that RD number, so the inventory provides no indication 

about what documents “RD 104537” refers to (pages 41-47) 

x Similarly, the inventory just lists as an entry "RD 105358" but it does not tell 

provide any detail about which documents under that RD number are included. 

Fourth, the 1988 Area 3 investigative file inventory appears to have been filled out 

entirely on one day – February 2, 1988, again revealing a gap in the CPD’s policies: Pursuant to 

the Special Orders, there was no requirement that inventories be filled out contemporaneously. 

Moreover, inventories did not need to be sent to the Records Division until charges were lodged. 

As a result, this left too much discretion to the individual detective to determine what to retain in 

the file – and hence what would go onto the inventory – at the end of his or her investigation. 

As such, even had a criminal defense attorney received the investigative file inventories – 

which in this case were not even part of the PRF – they were wholly incomplete and an 

insufficient mechanism to ensure that a criminal defense attorney was either put on notice of or 

provided with a complete set of documents. There is no reason to think that this aspect of the 

Kluppelberg case different in any significant way from how other similar cases were handled, 

based on my review of the homicide files, as well as the depositions in this case. 

Opinion #11: The Special Orders Issued Were a Deficient Cure to the Problem of Street 

Files 

Although then-Superintendent Richard Brzezcek testified that the problem of street files 

and the preservation of investigative documents was CPD’s responsibility – and notwithstanding 

that this problem was a “big deal” – the CPD response was wholly inadequate.204 According to 

Brzezcek, the only change that CPD made in the immediate aftermath of the street files problem 

was Notice 82-2.205 That Notice, however, was wholly deficient as a mechanism to eliminate the 

use of street files, and was followed by a series of special orders, described above, that were also 

deficient. Moreover, despite the fact that the use of street files was deeply ingrained within CPD 

– or at least within the detective division – there was little training offered and virtually no 

oversight to ensure elimination of the practice. 

A. Importance of the Issue 

It is fair to say that in any agency some matters are considered “high risk” to the 

institution and are always brought to the head of the agency’s (and his/her command staff’s) 

attention. They can range from wide spread threats to public safety (patterns of violent crime, 

terrorism, etc.), to officer involved shootings, to high-risk policies (use of force, police pursuits, 



204 Brzezcek Test. 4577-78; Hickey 205-207 205 Brzezcek 4574-75 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 380 of 433 PageID #:15801
60 

etc.), and to such “mundane” things as risk management (adverse findings in law suits). Any 

responsible Police Chief, Police Superintendent, or Sheriff in the United States has regularly 

scheduled staff meetings to be briefed on such matters. Here, as Hickey has acknowledged, the 

issue of “street files” was a big deal. Brzeczek and other high-ranking officials within the CPD 

were aware of the problem, and as Brzeczek testified, took accountability for them. 

The problem of “street files” should not only have been at the forefront of policymakers’ 

attention in 1982 and 1983, but should have continued even after the Special Orders were 

enacted (and the updated Special Order 86-3 suggests that personnel were aware of their 

continuing obligation to monitor the issue). Based on my experience, when you run a police 

department of this size, policymakers are aware of department-wide issues of a very serious 

nature. Particularly when an issue results in court-action – like the street files problem did – that 

would be an issue of a very serious nature. As a result, policymakers would have and should 

have kept themselves apprised of whether and how the issue was resolving . 

B. Judge Shadur identified problems with the language and scope of the orders, 

which was not corrected 

In his opinion, Judge Shadur identified several areas in which Special Order 83-1 fell flat. 

In particular, and as described above, he found that 83-1 should also include the following 

provisions: 

x The CPD should open an Investigative File Case Folder in all violent crime field 

investigations not just in certain categories of cases or once felony charges or 

approved. 

x Take and maintain complete notes of all relevant matters during the course of an 

investigation. 

x Direct any detective who receives information relating to a violent crime 

investigation that is not assigned to him to forward the information he receives to 

the detective in charge of the case; 

x Transmit two copies of the Investigative File Inventory Sheet to the Office of 

Legal Affairs of the Department of the Cook County State’s Attorney’s Office 

whenever a subpoena or discovery motion is received so that one copy can be 

given to defense counsel; and 

x Assure that the CPD’s Training Division develop a program to educate detectives 

in the new procedures.206

 These changes, however, were not enacted with Special Order 83-1. 

C. CPD Response Still Allowed For Multiple Files With Different Content 

In fact, even where later Special Orders did address some of the deficiencies identified by 

Judge Shadur, they still fell short. First, the Special Orders still allowed there to be multiple files 

with different documents and different content in multiple places. This practice – particularly 

given the history of the street files practice – was unacceptable. 



206 Palmer v. City of Chicago, 755 F.2d 560 (7th Cir. 1985), P 2532 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 381 of 433 PageID #:15802
61 

In fact, in reviewing the materials provided, I identified at least three different files that 

would be created relating to any criminal investigation even once the Special Orders regarding 

file creation, maintenance and preservation were issued. First, there would be a permanent 

retention file in the Records Division. According to Hickey, this file would contain only 

supplementary reports, general offense case reports and the arrest report filed under the 

accompanying RD number.207 Second, there would be a unit RD file: Hickey testified that this 

was a slim file kept in the homicide drawer at the Area to identify that there is a case open.208

Like the permanent retention file, it would contain all the known official police reports: original 

case offense report, supplementary reports, and reports sent to the investigative unit from support 

units.209 Third, there would be the investigative file maintained by the area or any specialized 

unit.210 This file would contain documents that individual detectives assigned to investigate the 

case have determined should be in there.211

As noted above, none of the files had to have the same documents in them: In fact, by 

design, they did not.212 Likewise, Hickey admitted that the files did not even necessarily have the 

same information in them.213 

The problems created by such an unwieldy system are obvious: It creates the potential for 

information and documents to go missing because they are not centrally controlled. For example, 

in this case, the Bomb & Arson investigative file has not been found or produced. 

Moreover, because the files are designed to be different and to be retained in different 

locations, there is no way to ensure that the investigative file – which is retained at the Area – is 

produced during any criminal prosecution. As described more fully below, if there is no 

guarantee that any documents beyond those maintained at the Records Division are produced 

during a criminal prosecution, then whatever different information is in the investigative file – 

potentially exculpatory or impeaching – will never reach the hands of the criminal defendant. 

D. There was Too Much Discretion Given to Detectives About What to Document 

and How to Document 

In addition to the problem of multiple files, the Special Orders do not sufficiently dictate 

what information needs to be recorded. Rather, the Orders allow for substantial discretion on 

what information to document – and even how to document that information. 

1. The Special Orders Left it Up to the Detective to Determine What to 

Document 



207 Hickey [2015] 22-23, 95-96 208 Hickey 115-16 

209 Hickey 115-16; S.O. 86-3 210 Hickey 297-300 211 Hickey 297-300 212 See for examples Hickey [2015] describing documents that would go in the investigative file but not in the 

permanent retention file at 71-72, 81, 91, 94, 100, 103, 105, 108-110 

213 Hickey [2015] at 100 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 382 of 433 PageID #:15803
62 

The Special Orders provide no instruction on what has to go into a supplementary report. 

Notwithstanding the fact that the supplementary report was the official CPD police report that 

would be retained at Records Division and therefore disclosed to the prosecutor and defense, the 

Special Orders are silent on what must be included in this critical document.214

Moreover, while the Special Orders explain that a detective is required to record all 

relevant information and transcribe relevant information on a GPR or memo into an official 

report, the Special Orders nowhere explain what is “relevant.” As the former Commander of 

Area 3 testified, what is relevant to one detective may not be relevant to another detective.215

Moreover, Hickey testified that “relevant” is limited in scope. In particular, Hickey explained 

that information is relevant and therefore has to be recorded or transcribed pursuant to the 

Special Orders only if it is still relevant at the time that a detective is writing up his or her 

supplementary report and if the detective gives that information some credence.216 

The failure to provide some guidance on the meaning of “relevance” and the narrow 

interpretation of relevance adopted by the City gave detectives far too much discretion in what 

had to be documented. This is particularly true because the status quo had previously been not to 

record or document information – at least not on official documents that would be maintained by 

CPD and disclosed to the prosecution and defense. As a result, to overcome this culture – and 

this citywide practice – CPD had to be explicit in its requirements and provide direct guidance 

about what did or did not have to be documented; it is not enough to leave it up to the individual 

officer. When that is done in circumstances like the one at issue here, the bad practices of the 

past tend to repeat themselves. 

2. No Requirement to Document Elimination of Suspects 

In fact, what I found particularly troubling in reviewing the materials relevant to this case 

is the fact that the Special Orders did not require detectives to document the identity of or 

investigative steps taken to eliminate particular suspects. After the Laverty disclosure and Jones 

litigation, the CPD undertook its own internal audit and identified as one of the main components 

of “street files” documents (be it memos or case or supplementary reports from other crimes) that 

are “utilized in suspect elimination and identification . . . .”217 (In fact, one of Laverty’s “street 

files” memos dealt with a possible alternative offender.) As Hickey explained, substantive efforts 

were going undocumented as part of the investigative storyline.218 Nonetheless, the CPD did 

nothing to address this identified problem. 

Indeed, Hickey testified that it was not the policy of the CPD to require detectives to 

document suspects who were eliminated.219 To the contrary, it was permissible and consistent 

with the Special Orders not to document the identity or investigative steps taken to eliminate a 

suspect if a detective did not think that information was relevant or if the detective discounted it 



214 Hickey [2015] 20 215 Stibich Test. P4500, 4505, 4515-17 216 Hickey 339; Hickey [2015] 24-25, 33, 61, 90-91 217 Brady & Tolliver P2459; Hickey 165-66 218 Hickey 165 

219 Hickey 237-38 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 383 of 433 PageID #:15804
63 

for some reason.220 In this case, that policy meant that none of the 1984 detectives investigating 

the Hermitage Fire (be they Bomb and Arson or Area 3) had to document information about 

Isabel Ramos – including her oral statement to Detective Micek – if they discounted it or if they 

determined it was not relevant because the case was closed as a noncriminal fire. Stated 

differently, as a result of the City’s policy, the detectives were not required to include critical 

information about an alternative offender in any supplementary report or other official document 

in Kluppelberg’s case. That is simply improper and unacceptable. 

3. No Requirement that Documents be Shared 

Relatedly, the Special Orders and CPD’s response to the street files problem failed to 

sufficiently address the sharing of information between and among different units. Special Order 

83-1 was completely silent on detectives sharing information about cases between and among 

each other. While Special Orders 83-2 and 86-3 contained a provision requiring detectives to 

share information, that provision was deficient because it provided no guidance on how that 

sharing was to take place and what information was to be memorialized where. 

As Hickey explained, Special Order 83-2 obligated a detective investigating case A with 

information about case B to turn over that information to the detective investigating case B. But 

the Order (and 86-3 that followed) did not require either detective to create a document with the 

information about case B; it could simply be communicated orally.221

 Moreover, the Special Orders were silent on distribution.222 In other words, CPD had no 

policy on how or when to share documents between and among units. That meant that different 

units investigating the same crime were not required to share documents, even if those 

documents may have been highly pertinent to the crime.223 So a GPR, memo or supplementary 

report created by Area 3 might not make into the Bomb and Arson investigative file for the same 

crime. 

Worse yet, CPD policy also did not require a copy of a supplementary report listed under 

the RD for case A to go into the official file for case B even if it discussed information relevant 

to case B because the supplementary report was listed under the RD number for case A.224 

According to Hickey, documents were filed based on RD number without reference to their 

content.225 In this case, that meant that CPD policy did not require a copy of Detective Micek’s 

report documenting Isabel Ramos’ oral statement to him to go into any – let alone the official – 

file for the Hermitage fire because that report was listed under the RD number for the Marshfield 

fire. 



220 Hickey 339; Hickey [2015] at 66-67 221 Hickey 236-37 222 Hickey [2015] 39 223 Hickey [2015] 43, 46 224 Hickey 356-58; Hickey [2015] 95 225 Hickey 356-58 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 384 of 433 PageID #:15805
64 

By compartmentalizing documents in this way and failing to require document sharing 

between and among detective units, there is a grave risk that critical information – even if orally 

communicated from one detective to the next – is not going to make its way to the prosecution or 

defense. 

4. Still Permissible to Use Non-Official Forms 

Finally, in addition to providing detectives with too much discretion about what to 

document, the Special Orders also provided detectives with too much discretion about how to 

document information – at least as applied in practice. Hickey testified that if a detective writes 

down his investigative activity on any piece of paper – regardless of whether it is on an official 

format – and that paper makes its way into the investigative file, the detective has satisfied 

Special Order 83-1 and 83-2.226 Indeed, during his testimony, Hickey repeatedly explained that 

as long as information was documented, the format of that documentation – whether it is on a 

GPR or interwatch memoranda – was not relevant and the document would be accepted.227

Likewise, Hickey testified that detectives were still permitted to take notes on blank forms.228 

From what I can tell from my review of the pallet and homicide files, there were 

innumerable examples of memos or notes taken on a blank piece of paper. In no instance, did 

there appear to be a request to re-transcribe that information onto a GPR – and in some instances, 

the non-conforming or non-official document was the only place that the information appeared 

(e.g., it was not transcribed onto a case or supplementary report). This is in line with Hickey’s 

testimony that as long as the information was written down, it was accepted as compliant with 

the order. 

The problem with this approach is that it signals that the old ways – the ways of street 

files that the CPD should have been trying to correct – are acceptable. It creates a slippery slope: 

first allowing detectives to use non-official forms, then allowing them to keep the documents or a 

parallel file for their own use, and then keeping that information out of any official file. It is not 

only that best practices require enforcement of Special Orders to give them teeth, but also, given 

the circumstances here, strict adherence was necessary to create a new culture and practice so 

that detectives would not fall back into the old unlawful habit of using street files. 

E. Limited in Scope 

Another way in which the Special Orders were defective is their limited scope: they only 

applied to detectives (and violent crimes detectives at that). For example, although multiple 

squads, units, divisions, etc. might be routinely involved in a homicide investigation, Special 

Orders 83-1 and 86-3 were directed only to detectives and not to gang crimes or other police 

officers. This resulted in, and apparently continues to result in, conflicting and incomplete 

investigative practices in serious crimes. 

In fact, Hickey testified that he raised the fact that Special Order 83-1 was only addressed 



226 Hickey 373 227 Hickey [2015] 21, 67, 73-74, 78 228 Hickey [2015] 67 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 385 of 433 PageID #:15806
65 

to the Detective Division and that the Department might want to look beyond the detective 

division to see if the problem extended to other units.229 In fact, at some point, Hickey suggested 

that perhaps Research and Development and Auditing Internal Controls Division should get 

involved because there may be department-wide implications to the use of street files.230 But 

there was no response from the chain of command to Hickey’s concerns and CPD never looked 

to see if the problem of street files went beyond the Detective Division. This failure to look 

beyond the detectives – notwithstanding the fact that they worked closely with other units in 

investigating crimes – was deficient. 

F. There was No Mechanism to Ensure Complete Response to Subpoena or 

Motion for Discovery 

Finally, the Special Orders were deficient because there was no mechanism put into place 

in the Special Orders to ensure that the CPD provided a complete response – and produced all 

documents – when it received a subpoena, motion for discovery, or request from prosecutors. 

According to Hickey, when a request for investigative documents is made to the Chicago 

Police Department, that request goes to the Records Division, Subpoena Service Unit.231 A 

sergeant was in charge of the Subpoena Service Unit, and that sergeant reported to the assistant 

director and director of the Records Division.232 It was the Record Division director’s 

responsibility to set policy at the Subpoena Service Unit.233 

The Chicago Police Department had no written policy that he was aware of dictating how 

the Subpoena Service Unit should search for documents responsive to a subpoena or request for 

records.234 In addition, there were no directives addressing “policies, safe checks, [or] procedures 

. . . to ensure that when a request came in either by a subpoena or by an informal request from 

and Assistant State’s Attorney . . . that all of the necessary information including exculpatory 

information was provided by the subpoena services unit in response to that request.”235

The subpoena service unit was staffed by non-sworn personnel with the title “clerk.”236

There was no formal training of personnel assigned to respond to subpoenas.237 Whether all of 

the different units that worked on a given investigation were searched for documents responsive 

to a subpoena depended in large part on the discretion and experience of the personnel searching 

for the documents, such that a subpoena for all documents under a certain RD number would not 

necessarily result in the production of all documents corresponding to that particular 

investigation.238 Hickey described the Subpoena Service Unit’s effort to respond to document 



229 Hickey 207-208 230 Hickey 208 231 Hickey 358 232 Hickey, Rivera v. Guevara, et al., No. 12 C 4428, pages 146-47 233 Ibid, pages 159-60 234 Ibid, pages 36-37 235 Ibid, page160 236 Ibid, pages 147-48 237 Ibid, page 39 238 Ibid, pages 43-46 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 386 of 433 PageID #:15807
66 

requests as an “art.”239 He acknowledged that it is possible in a case with multiple units working 

on the same investigation that the subpoena could only go to one of those units.240 

All of this was true as well with respect to requests for documentsmade by the Cook 

County State’s Attorney’s Office to the Chicago Police Department.241 This system was in place 

before Mr. Kluppelberg’s conviction and continued in force until after the year 2000.242 

Though Hickey testified that in some cases, the Subpoena Service Unit would produce 

copies of the general offense case report, supplementary reports, and arrest reports that were in 

the records division, he acknowledged that it is possible in Kluppelberg’s case in particular that 

the Subpoena Service Unit would have sent a request for documents to Area 3 but not to Bomb 

and Arson.243 

This system, or lack thereof, for responding to requests for documents and producing 

investigative materials, including exculpatory information, is deficient. Because there are 

multiple files in multiple locations pursuant to the Special Orders and CPD’s design, there is an 

acute need for policies, practices and training to ensure that exculpatory information was 

produced to prosecutors and criminal defendants. Indeed, the judge in the Palmer litigation had 

expressly identified the risk of constitutional violations from the City’s failure to have policies to 

ensure that information from investigative and working files were produced to prosecutors and 

criminal defendants. Yet, even afterward the City failed to put in place the requisite policies, 

practices and training. (See supra; see also City’s Response to Seventeenth Requests for 

Production, Nos. 1 and 3, Rivera) We know in Kluppelberg’s case, for example, that the New 

File was not produced. The events in the Palmer litigation – and Kluppelberg’s case –are 

examples of what happens when the City lacks policies to ensure that exculpatory and/or 

impeaching evidence is turned over. 

Opinion #12: The City Failed to Provide Proper Training and Oversight on Special Orders 

Designed to Eliminate Street Files 

The testimony and documents that I have reviewed in this case (and to some extent, in 

other cases involving the CPD in which I have rendered opinions) establish a pervasive pattern 

and practice by the Chicago Police Department of issuing critically important orders, but then 

failing to provide proper training and oversight on those orders. 

When you have a practice as ingrained as the street files practice was, it is simply not 

sufficient to have one training session to ensure that the old practices are eliminated and new 

practices are adopted. Hickey testified that he provided a one-time training to about 1,000 

detectives.244 He said each training session was done in groups of 30-40 people, and lasted 



239 Ibid, page 162; Hickey 362-63 240 Hickey 362-63 241 Hickey, Rivera, page 125 242 Ibid, pages 151-53 243 Hickey 359-61 244 Hickey 308-309 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 387 of 433 PageID #:15808
67 

approximately 3 hours.245 During that three hour training session, he went over Special Order 83-

1. One training session was wholly insufficient to try to change a decades-long practice. In fact, 

Hickey testified that the years after Special Order 83-1, he learned that unit detectives were 

reverting back to carrying their own files on the street separate and apart from the file maintained 

by CPD.246 Nothing, however, was done about this. 

In addition, there was testimony from the detectives that there was confusion not only 

about whether personal notes had to be retained, but also about whether the Special Orders 

applied to the entire detective division or just to violent crimes.247 This confusion underscores 

the importance of training – beyond simply the three hours that were given. 

Similarly, there was no oversight to ensure that detectives were following the Special 

Orders. In fact, documents that I reviewed in conjunction with this report, suggest just the 

opposite: that detectives were continuing to submit documents that were not compliant with the 

Special Orders and that the street file practice continued, yet no discipline or corrective action 

was taken. 

 On a department-wide scale, there was no action taken whatsoever to ensure that the 

Special Orders were being followed. As Hickey explained, although he did a sampling prior to 

the Special Orders being issued, he did not do one at any time after Notice 82-2 and was not 

aware of anyone else conducting such an audit.248 On a more individual scale, Hickey testified 

that members of the police department were supposed to conduct inspections pursuant to Special 

Order 83-2 but Hickey has no idea if they actually conducted such investigations.249 Similarly, 

Commander Stibich testified that supervisors were supposed to review files but he had no idea 

how often, when or the manner in which that review was conducted.250 

 In fact, it appears that there was no oversight to ensure that the Special Orders were being 

enforced and that the street files practice was eliminated. This is particularly troubling given the 

importance and scope of the problem and is certainly deficient. You cannot expect a departmentwide, decades-long practice to be eliminated overnight by simply issuing an order that was read 

at roll call a few times. You have to take more action to ensure that the practice ceases to 

continue.

Opinion #13: The City’s Failure to Document How Cases are Interconnected 

Testimony and documents indicate a negligent pattern and practice by the Chicago Police 

Department of allowing separate units to work on essentially the same cases, but not formally 

requiring timely sharing and recording of information developed. 



245 Hickey 309 246 Hickey 321, 327 247 Micek 2015 dep, page 22 248 Hickey 160-61, 166, 167 

249 Hickey 375-76. 250 Stibich 4504-05 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 388 of 433 PageID #:15809
68 

The detective investigatory failures that have been identified throughout my report above 

demonstrate to me that at least as of March 1984 to July 1989, the Chicago Police Department 

failed to promulgate clear standards for all aspects of investigations, that the standards that they 

had promulgated were deficient in numerous ways, that it failed to properly train its officers in 

the application of those standards, that it failed to supervise and enforce the policies, practices, 

and procedures that it had issued, that it failed to discipline officers or detectives when they 

violated these policies, practices, and procedures, and that as an institution it had an intentional 

and willful indifference to whether the policies were or were not followed. 

 In particular, and as described more fully above, the CPD failed to: 

x Implement requirements for document sharing, including among and within units 

investigating the same case; 

x Implement requirements for documenting information that is shared among and 

within units; and 

x Implement requirements that documents that are created as part of the investigation 

into case A but relevant to case B make it into the investigative and permanent 

retention files for case B 

In Kluppelberg’s case, these deficiencies meant that (a) information about Isabel Ramos 

never made it into the permanent retention file for the Hermitage fire; (b) Isabel Ramos’ oral 

confession given to and memorialized by Detective Micek never made it into the Area 3 

investigative file or the permanent retention file for the Hermitage Fire. In addition, because the 

Bomb and Arson investigative file has never been produced, it is possible that documents in that 

file were not part of the 1984 Area 3 investigative file and vice-versa. Because detectives used 

their working files to store information in real time about the on-going homicide investigation, it 

is entirely possible – and likely – that their area investigative files contained information about 

leads and alternate suspects from other cases that they could safely omit from the official report 

and still comply with policy. 

Opinion #14: The City’s Failure to Properly Retain Files 

I was also very concerned to learn that important portions of the City's original files were 

"missing". In fact, the City has yet to produce the Bomb & Arson Investigative file in this case 

notwithstanding the fact that there almost assuredly was one. Likewise, the first time the New 

File was produced to Kluppelberg was in this civil litigation in 2014: It was never produced to 

the prosecutor or to Kluppelberg during the criminal proceedings. 

The integrity of police investigatory files is a central requirement of department policies, 

procedures and the law. These policies, procedures, and laws are specifically designed to protect 

defendants from evidence not being produced to them (and the integrity of the files also protects 

the police officers from false accusations that they have withheld material or conducted an 

insufficient investigation). Here, files that were not disclosed, but belatedly found (despite very 

clear policies that when such cases result in convictions, those materials are to be retained). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 389 of 433 PageID #:15810
69 

Based on my professional experience and the importance that all such materials be retained after 

a conviction occurs (and especially a murder conviction), this should not and must not happen. 

After every murder conviction, there are numerous appeals, post-conviction filings (both 

state and federal), re-investigations, and, possibly integrity reviews. Therefore, it is vital that all 

files that relate to a murder investigation or trial be carefully preserved for future proceedings. 

The fact that these files were missing from CPD's retained files is both extraordinary and 

unacceptable. Indeed, I have been told that some of the City's own witnesses have admitted that 

such missing files are violations. 

The relevance of vital materials that were missing suggests that the direct violation of the 

City (and presumably the County's) policies that these records be maintained was not 

uncommon. It further causes suspicion whether all of the information about exculpatory 

materials were or were not turned over to the prosecutors and/or defense counsel as required. 

The belated discovery by CPD of what has been described as the “New File”251 is 

consistent with the pattern and practice that I have observed in similar cases involving the failure 

to produce relevant records to prosecutors, defendants, courts, and plaintiffs. The casual 

treatment of essential records by detectives, supervisors, commanders, and the CPD compounds 

the operational and administrative integrity of investigatory notes, files, reports, and records. To 

have a dysfunctional system that allows multiple documents to not be included in the same case, 

and/or related cases is professionally inexcusable. It is obvious that the Marshfield (Ramos) fire 

investigation material was “scattered” and incomplete in one central location. Some Ramos 

material was included in Area 3 Violent Crime unit files, some in Bomb and Arson unit files, 

Area 3 street/working files, Bomb and Arson street/working files, and some (but certainly not 

all) in the Permanent Retention file. The same deficiency holds true in like regards for the 

Lupercio/Hermitage fire investigation. 

Opinion #15: Use of Street Files Continued Even After Enactment of Special Orders 

A. Evidence of Street Files in Other Cases 

The continued use of street files has been documented in several other cases throughout 

the City of Chicago. Nathson Fields was convicted of the double murder of Jerome Smith and 

Talman Hickman in 1986.252 Fields’ conviction was thrown out after a court granted his petition 

for post-conviction relief, but he was re-tried in 2009 and acquitted.253 He then filed a civil 

rights lawsuit against the City of Chicago in 2011, and during discovery for the civil lawsuit, a 

street file “of over a hundred pages of police reports concerning the Smith/Hickman murders was 

located in a nondescript file cabinet at the Area 1 police station, along with files relating to other 

murders.”254



251 City’s amended answers to plaintiff’s 7th set of interrogatories (11/17/2014) 252 Fields v. City of Chicago, Memorandum Opinion and Order, page 2 253 Ibid at 3 254 Ibid at 7 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 390 of 433 PageID #:15811
70 

Another street file was disclosed in civil litigation about Jacques Rivera’s conviction for 

the murder of Felix Valentin. Rivera discovered that Area Five had a Detective Division street 

file containing 30 pages of police reports and documents related to the Valentin homicide 

investigation that had not been disclosed to him during his criminal proceedings.255 

Similarly, in another homicide investigation in Area Six, a 1992 supplementary report 

explained that “[a] copy of this case report was obtained and placed into the street file for future 

reference.”256 And, a memorandum authored by the Commander of the Area Six Detective 

Division in 1989 – six years after Special Order 83-1 – enclosing a document located during a 

search of “street files” in a homicide investigation.257 In transmitting those documents to the 

Director of the Records Division, the memorandum explained that the enclosed reports “would 

not be part of the [record division] file” in the case.258

B. Street File in Kluppelberg’s Case 

Likewise, the failure to properly document and turn over the New File to Kluppelberg 

was not an anomaly. Rather, it was an example of the Chicago Police Department’s continued 

use of street files. As noted above, based on the Department’s definition of a “Street File,” I 

opine that the New File was a Street File. 

Opinion #16: Failure to take any after-action internal review of what happened 

After Cook County Circuit Court Judge Rickey Jones vacated Kluppelberg’s conviction 

and Judge Michael McHale issued a Certificate of Innocence, the CPD should have undertaken 

an internal review; its failure to do so is not proper. This is especially true when one considers 

the evidence that the detectives had in 1984 and still have regarding other possible suspects. 

The Chicago Police Department’s apparent conscious decision to not investigate its 

detectives’ failures and its own failures with respect to the 1987-1988 investigation, and its 

failure to re-open the fire investigation once the innocence of Kluppelberg was determined by the 

court, provides additional support for the conclusion that CPD does not have an interest in 

learning and correcting what went so terribly wrong in this case or in bringing closure to the 

deaths of the Lupercio family. An unbiased and professional review of the material produced in 

discovery during this case would, in my opinion, have led a responsible and professional police 

organization to proactively take the lead in re-opening the investigation into the deaths of the 

Lupercio family. The Department owes this at least to the victims and the victims’ families, but 

also to the entire community it polices to ensure that these types of failures to not repeat again 

and again and again. 



255 Rivera v. Guevara, No. 12 CV 4428, Supplemental Mem. in Support of Plaintiff’s Mot. to Compel Prod. of Street 

File Doc., Dckt No. 99 

256 Docket 212-3 257 Docket 212-4 258 Ibid. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 391 of 433 PageID #:15812
71 

Relatedly, there was a belated discovery of 4 pallets of CPD records259 said to contain: 

1. Investigative files for arson, criminal sexual assaults, sexual offender, aggravated battery, 

battery, aggravated assault, theft, burglary, robbery, kidnapping, death investigation, 

suicide, intimidation, and justified homicide; 

2. A single box of homicide files in which the defendant was acquitted; 

3. Copies of thousands of individual case reports in sequential order; 

4. Court notification books and arrest books; 

5. Administrative documents such as control books, arrest tabulations, monthly crime 

summaries, details, daily arrest records, drivers’ license inspections, election duty roster, 

homicide data sheets, in-service training course, shotgun certifications, and health 

insurance claims forms. 

The documents, when dated, appear to fall between 1983 and 1994, and should have 

resulted in a search, evaluation, documentation, indexing, and (where appropriate) notification of 

contents to each and every individual defendant in any past or current CPD cases, regardless of 

conviction. There is nothing in the material that I reviewed that would indicate that this has been 

done. Similarly, the CPD should have determined why the pallets were there and whether this 

was part of a larger problem of files going missing or being improperly filed (such as the files 

found in the basement in Area Central in the Fields litigation, which also included files from 

Area 3260). 

Concluding Statement 

I have provided my opinions based upon my training, experience, and after a careful 

evaluation of the totality of circumstances in this matter. I utilized all of the facts and data 

known to me, and applied generally accepted police management principles and methods. From 

a police management perspective the failure of each defendant to act in a lawful and professional 

manner caused Kluppelberg unnecessary harm. In addition, the City of Chicago’s widespread 

practice of encouraging, condoning and at best, ignoring officers’ violations of appropriate 

procedures, practices and law caused Kluppelberg harm. 

Confessions, especially those obtained from individuals after lengthy interrogations, are 

all notoriously suspect. To have a police agency base an entire homicide investigation and charge 

request solely on confessions and/or coerced witness statements alone, without any corroborating 

or physical evidence, is practically unheard of. Absent any physical evidence, motive, or material 

circumstances, the case is worthless and no experienced investigator or prosecutor would have 



259 City’s amended answers to plaintiff’s 7th set of interrogatories (11/17/2014), pages 10-11 260 Samuel Brown Testimony, Fields v. City of Chicago, 10-cv-1168 at 2321: 

Q: In the basement of Area 1, there's also homicide files for Area 4; is that correct? 

A. Yes, there are. 

Q. And there's homicide files for Area 3; is that correct? 

A. Yes. 

Q. And these are homicide investigatory files; isn't that correct? 

A. Yes, it is. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 392 of 433 PageID #:15813
72 

proceeded in these circumstances without the required additional evidence needed to corroborate 

the statements. 

The circumstances of taking and creating such statements are too easily abused by the 

investigators because it is the investigators who control all of the information that is being 

developed, and this is especially true when they do so, as in this case, without audio recording, 

without video recordings, without any other proper records of the specific times and information 

that the various components of the interrogation occurred. 

Here, far too many standard operating procedures for police department investigations 

were not followed. Information as simple and straightforward as documenting how much of the 

period that someone is being held they were they actually questioned, when such questioning 

sessions began and ended, and a summary of what was addressed and said in each session should 

be summarized and preserved by any competent and trained detective. 

Considering all of the facts that the Detectives assert regarding James Kluppelberg’s 

initial arrest, voluntary cooperation, delay in questioning, voluntary admission of guilt, speed of 

such admission once questioning began, no attorney being present, the complete lack of 

corroboration of any of the statements made by Kluppelberg (other than the supposed 

corroboration of subsequent “witness statements” that the detectives obtained), as well as the 

provable false facts contained in Kluppelberg’s supposedly voluntary statement, I find it highly 

improbable that the scenario played out the way detectives assert, and based on my experience I 

instead identify in this investigation many of the telltale signs of the detectives having a predetermined outcome that they wanted to achieve for purposes of the investigation, and they 

proceeded to intentionally and wrongfully arrest, interrogate, and coerce false and concocted 

confession from Kluppelberg and of the so-called “witnesses” for the purpose of clearing a 

murder investigation they had not yet solved and which they were not, as of that time, taking all 

required steps to try to solve. In my professional opinion, the detectives’ acts and omissions 

were professionally inexcusable and unconscionable. 

In sum, it is my professional opinion to a reasonable degree of professional certainty in 

the law enforcement community, and based on longstanding and well-accepted law enforcement 

practices, that the defendant detectives in this case arrested and caused to be charged James 

Kluppelberg, even though they had no reasonable and supported basis to believe he was involved 

in the deaths of members of the Lupercio family, and that they intentionally and wrongfully 

undertook the numerous acts and omissions identified throughout this report for the purpose of 

clearing an open investigation and removing this individual from the streets of Chicago. I am not 

aware of any valid basis on which these detectives reasonably obtained Kluppelberg’s alleged 

“confession”, or the allegedly corroborative “witness statements” of others, or for recommending 

that he be charged and prosecuted for the Lupercio deaths. 

I reserve the right to supplement or modify this report and my opinions expressed in the 

report to the extent that additional information is presented to me and to the extent permitted by 

rules. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 393 of 433 PageID #:15814
73 

Pursuant to 28 U.S.C Section 1746, I declare under penalty of perjury that the foregoing 

is true and correct. 

______________________________________

Michael D. Brasfield 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 394 of 433 PageID #:15815
74 

Attachment A - Court Experience

Report of Plaintiff's Expert – Michael D. Brasfield 

James Kluppelberg v. Jon Burge and City of Chicago, et al. 

No. 1:13-cv-03963 

Compliance with Federal Rule of Procedure 26 (a) (2) (B) 

Testimony at Trial or Deposition for Preceding Four Years

I have either testified at trial or deposition as a witness in Federal, State, and Local Courts 

throughout my law enforcement career. These appearances have been in both civil and criminal 

matters. I have appeared in Federal District Courts in Fort Lauderdale, Miami, Seattle, and 

Tacoma. Civil litigation involving all types of police procedures and practices have included the 

use of force; police pursuits; deadly force; negligent selection, training, and retention; as well as 

class action and Federal Section 1983 civil rights cases. Specifically, testimony and/or 

deposition over the last four years are as follows: 

x In the United States District Court (District of Colorado) - Schneider v. City of Grand 

Junction Police Department, et al. - Civil Action No. 10-cv-01719-MSK-KLM – For 

Plaintiff – Violation of Constitutional Rights. 

x In the United States District Court (Eastern District of Washington) – Creach v. Spokane 

County, et al. – Cause No. 2:2011cv00432 – For Defendant – 42:1983 Civil Rights Act. - 

Fatal shooting by police officer. 

x In the Superior Court of the State of Washington (Spokane County) – Glidden v. City of 

Spokane Valley, et al. – Cause No. 11-2-04437-2 – For Defendant – Police Shooting - 

Negligent training, supervision, retention. 

x In the United States District Court (Northern District of Illinois, Eastern Division) – April 

Ortiz – Cause No. 04-CV-7423 – For Plaintiff – 42 USC, 1983 - Denial of Medical Care. 

x In the United States District Court (Eastern District of Washington) – Duncan v. Liberty 

Lake – Cause No. 2:2012cv00219 – For Defendant – Violation of Civil Rights. 

x In the United States District Court (Eastern District of Washington) - Thoma v. City of 

Spokane – Cause No. CV-12-156-EFS – For Defendant – 42 U.S.C. Sec. 1983 

x In the United States District Court (Western District of Washington) – Theoharis v. 

Rongen – Cause No. 2:13-cv-01345-RAJ – For Plaintiff – 42 U.S.C Sec. 1983 – 

Excessive and Unreasonable Force and Unreasonable Search and Seizure. 

x In the Court of Common Pleas of Allegheny County, Pennsylvania – Commonwealth of 

Pennsylvania v. Leon Ford – Cause No. CC201303273 – For Defendant - Multiple 

criminal charges. 

x In the Superior Court for the State of Alaska (Anchorage) – Boshears v. State of Alaska –

Cause No. 3AN-13-07970CI – For Plaintiff – Negligence of Duty. 

x In the United States District Court (Northern District of Illinois, Eastern Division) – 

Percy Coleman v. City of Chicago – Cause No. 12C-10061 – For Plaintiff – 42 USC, 

1983 – Wrongful Death. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 395 of 433 PageID #:15816
75 

x In the United States District Court (Northern District of Illinois, Eastern Division) – Deon 

Patrick v. City of Chicago – Cause No. 14C-3658 – For Plaintiff – 42 USC, 1983 – 

Wrongful Conviction. 

x In the United States District Court (Eastern District of Washington) – Goehring v. City of 

Kennewick – Cause No. 4:14-CV-5104-RMP – For Defendant – Violation of Civil 

Rights. 

In addition, I have provided my expert opinion, reviewed, consulted, or been retained in civil 

litigation related matters for plaintiffs and defense attorneys or governmental entities over 50 

times in the last 10 years in Riverside County (CA), Trinity County (CA), Prescott County (AZ), 

Chicago (IL), Garland (TX), Bradley County (TN), Hazard (KY), Clallam County (WA), 

Franklin County (WA), Reno (NV), Unalakleet (AK), Whatcom County (WA), Albany (OR), 

Jackson (MS), Seattle (WA), Columbia (SC), and Sweetwater County (WY). 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 396 of 433 PageID #:15817
76 

Attachment B - Report of Material Reviewed 

Plaintiff's Expert – Michael D. Brasfield 

James Kluppelberg v. Jon Burge and City of Chicago, et al. 

No. 1:13-cv-03963 

I have been provided and reviewed the following documents and materials concerning this case: 

x First Amended Complaint (4/10/2014) – 23 pages 

o 134.Amended Complaint.pdf 

x William Alletto deposition transcript (3/2/2015) – 353 pages 

o Alletto, William - Vol.pdf 

x Area File (circa 1988) – 95 pages 

o area file.pdf 

x Jon Burge deposition transcript (5/6/2014) – 145 pages 

o Burge Dep Transcript.pdf 

x City’s amended answers to plaintiff’s 7th set of interrogatories (11/17/2014) – 14 pages 

o City Amended Answers to Plaintiff INT 7.pdf 

x City’s response to plaintiff’s 2nd set of requests for admissions (6/16/2014) – 14 pages 

o City Response to Plaintiff RTA 2.pdf 

x Fire Investigation Report #F104537 (3/23/1984) – 8 pages 

o CITY-KLUP_000683-CITY-KLUP_000690.pdf 

x Fire Investigative Inventory file #F104537 (circa 1984) – 11 pages 

o CPDREV_00000196.pdf 

x Victor M. Vega-Valentin deposition transcript (4/11/2014) – 220 pages 

o DEPOSITION OF VICTOR VEGA VALENTIN.pdf 

x Michael Duffin deposition transcript (6/23/2014) – 172 pages 

o Duffin, Michael - Vol_ I.pdf 

x James Kluppelberg deposition transcript (3/31/2015) – 429 pages 

o James Kluppelberg 03-31-1015.fullprint.pdf 

o James Kluppelberg 03-31-2015.index.pdf 

x George Jenkins deposition transcript (5/12/2014) – 289 pages 

o Jenkins, George - Vol_ I.pdf 

x William Kelly deposition transcript (2/4/2015) – 399 pages 

o Kelly, William - Vol.pdf 

x Wayne Micek deposition transcript (4/16/2014) – 356 pages 

o Micek, Wayne - Vol.pdf 

x Wayne Micek deposition transcript (6/10/2015) – 72 pages 

o 108907 Micek, Wayne K. 061015 fullprint.pdf 

x Wayne Micek deposition index (6/10/2015) – 14 pages 

o 108907 Micek, Wayne K. 061015 index.pdf 

x John Nelson deposition transcript (4/17/2014) – 126 pages 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 397 of 433 PageID #:15818
77 

o Nelson, John - Vol.pdf 

x Lawrence Tuider deposition transcript (4/18/2014) – 254 pages 

o Tuider, Lawrence - Vol.pdf 

x Kenneth Urbon deposition transcript (7/2/2014) – 276 pages 

o Urbon, Kenneth - Vol_full.pdf 

x Duane Glassco deposition transcript (7/18/2014) – 169 pages + 87 exhibit pages 

o GLASSCO, DUANE.pdf 

o Exhibits 1 through 11 

x Branigan Investigative Report - Exhibit 05 (P5825-5827) 6/23/2010 – 3 pages 

o P5825-5827.pdf 

o Branigan Investigative Report - Exhibit 06 (P5823-5824) 9/13/2010 – 3 

pagesP5822-5824.pdf 

x Rolston deposition transcript (5/8/2015) – 474 pages 

o Rolston.pdf 

o Leonard Ralston 05-08-2015.index.pdf 

x Permanent Retention file (3/24/1984 & onward) – 49 pages 

o permanent retention file.pdf 

x New File (3/24/1984 & onward) – 60 pages 

o new file .PDF 

x John Smith deposition transcript (6/17/2015) – 226 pages 

o John Smith exhibit 1 – 58 pages 

o John Smith exhibit 2 – 2 pages 

o John Smith exhibit 3 – 4 pages 

o John Smith exhibit 4 – 4 pages 

o John Smith exhibit 5 – 3 pages 

o John Smith exhibit 6 – 1 page 

x

x Francis Huber deposition transcript (4/29/2015) and attachments - 170 pages 

o 1 Huber 042915-1.pdf (5) 

o 2 Huber 042915-2.pdf (1) 

o 3 Huber 042915-3.pdf (1) 

o 4 Huber 042915-4.pdf (1) 

x Chicago Police Personnel Training Records (CITY-KLUP_000475-523) – 49 pages 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 398 of 433 PageID #:15819
78 

o Jon Burge (1) 

o Leonard Ralston (2) 

o John Schmitz (12) 

o James Farley (2) 

o William Kelly (9) 

o Thomas Ptak (2) 

o Kenneth Urbon (2) 

o Michael Duffin (1) 

o George Jenkins (1) 

o John Nelson (9) 

o Victor Vega (1) 

o Wayne Micek (6) 

o Denis Guest (1) 

x Leonard Rolston – Chicago Police Personnel File (JGS 2979-3051) – 73 pages 

x Palmer v. City of Chicago, Case No. 82C 2349 – 3,312 pages 

o P2477-5788 (Palmer v. City of Chicago).pdf 

x Chicago Police Department Special Orders – 17 pages 

o Special Order 82-2.pdf (3) 

o Special Order 83-1.pdf (5) 

o Special Order 83-2.pdf (5) 

o Special Order 86-3.pdf (4) 

x Standard Operating Procedure Chapter 18 

x General Order 82-15 (City_Klupp_2205-08) – 4 pages 

o General order 82-15.pdf 

x Memo, April 18 1986 (JGS 7012-7018)

x CPD Supplementary Report – Lassiter Homicide #T 532-804 (11/23/1992) – 2 pages 

o 212-3.Ex C.pdf 

x CPD “To-From” memo regarding Manuel Rivera (10/19/1989) – 1 page 

o 212-4.Ex D.pdf 

x Kluppelberg Trial Transcript documents – 892 pages 

o P1-240.pdf 

o P241-431.pdf 

o P432-606.pdf 

o P607-830.pdf 

o P831-892.pdf 

x Andrew Robertson deposition (6/25/2015) – 87 pages 

o 124692 Robertson.Andrew 062515.fullprint.pdf 

x Michelle Brittain deposition (1/14/2015) – 186 pages 

o Brittain, Michelle.pdf 

x City’s Second Amended Responses and Objections (12/18/2014) – 15 pages 

o City 2nd Amd Objections and Responses to Plaintiff’s INT 7.pdf 

x City’s Fourth Amended Responses and Objections (6/26/2015) – 15 pages 

o Fourth Amended Objections and Responses to Plaintiff’s Seventh Set of 

Interrogatories to the Defendant City of Chicago.pdf 

x James Hickey deposition – Part 1 (7/29/2014) – 290 pages 

o Hickey (pt1).pdf 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 399 of 433 PageID #:15820
79 

x James Hickey deposition – Part 2 (7/31/2014) – 118 pages 

o Hickey (pt2).pdf 

x Russell Ogle report (5/23/2008) – 14 pages 

o P2406-2419 (Ogle Report).pdf 

x Joseph Perfetti deposition (6/11/2015) – 179 pages 

o Perfetti, Joseph.pdf 

x Isabel Ramos statement (3/24/1984) – 1 page 

o Ramos statement (CITY-KLUP_926).pdf 

x City’s Third Amended Objections and Responses (6/23/2015) – 14 pages 

o Third Amended Objections and Responses to Plaintiff's Seventh Set of 

Interrogatories to the Defendant City of Chicago.pdf 

x Verification – City’s 4th Amended O&R by CPD Sgt. Galen T. Caldwell (undated) – 1 

page 

o Verification, Fourth Amended Objections and Responses to Plaintiff's Seventh 

Set of Interrogatories to the Defendant City of Chicago.pdf 

x Verification - City’s 3rd Amended O&R by CPD Sgt. Galen T. Caldwell (undated) – 1 

page 

o Verification, Third Amended Objections and Responses to Plaintiff's Seventh Set 

of Interrogatories to the Defendant City of Chicago.pdf 

x City’s Fourth Amended Responses to Seventh Set of Interrogatories 

x Old Area 3 Files (6/30/2015) – 46 pages 

o 260-11.Ex K.pdf 

x Third and California Area 3 Files (6/30/2015) – 8 pages 

o 260-11.Ex L.pdf 

x Bonnie Kluppelberg deposition (5/14/2015) – 67 pages 

o 051415bonnie_hileman_cond_N_ex.pdf 

x Marshall Weinberg deposition (5/20/2015) – 256 pages 

o 125593 Weinberg.Marshall 052015.fullprint.pdf 

x O&R to Plaintiff’s Third Set of Requests for Admissions (11/17/2015) – 16 pages 

o City Objections and Response to Plaintiff’s RTA 3.pdf 

x Jail Medical Record by Cermak Health Service - 17 pages 

o CITY KLUP 3286-3302.pdf 

x Michael Colander deposition (6/24/2015) – 146 pages 

o 124690 Colander.Michael 062415.fullprint.pdf 

x James Hickey deposition (6/9/2015) - 160 pages 

o 108851 Hickey-James K. 060915.fullprint.pdf 

x James Hickey deposition, Rivera v. Guevara (6/10/14) – 62 pages 

o Hickey Dep Rivera v. Guevara (6-10-14) (condensed).pdf 

x James Hickey deposition, Rivera v. Guevara (5/6/14) – 43 pages 

o Hickey Dep Rivera v. Guevara Part 1 (5-6-14) (condensed).pdf 

x Andrew Robertson Deposition (6/25/15) – 87 pages 

o Robertson.Andrew 062515.fullprint.pdf 

x Janet McCarthy Deposition (12/09/2015) – 188 pages 

o McCarthy.Janet 120915.fullprint.pdf 

x Santos Lupercio Deposition (05/15/2015) – 76 pages 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 400 of 433 PageID #:15821
80 

o Santos Lupercio 05-15-2015.fullprint.pdf 

x Chicago OPA report to CPD Superintendent (Goldston – Sanders 11/2/1990) – 98 pages 

o P7167-7264 Goldston_Sanders.Report (00000002).pdf 

x 118 Documented Burge Area 2 and 3 Torture Victims 1972-1991 – 14 pages 

o P7265-7278 Documented-TorturesurvivorsunderBurge (00000002).pdf 

x

x National Registry of Exonerations. University of Michigan Law School. Maurice 

Possley. Before June 2012 

x Garrett B: Judging innocence. Colum L Rev 108:55–142 (2008); Leo R: Police 

Interrogation and American Justice. Harvard University Press (2008). 

x P2453-2476.pdf 

o Teletype 

o Brady & Tolley Memo 

o Memo to Raymond Clark from Sgt. Brady 

o Memo to Raymond Clark from John Stibich 

x Report of Theodore Adams (8/3/2015) 

x Samuel Brown Testimony, Fields v. City of Chicago, 10-cv-1168 (4/22/2014) – 43 pages 

o Brown Testimony 04-22-2014 FIELDS V CITY Trial 4-22-14.pdf 

x City of Chicago’s Amended Response to Plaintiff’s Seventeenth Set of Requests to 

Produce Documents (3/27/2015) – 6 pages 

o DOC17 City's Amended Response, Rivera v. Guevara.pdf 

x Supplemental Memorandum in Support of Plaintiff’s Motion to Compel Production of 

Street Files, Rivera v. Guevara. 

o 99.Supp Mem re Street Files.pdf 

x Memorandum Opinion and Order, Fields v. City of Chicago (2/6/2014) – 30 pages 

o Memorandum Opinion Order, Fields v. City of Chicago.pdf 

x Jones v. City of Chicago, 856 F.2d 985, 988 (7th Circuit 1988) 

o Production Letters from City2015.09.02 - Production Letter to Plaintiff.pdf 

o 2015.09.15 Production Letter to Plaintiff.pdf 

o 2015.09.18 - Production Letter to Plaintiff.pdf 

o 2015.09.22 - Production Letter to Plaintiff.pdf 

o 2015.10.05 - Production Letter to Plaintiff.pdf 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 401 of 433 PageID #:15822
81 

o 2015.10.20 - Production Letter to Plaintiff.pdf 

o 2015.10.27 - Production Letter to Plaintiff.pdf 

o 2015.11.02 - Production Letter to Plaintiff.pdf 

o 2015.08.11 - Production Letters to Plaintiff.pdf 

o 2015.08.18 Production Letter to Plaintiff.pdf 

o 2015.08.25 Production Letter to Plaintiff.pdf 

o 2015.08.28 Production Letter to Plaintiff.pdf 

x Major Crime Worksheets – 1,073 pages 

o City 29562-29714 (Major Crime Worksheets).pdf -153 pages 

o City 29744-29986 (Major Crime Worksheets).pdf – 228 pages 

o City 32719-32896 (Major Crime Worksheets).pdf – 150 pages 

o City 33032-33176 (Major Crime Worksheets).pdf – 131 pages 

o City 33317-33560 (Major Crime Worksheets).pdf – 244 pages 

o City 33712-33873 (Major Crime Worksheets).pdf – 162 pages 

o City 34315-32316 (Major Crime Worksheets).pdf – 2 pages 

o City 34618-34620 (Major Crime Worksheets).pdf – 3 pages 

x Pallet Files – 20,348 pages 

o CITY-KLUP_012298 - 13988.pdf – 1,470 pages 

o CITY-KLUP_013999 - 15021.pdf – 1,023 pages 

o CITY-KLUP_015022 - 15959.pdf – 855 pages 

o CITY-KLUP_015960 - 17766.pdf – 1,517 pages 

o CITY-KLUP_017767 - 20564.pdf – 2,226 pages 

o CITY-KLUP_020565 - 21448.pdf – 773 pages 

o CITY-KLUP_021449 - 23234.pdf – 1,287 pages 

o CITY-KLUP_023235 - 23251.pdf – 17 pages 

o CITY-KLUP_023266 - 25742.pdf – 1,786 pages 

o CITY-KLUP_025743 - 26494.pdf – 513 pages 

o CITY-KLUP_026495 - 27804.pdf – 811 pages 

o CITY-KLUP_027805 - 27862.pdf – 58 pages 

o CITY-KLUP_027683 - 27954.pdf – 91 pages 

o CITY-KLUP_027955 - 34766.pdf – 6,746 pages 

o CITY-KLUP_034793 - 34899.pdf – 107 pages 

o CITY-KLUP_034900 - 35293.pdf – 394 pages 

o CITY-KLUP_035294 - 35754.pdf – 461 pages 

o CITY-KLUP_035754 - 35768.pdf – 15 pages 

o CITY-KLUP_035769 - 35821.pdf – 53 pages 

o CITY-KLUP_035822 - 35912.pdf – 91 pages 

o CITY-KLUP_035915 - 35922.pdf – 8 pages 

o CITY-KLUP_035923 - 35926.pdf – 4 pages 

o CITY-KLUP_035927 - 35946.pdf – 20 pages 

o CITY-KLUP_035947 - 35964.pdf – 18 pages 

o CITY-KLUP_035965 - 35968.pdf – 4 pages 

x Homicide Files, 19,687 pages 

o CITY-KLUP_012472- CITY-KLUP_012601 (130 pages) 

o CITY-KLUP_012602- CITY-KLUP_012681 (80 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 402 of 433 PageID #:15823
82 

o CITY-KLUP_013009- CITY-KLUP_013054 (46 pages) 

o CITY-KLUP_013055- CITY-KLUP_013130 (76 pages) 

o CITY-KLUP_013131- CITY-KLUP_013165 (35 pages) 

o CITY-KLUP_013228- CITY-KLUP_013493 (266 pages) 

o CITY-KLUP_013494- CITY-KLUP_013581 (88 pages) 

o CITY-KLUP_013582- CITY-KLUP_013651 (70 pages) 

o CITY-KLUP_013652- CITY-KLUP_013715 (64 pages) 

o CITY-KLUP_013716- CITY-KLUP_013859 (144 pages) 

o CITY-KLUP_013860- CITY-KLUP_013917 (58 pages) 

o CITY-KLUP_013918- CITY-KLUP_013988 (71 pages) 

o CITY-KLUP_013999- CITY-KLUP_014138 (140 pages) 

o CITY-KLUP_014585- CITY-KLUP_014693 (109 pages) 

o CITY-KLUP_014694- CITY-KLUP_014850 (157 pages) 

o CITY-KLUP_038100-CITY-KLUP_038170 (71 pages) 

o CITY-KLUP_038174-CITY-KLUP_038335 (162 pages) 

o CITY-KLUP_038530-CITY-KLUP_038747 (218 pages) 

o CITY-KLUP_038748-CITY-KLUP_038805 (58 pages) 

o CITY-KLUP_038852-CITY-KLUP_039044 (193 pages) 

o CITY-KLUP_039045-CITY-KLUP_039178 (134 pages) 

o CITY-KLUP_040549-CITY-KLUP_040695 (147 pages) 

o CITY-KLUP_040808-CITY-KLUP_040913 (106 pages) 

o CITY-KLUP_041296-CITY-KLUP_041350 (55 pages) 

o CITY-KLUP_042005-CITY-KLUP_042086 (82 pages) 

o CITY-KLUP_042583-CITY-KLUP_042635 (53 pages) 

o CITY-KLUP_044272-CITY-KLUP_044353 (82 pages) 

o CITY-KLUP_045227-CITY-KLUP_045386 (160 pages) 

o CITY-KLUP_045462-CITY-KLUP_045507 (46 pages) 

o CITY-KLUP_045877-CITY-KLUP_046179 (303 pages) 

o CITY-KLUP_046180-CITY-KLUP_046245 (66 pages) 

o CITY-KLUP_046246-CITY-KLUP_046452 (207 pages) 

o CITY-KLUP_046604-CITY-KLUP_046754 (151 pages) 

o CITY-KLUP_046895-CITY-KLUP_046945 (51 pages) 

o CITY-KLUP_047010-CITY-KLUP_047072 (63 pages) 

o CITY-KLUP_047142-CITY-KLUP_047220 (79 pages) 

o CITY-KLUP_047599-CITY-KLUP_047672 (74 pages) 

o CITY-KLUP_048286-CITY-KLUP_048354 (69 pages) 

o CITY-KLUP_048578-CITY-KLUP_048662 (85 pages) 

o CITY-KLUP_048788-CITY-KLUP_048891 (104 pages) 

o CITY-KLUP_048892-CITY-KLUP_049048 (157 pages) 

o CITY-KLUP_049370-CITY-KLUP_049508 (139 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 403 of 433 PageID #:15824
83 

o CITY-KLUP_049644-CITY-KLUP_049783 (140 pages) 

o CITY-KLUP_049784-CITY-KLUP_049805 (22 pages) 

o CITY-KLUP_049806-CITY-KLUP_049868 (63 pages) 

o CITY-KLUP_049869-CITY-KLUP_049926 (58 pages) 

o CITY-KLUP_049927-CITY-KLUP_049971 (45 pages) 

o CITY-KLUP_049972-CITY-KLUP_050077 (106 pages) 

o CITY-KLUP_050162-CITY-KLUP_050261 (100 pages) 

o CITY-KLUP_052914-CITY-KLUP_053061 (148 pages) 

o CITY-KLUP_053062-CITY-KLUP_053082 (21 pages) 

o CITY-KLUP_053829-CITY-KLUP_054142 (314 pages) 

o CITY-KLUP_057568-CITY-KLUP_057703 (136 pages) 

o CITY-KLUP_058409-CITY-KLUP_058493 (85 pages) 

o CITY-KLUP_059646-CITY-KLUP_059920 (275 pages) 

o CITY-KLUP_060061-CITY-KLUP_060238 (178 pages) 

o CITY-KLUP_060602-CITY-KLUP_060728 (127 pages) 

o CITY-KLUP_061456-CITY-KLUP_061584 (129 pages) 

o CITY-KLUP_061646-CITY-KLUP_061703 (58 pages) 

o CITY-KLUP_061704-CITY-KLUP_061977 (274 pages) 

o CITY-KLUP_063019-CITY-KLUP_063129 (111 pages) 

o CITY-KLUP_063698-CITY-KLUP_063859 (162 pages) 

o CITY-KLUP_064951-CITY-KLUP_065093 (143 pages) 

o CITY-KLUP_065094-CITY-KLUP_065241 (148 pages) 

o CITY-KLUP_066750-CITY-KLUP_066931 (182 pages) 

o CITY-KLUP_067103-CITY-KLUP_067221 (119 pages) 

o CITY-KLUP_067746-CITY-KLUP_067862 (117 pages) 

o CITY-KLUP_068502-CITY-KLUP_068648 (147 pages) 

o CITY-KLUP_069103-CITY-KLUP_069236 (134 pages) 

o CITY-KLUP_069841-CITY-KLUP_070212 (372 pages) 

o CITY-KLUP_072893-CITY-KLUP_072975 (83 pages) 

o CITY-KLUP_074112-CITY-KLUP_074168 (57 pages) 

o CITY-KLUP_078824-CITY-KLUP_078899 (76 pages) 

o CITY-KLUP_079909-CITY-KLUP_080047 (139 pages) 

o CITY-KLUP_080048-CITY-KLUP_080138 (91 pages) 

o CITY-KLUP_081746-CITY-KLUP_081800 (55 pages) 

o CITY-KLUP_082233-CITY-KLUP_082319 (87 pages) 

o CITY-KLUP_082608-CITY-KLUP_082674 (67 pages) 

o CITY-KLUP_082921-CITY-KLUP_083052 (132 pages) 

o CITY-KLUP_083100-CITY-KLUP_083174 (75 pages) 

o CITY-KLUP_083346-CITY-KLUP_083429 (84 pages) 

o CITY-KLUP_083690-CITY-KLUP_083774 (85 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 404 of 433 PageID #:15825
84 

o CITY-KLUP_083775-CITY-KLUP_083861 (87 pages) 

o CITY-KLUP_083862-CITY-KLUP_083976 (115 pages) 

o CITY-KLUP_083977-CITY-KLUP_084035 (59 pages) 

o CITY-KLUP_084036-CITY-KLUP_084211 (176 pages) 

o CITY-KLUP_084212-CITY-KLUP_084322 (111 pages) 

o CITY-KLUP_084323-CITY-KLUP_084331 (9 pages) 

o CITY-KLUP_084475-CITY-KLUP_084550 (76 pages) 

o CITY-KLUP_084551-CITY-KLUP_084696 (146 pages) 

o CITY-KLUP_084697-CITY-KLUP_084785 (89 pages) 

o CITY-KLUP_084786-CITY-KLUP_084820 (35 pages) 

o CITY-KLUP_084821-CITY-KLUP_084902 (82 pages) 

o CITY-KLUP_085003-CITY-KLUP_085097 (95 pages) 

o CITY-KLUP_085098-CITY-KLUP_085168 (71 pages) 

o CITY-KLUP_085400-CITY-KLUP_085448 (49 pages) 

o CITY-KLUP_085733-CITY-KLUP_086006 (274 pages) 

o CITY-KLUP_086535-CITY-KLUP_086599 (65 pages) 

o CITY-KLUP_086600-CITY-KLUP_086806 (207 pages) 

o CITY-KLUP_086807-CITY-KLUP_087006 (200 pages) 

o CITY-KLUP_087007-CITY-KLUP_087233 (227 pages) 

o CITY-KLUP_087522-CITY-KLUP_087776 (255 pages) 

o CITY-KLUP_087893-CITY-KLUP_088022 (130 pages) 

o CITY-KLUP_090378-CITY-KLUP_090439 (62 pages) 

o CITY-KLUP_090495-CITY-KLUP_090647 (153 pages) 

o CITY-KLUP_090648-CITY-KLUP_090705 (58 pages) 

o CITY-KLUP_090706-CITY-KLUP_090788 (83 pages) 

o CITY-KLUP_090789-CITY-KLUP_091033 (245 pages) 

o CITY-KLUP_091100-CITY-KLUP_091309 (210 pages) 

o CITY-KLUP_091310-CITY-KLUP_091399 (90 pages) 

o CITY-KLUP_091400-CITY-KLUP_091534 (135 pages) 

o CITY-KLUP_091752-CITY-KLUP_091903 (152 pages) 

o CITY-KLUP_091904-CITY-KLUP_091998 (95 pages) 

o CITY-KLUP_092090-CITY-KLUP_092579 (490 pages) 

o CITY-KLUP_092795-CITY-KLUP_092955 (161 pages) 

o CITY-KLUP_092956-CITY-KLUP_093138 (183 pages) 

o CITY-KLUP_093139-CITY-KLUP_093210 (72 pages) 

o CITY-KLUP_095901-CITY-KLUP_096049 (149 pages) 

o CITY-KLUP_100702-CITY-KLUP_100839 (138 pages) 

o CITY-KLUP_100937-CITY-KLUP_100987 (51 pages) 

o CITY-KLUP_100988-CITY-KLUP_101052 (65 pages) 

o CITY-KLUP_101053-CITY-KLUP_101134 (82 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 405 of 433 PageID #:15826
85 

o CITY-KLUP_101218-CITY-KLUP_101264 (47 pages) 

o CITY-KLUP_101265-CITY-KLUP_101359 (95 pages) 

o CITY-KLUP_101360-CITY-KLUP_101472 (113 pages) 

o CITY-KLUP_101527-CITY-KLUP_101626 (100 pages) 

o CITY-KLUP_101891-CITY-KLUP_102011 (121 pages) 

o CITY-KLUP_102012-CITY-KLUP_102092 (81 pages) 

o CITY-KLUP_106385-CITY-KLUP_106483 (99 pages) 

o CITY-KLUP_106484-CITY-KLUP_106598 (115 pages) 

o CITY-KLUP_106599-CITY-KLUP_106686 (88 pages) 

o CITY-KLUP_106913-CITY-KLUP_106977 (65 pages) 

o CITY-KLUP_107190-CITY-KLUP_107313 (124 pages) 

o CITY-KLUP_107314-CITY-KLUP_107316 (3 pages) 

o CITY-KLUP_108879-CITY-KLUP_108952 (74 pages) 

o CITY-KLUP_109068-CITY-KLUP_109165 (98 pages) 

o CITY-KLUP_112167-CITY-KLUP_112430 (264 pages) 

o CITY-KLUP_112431-CITY-KLUP_112688 (258 pages) 

o CITY-KLUP_112809-CITY-KLUP_112879 (71 pages) 

o CITY-KLUP_115405-CITY-KLUP_115475 (71 pages) 

o CITY-KLUP_115476-CITY-KLUP_115546 (71 pages) 

o CITY-KLUP_115547-CITY-KLUP_115632 (86 pages) 

o CITY-KLUP_115633-CITY-KLUP_115692 (60 pages) 

o CITY-KLUP_115693-CITY-KLUP_115931 (239 pages) 

o CITY-KLUP_116047-CITY-KLUP_116131 (85 pages) 

o CITY-KLUP_116132-CITY-KLUP_116228 (97 pages) 

o CITY-KLUP_116229-CITY-KLUP_116329 (101 pages) 

o CITY-KLUP_116330-CITY-KLUP_116570 (241 pages) 

o CITY-KLUP_116571-CITY-KLUP_116649 (79 pages) 

o CITY-KLUP_116722-CITY-KLUP_116797 (76 pages) 

o CITY-KLUP_116798-CITY-KLUP_116865 (68 pages) 

o CITY-KLUP_117003-CITY-KLUP_117099 (97 pages) 

o CITY-KLUP_117255-CITY-KLUP_117369 (115 pages) 

o CITY-KLUP_118545-CITY-KLUP_118802 (258 pages) 

o CITY-KLUP_118803-CITY-KLUP_118920 (118 pages) 

o CITY-KLUP_118921-CITY-KLUP_119083 (163 pages) 

o CITY-KLUP_119551-CITY-KLUP_119712 (162 pages) 

o CITY-KLUP_119815-CITY-KLUP_120009 (195 pages) 

o CITY-KLUP_120032-CITY-KLUP_120099 (68 pages) 

o CITY-KLUP_120100-CITY-KLUP_120285 (186 pages) 

o CITY-KLUP_120286-CITY-KLUP_120395 (110 pages) 

o CITY-KLUP_120396-CITY-KLUP_120562 (167 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 406 of 433 PageID #:15827
86 

o CITY-KLUP_120563-CITY-KLUP_120682 (120 pages) 

o CITY-KLUP_127549-CITY-KLUP_127560 (12 pages) 

x Permanent Retention Files 

o CITY-KLUP_034900 - 35293 (394 pages)

x Sample for Inventories, 5402 pages 

o CITY-KLUP_038174-CITY-KLUP_038335 (162 pages) 

o CITY-KLUP_039725-CITY-KLUP_039837 (113 pages) 

o CITY-KLUP_040549-CITY-KLUP_040695 (147 pages) 

o CITY-KLUP_041701-CITY-KLUP_041734 (34 pages) 

o CITY-KLUP_042005-CITY-KLUP_042086 (82 pages) 

o CITY-KLUP_042520-CITY-KLUP_042582 (63 pages) 

o CITY-KLUP_043248-CITY-KLUP_043288 (41 pages) 

o CITY-KLUP_043541-CITY-KLUP_043612 (72 pages) 

o CITY-KLUP_043741-CITY-KLUP_043848 (108 pages) 

o CITY-KLUP_044890-CITY-KLUP_044914 (25 pages) 

o CITY-KLUP_047440-CITY-KLUP_047491 (52 pages) 

o CITY-KLUP_047888-CITY-KLUP_047995 (108 pages) 

o CITY-KLUP_048224-CITY-KLUP_048285 (62 pages) 

o CITY-KLUP_049167-CITY-KLUP_049369 (203 pages) 

o CITY-KLUP_049644-CITY-KLUP_049783 (140 pages) 

o CITY-KLUP_053829-CITY-KLUP_054142 (314 pages) 

o CITY-KLUP_057356-CITY-KLUP_057567 (212 pages) 

o CITY-KLUP_059995-CITY-KLUP_060060 (66 pages) 

o CITY-KLUP_061361-CITY-KLUP_061455 (95 pages) 

o CITY-KLUP_062745-CITY-KLUP_062904 (160 pages) 

o CITY-KLUP_064390-CITY-KLUP_064483 (94 pages) 

o CITY-KLUP_065529-CITY-KLUP_065556 (28 pages) 

o CITY-KLUP_066358-CITY-KLUP_066432 (75 pages) 

o CITY-KLUP_067103-CITY-KLUP_067221 (119 pages) 

o CITY-KLUP_069322-CITY-KLUP_069406 (85 pages) 

o CITY-KLUP_072976-CITY-KLUP_073241 (266 pages) 

o CITY-KLUP_073302-CITY-KLUP_073375 (74 pages) 

o CITY-KLUP_077873-CITY-KLUP_077908 (36 pages) 

o CITY-KLUP_078029-CITY-KLUP_078075 (47 pages) 

o CITY-KLUP_080604-CITY-KLUP_080798 (195 pages) 

o CITY-KLUP_081673-CITY-KLUP_081745 (73 pages) 

o CITY-KLUP_082374-CITY-KLUP_082450 (77 pages) 

o CITY-KLUP_082608-CITY-KLUP_082674 (67 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 407 of 433 PageID #:15828
87 

o CITY-KLUP_084475-CITY-KLUP_084550 (76 pages) 

o CITY-KLUP_087007-CITY-KLUP_087233 (227 pages) 

o CITY-KLUP_101473-CITY-KLUP_101526 (54 pages) 

o CITY-KLUP_102012-CITY-KLUP_102092 (81 pages) 

o CITY-KLUP_108879-CITY-KLUP_108952 (74 pages) 

o CITY-KLUP_111659-CITY-KLUP_111857 (199 pages) 

o CITY-KLUP_115693-CITY-KLUP_115931 (239 pages) 

o CITY-KLUP_115932-CITY-KLUP_115989 (58 pages) 

o CITY-KLUP_116229-CITY-KLUP_116329 (101 pages) 

o CITY-KLUP_116650-CITY-KLUP_116721 (72 pages) 

o CITY-KLUP_118498-CITY-KLUP_118544 (47 pages) 

o CITY-KLUP_118545-CITY-KLUP_118802 (258 pages) 

o CITY-KLUP_119551-CITY-KLUP_119712 (162 pages) 

o CITY-KLUP_120563-CITY-KLUP_120682 (120 pages) 

o CITY-KLUP_127673-CITY-KLUP_127687 (15 pages) 

o CITY-KLUP_128264-CITY-KLUP_128387 (124 pages) 

x Index of Inventories 

o All Inventories Index.xls 

x Multiple files per RD number, 3701 pages 

o CITY-KLUP_037920-CITY-KLUP_038062 (143 pages) 

o CITY-KLUP_046946-CITY-KLUP_046965 (20 pages) 

o CITY-KLUP_048892-CITY-KLUP_049048 (157 pages) 

o CITY-KLUP_049644-CITY-KLUP_049783 (140 pages) 

o CITY-KLUP_049784-CITY-KLUP_049805 (22 pages) 

o CITY-KLUP_049806-CITY-KLUP_049868 (63 pages) 

o CITY-KLUP_049869-CITY-KLUP_049926 (58 pages) 

o CITY-KLUP_049927-CITY-KLUP_049971 (45 pages) 

o CITY-KLUP_049972-CITY-KLUP_050077 (106 pages) 

o CITY-KLUP_052914-CITY-KLUP_053061 (148 pages) 

o CITY-KLUP_053062-CITY-KLUP_053082 (21 pages) 

o CITY-KLUP_057356-CITY-KLUP_057567 (212 pages) 

o CITY-KLUP_059218-CITY-KLUP_059432 (215 pages) 

o CITY-KLUP_068649-CITY-KLUP_068649 (1 pages) 

o CITY-KLUP_068650-CITY-KLUP_068859 (210 pages) 

o CITY-KLUP_072504-CITY-KLUP_072715 (212 pages) 

o CITY-KLUP_072716-CITY-KLUP_072892 (177 pages) 

o CITY-KLUP_076551-CITY-KLUP_076613 (63 pages) 

o CITY-KLUP_076614-CITY-KLUP_076656 (43 pages) 

o CITY-KLUP_076959-CITY-KLUP_077000 (42 pages) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 408 of 433 PageID #:15829
88 

o CITY-KLUP_077001-CITY-KLUP_077133 (133 pages) 

o CITY-KLUP_077134-CITY-KLUP_077266 (133 pages) 

o CITY-KLUP_077681-CITY-KLUP_077765 (85 pages) 

o CITY-KLUP_077796-CITY-KLUP_077872 (77 pages) 

o CITY-KLUP_084036-CITY-KLUP_084211 (176 pages) 

o CITY-KLUP_084323-CITY-KLUP_084331 (9 pages) 

o CITY-KLUP_106348-CITY-KLUP_106384 (37 pages) 

o CITY-KLUP_106385-CITY-KLUP_106483 (99 pages) 

o CITY-KLUP_107146-CITY-KLUP_107189 (44 pages) 

o CITY-KLUP_107190-CITY-KLUP_107313 (124 pages) 

o CITY-KLUP_107314-CITY-KLUP_107316 (3 pages) 

o CITY-KLUP_113595-CITY-KLUP_113668 (74 pages) 

o CITY-KLUP_113669-CITY-KLUP_113670 (2 pages) 

o CITY-KLUP_115547-CITY-KLUP_115632 (86 pages) 

o CITY-KLUP_120032-CITY-KLUP_120099 (68 pages) 

o CITY-KLUP_126893-CITY-KLUP_126928 (36 pages) 

o CITY-KLUP_127421-CITY-KLUP_127431 (11 pages) 

o CITY-KLUP_127432-CITY-KLUP_127447 (16 pages) 

o CITY-KLUP_127448-CITY-KLUP_127457 (10 pages) 

o CITY-KLUP_127458-CITY-KLUP_127468 (11 pages) 

o CITY-KLUP_127469-CITY-KLUP_127499 (31 pages) 

o CITY-KLUP_127527-CITY-KLUP_127548 (22 pages) 

o CITY-KLUP_127549-CITY-KLUP_127560 (12 pages) 

o CITY-KLUP_127561-CITY-KLUP_127576 (16 pages) 

o CITY-KLUP_127688-CITY-KLUP_127709 (22 pages) 

o CITY-KLUP_127710-CITY-KLUP_127889 (180 pages) 

o CITY-KLUP_128445-CITY-KLUP_128514 (70 pages) 

CITY-KLUP_128515-CITY-KLUP_128530 (16 pages) 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 409 of 433 PageID #:15830
89 

Attachment C – Compensation 

Report of Plaintiff's Expert – Michael D. Brasfield 

James Kluppelberg v. Jon Burge and City of Chicago, et al. 

No. 1:13-cv-03963 

My compensation for work related to this case is $300 per hour, with a four hour minimum. 

Deposition and trial testimony is billed at a flat rate of $1200 for up to four hours. After four 

hours, the hourly rate of $300 is charged. Time spent traveling and waiting to testify is 

considered billable time. Reasonable expenses may be charged with prior approval. 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 410 of 433 PageID #:15831
90 

Attachment D - Resume 

Report of Plaintiff's Expert – Michael D. Brasfield 

James Kluppelberg v. Jon Burge and City of Chicago, et al. 

No. 1:13-cv-03963 

Education:

Bachelor of Arts, Police Administration - University of Washington, Seattle, WA 

Senior Management Institute for Police - Police Executive Research Forum, Washington, 

D.C. 

 Professional Experience: 

2003-2009 Elected Sheriff of Jefferson County, Washington

After retiring for a second time, and returning to the small rural county that I had chosen 

as my permanent retirement home, I ran for public office. This 1,815 square mile, 

predominantly rural county has a full time resident population of 26,000. The Jefferson 

County Sheriff's Office, established in 1853, is one of the oldest law enforcement 

organizations in the state of Washington. The Sheriff's Office budget for fiscal year 2008 

was $4.5 million. The Office has 50 employees and a large network of volunteers and 

reserve deputies. I was re-elected to a 2nd term which began on January 1, 2007 by an 

80% majority. I retired from this office in March 2009. 

2001 – 2003 Consultant and Program Director - South Downtown Foundation 

Responsibility for administering several million dollars for improving public safety in the 

International District, SoDo, and Pioneer Square neighborhoods of Seattle. Coordinated 

efforts with the City of Seattle, the Seattle Police Department and various interest and 

civic groups in the area. 

1995-2001 Police Chief of Fort Lauderdale, Florida

The 33 square mile city has a full time resident population of 165,000. An estimated 

additional 60,000 "snow bird" residents return to second homes in the city during the 6-

month winter season. Fort Lauderdale serves as the seat of government for a county of 

1.5 million and is in the heart of a diverse tri-county (Dade, Broward, and Palm Beach) 

population of 4 million. As one of the premier tourist destinations in South Florida, over 

12 million passengers come through the airport each year. The ocean port handles the 

second largest number of cruise ship sailings in the world. Fort Lauderdale serves as the 

governmental and business hub of the County. 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 411 of 433 PageID #:15832
91 

The City employed a workforce of 2,600 employees and operated with a budget of over 

$334 million. IAFF, FOP, and AFSCME Unions represent the fire, police, and general 

employees, respectively. The Fort Lauderdale Police Department had a budget of $60 

million and consisted of 500 sworn positions and 300 civilian positions. In 2000 the 

department received 600,000 calls for service, dispatched over 200,000 of those calls, 

made over 20,000 arrests, and issued over 65,000 traffic citations. The Department is 

now nationally recognized as an innovative leader in the field of community policing and 

was one of only a handful of cities nationwide to be selected as a Community Policing 

Demonstration Site by the Department of Justice. Oversaw and operated the only 

municipal jail in the state of Florida. 

A small sampling of initiatives undertaken over the 6 years includes: 

x First large municipal police agency in Florida to receive accreditation 

x Automobile anti-theft tactics that have reduced auto thefts by nearly 35% in one 

year 

x Aggressive property crime reduction efforts in the area of strengthened pawn shop 

record sharing and accountability 

x Partnerships with State Probation and Parole staff in "Ride Along Programs" with 

our patrol officers to remove violators from the community 

x Establishment of "Citizens on Patrol" in specially marked vehicles to enhance 

public safety 

x Aggressive enforcement of traffic and "quality of life" ordinances to help 

neighborhoods 

x Establishment of a Nuisance Abatement Board to address drug and prostitution 

activity 

x Significant reduction in alarm false dispatches to allow increased proactive patrol 

x Innovative anti-prostitution and anti-gang programs 

x Federal "Weed & Seed" designation, which has allowed us to partner with a wide 

range of community and governmental entities 

x Thirteen sessions of the Citizen Police Academy - a 3 month, 35 hour program 

x Summer COPJAM activities for at risk youth 

x Truancy and curfew programs which have dramatically reduced the rate of 

property crimes 

In 1997 undertook a city financed $10 million technology enhancement initiative for the 

Department. Half of it was for a new state of the art Computer Aided Dispatch (CAD) 

and Record Management System (RMS), and the other half for network servers, 

individual personal computers, Geographical Information System (GIS), Automated 

Fingerprint Identification System (AFIS), internet access, bar coding for property control 

and evidence, and the largest law enforcement deployment of handheld, pen based, 

Motorola Forte' computers for patrol officers. 

During my 6 year tenure, we successfully competed and received nearly $8 million in 

Federal and State grants. More than forty percent of the grant funds have gone into nonCase: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 412 of 433 PageID #:15833
92 

traditional community and social service support programs, in lieu of police personnel 

and hardware. 

During my tenure there was a dramatic improvement in the relationship between our 

unions and management. We successfully negotiated two (3 year) contracts without 

incident or rancor. Although there has been an increase in professional expectations of 

accountability for our employees, disciplinary appeals to arbitration had been all but 

eliminated. 

1990-1995 Assistant Chief - Seattle Police Department

An appointive, exempt position reporting directly to the Chief of Police - acted as the 

Executive Assistant Chief of the Department and commanded the Support Bureau. The 

Police Department employed over 1,875 personnel and had an annual budget of $120 

million. 

Responsible for and oversaw the activity of nine uniquely different divisions including: 

Training; Internal Investigations; Crime Prevention: Intelligence; Communications; 

Personnel; Records & Evidence; Data Processing; and Fiscal, Property, & Fleet 

Management. As the Executive Assistant Chief, was responsible for the day-to-day 

operation of the agency including authority for hiring, discipline, and administrative 

decisions. In addition, acted as primary management labor relations and contract 

negotiator with 12 labor unions. This bureau employed approximately 100 sworn and 

450 civilians. Served as the Seattle Police Department's jail liaison executive, as well as 

jail contract negotiator. Routinely served as acting Chief of Police. 

1986-1990 Major

An appointive, exempt position - command of SPD Inspectional Services Division, 

reported directly to the Chief of Police. Coordinated and implemented strategic planning 

for the entire Department and conducted periodic performance inspections of 

Departmental units. Oversaw the preparation of the Department's budget, as well as the 

formulation of departmental rules, policies, and procedures. Acted as liaison with elected 

officials and community groups. 

1984-1985 Captain

Command of SPD North Precinct. Responsible for Patrol operations in an area of the city 

that encompassed a population of 200,000 people and a uniformed force of 130 

officers. The precinct contained over a dozen unique communities including the 

University of Washington. Routinely served as acting Patrol Major overseeing all four 

patrol precincts - 550 sworn personnel. 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 413 of 433 PageID #:15834
93 

1982-1983 Captain

Command of SPD Internal Investigations Section, reported directly to the Chief of 

Police. Responsible for overseeing the investigation of alleged misconduct of nearly 

2,000 sworn and civilian members of the Department. 

1980-1981 Captain

Command of SPD West Precinct. Responsible for Patrol Operations in the downtown 

core of the city. Major league sports facilities, waterfront maritime industries, 

transportation, and financial, retail and business headquarters serving a daytime 

population of 300,000 -command of 150 sworn officers. 

1978-1979 Lieutenant

Commander of Basic Recruit Training. Responsible for the operation and administration 

of the recruit training for SPD as well as the contract recruit training with the Washington 

State Criminal Justice Training Commission for over 100 law enforcement agencies 

state-wide. Average recruit population on campus of 140 in 4 concurrent classes, as well 

as a multi-agency training staff. Also served for a brief period as a patrol watch 

commander in the downtown business area. 

1975 – 1977 Sergeant

Served as supervisor in the following: Patrol - uniformed patrol operations; Special 

Patrol Unit - plain clothes tactical response to priority crime problems, deployment at 

unusual occurrences, dignitary protection; Internal Investigations Section - investigation 

of citizen, departmental, and criminal allegations of police misconduct. 

1972 – 1975 Detective 

Served in the following: Accident Investigation Section - plain clothes follow-up 

investigation of hit-run, serious injury and fatality motor vehicle accidents; Burglary 

Section - investigated serious crimes directed against property; Vice Section - 

investigated organized crime, prostitution, pornography, liquor, and gambling activities, 

and engaged in extended undercover assignments. 

1968-1971 Patrol Officer

Started with Mercer Island (WA) P.D. in 1968, and then began career with Seattle P.D. in 

1969. 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 414 of 433 PageID #:15835
94 

Training (small sampling):

x Police Liability and the Management of Police Discipline - Americans for 

Effective Law Enforcement 

x Police Technology and Efficiency - International Association of Chiefs of Police 

x Total Quality Management - The Institute for Quality Service 

x Assessment Center Operations and Management - Federal Bureau of Investigation 

x Executive Development - Federal Bureau of Investigation 

x Incident Command System – National Incident Management System – Through 

Level 4 

x Gambling Enforcement and Supervision - Washington State Gambling 

Commission 

x Labor Relations and Negotiations - Federal Bureau of Investigation and 

Washington Association of Cities 

x Hazardous Materials Incident Management - National Highway Transportation 

Safety Board 

x Dignitary Protection Management and Supervision - U.S. Secret Service 

x Supervision of Auto Theft Investigation - National Auto Theft Bureau 

x Police Traffic Supervision - Northwestern Traffic Institute 

x Municipal Budget Management - Office of Management and Budget 

x Training for Trainers - Washington State Criminal Justice Training Commission 

x Managing Computer Operations - Department of Administrative Services 

x Investment in Excellence - The Pacific Institute 

x Organized and White Collar Crime - The University of Washington 

x Management of Computer Fraud Investigations - USWEST 

Law Enforcement Committees & Membership:

National:

x International Association of Chiefs of Police – Honorary Life Member 

x Police Executive Research Forum – Past Committee Co-Chair 

x National Sheriffs’ Association – Life Member 

x American Correctional Association - Member 

State:

x Appointed by the Governor and served as the only law enforcement member of 

the Washington State Sentencing Guidelines Commission (August 2003 – 2008) 

x Appointed to, and served as the chair of the Washington State Board on Law 

Enforcement Training Standards and Education (March 2003 – 2008) 

x Homicide Investigation Tracking System (HITS) Advisory Board (May 2003 – 

2006) 

x Executive Board member of the Washington State Sheriffs’ Association (May 

2006 – 2008) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 415 of 433 PageID #:15836
95 

x Washington Association of Sheriffs and Police Chiefs – Honorary Life Member 

Local:

x Past chair of Jefferson County Domestic Violence/Sexual Assault Program 

x Member of the Peninsula College Criminal Education Program Board 

x Executive Board of Olympic Peninsula Narcotics Enforcement Task Force 

x Executive Board of JeffCom 911 Communications System 

x Jefferson County Law & Justice Council 

x Olympic Law Enforcement Executives Association 

Achievements (sampling):

x Past Co-Chair of Private Sector Liaison Committee - International Association of 

Chiefs of Police 

x Coordinator for successful federal grant application on Community 

Policing Program (N.I.J.) 

x National Institute of Justice Symposium on Closed Circuit Television for 

deterrence and investigation of crime - Washington, DC 

x National Institute of Justice Symposium on Metro Area Drug Strategies - 

Washington, DC 

x Coordinator for federal grant application on Narcotics Strategies in Public 

Housing 

x Coordinator for federal grant application on Targeting Young Adult Gang Leaders 

x Federal Bureau of Investigation - National Law Enforcement Budget Advisory 

Group - Appointed by the Director of the F.B.I. 

x Broward County Chiefs' Association - President and Steering & Training 

Committees 

x Southeast Florida Drug Task Force - Board of Directors 

x Metropolitan Broward County Organized Crime Intelligence Unit - Board of 

Directors 

x Florida Police Chiefs' Association - Ethics Committee 

x Visiting management assessor for cities of New Orleans (LA), Columbus (OH), 

Portland, (OR), San Francisco (CA), Bremerton (WA) 

x Contract consultant (KOBA Associates) for peer review of NIJ grant work on the 

establishment of Computer Crimes Units 

x Contract consultant (Federal Housing & Urban Development Grant) to visit and 

analyze 6 major U.S. cities (Boston, Baltimore, Memphis, Oxnard, Cleveland & 

Seattle) police agencies and community policing in public housing 

x Subject matter and best practices expert on law enforcement personnel selection, 

screening, and back grounding – USIS Investigative Solutions Conference 

x Developed statewide law enforcement employment screening and back grounding 

model for the Washington Association of Sheriffs and Police Chiefs 

x Oversight responsibility for acquisition of Computer Aided Dispatch and Mobile 

Digital Terminal System 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 416 of 433 PageID #:15837
96 

x Oversight responsibility for acquisition of Comprehensive Shared Records 

Management System 

x Oversight responsibility for acquisition of Jail Booking Video Imaging System 

x Oversight responsibility for management of computerized Patrol Deployment 

Model 

x Responsibility for design and construction oversight, acceptance and start-up of 

new police precinct facility 

x Evaluation of Detective Decentralization Program and Detective Case 

Management System 

x Acquisition of Geo-based Automated Mapping System 

Selected Publications:

x Contributor - National Institute of Justice - Off-Duty Police Employment 

Practices 

x Citation - Federal Bureau of Investigation article on joint Police-Community 

Partnerships 

x Author of national and state articles - alarm reduction issues and strategies 

x Author of several historical articles - homicides of police officers

Prior Law Enforcement & Community Service:

x Major City Chiefs - Human Resources sub-committee 

x Washington State Chiefs & Sheriffs - Information Technology sub-committee 

x Mayor's Task Force on Street People and the Homeless 

x Selection and oversight committee for Police Department Management Study 

consultant contract 

x Selection and oversight committee for Police-Citizen Complaint Process 

consultant contract 

x Executive Member - South Florida Regional Law, Safety, and Justice Committee 

x Automated Fingerprint Identification System / Jails - On-site benchmark testing & 

nationwide visitation team 

x Health Service and Police Community Based Alcohol Triage Program 

x King County Executive - Jail Advisory Committee (JCWG) 

x City of Seattle - Deferred Compensation Plan provider selection and oversight 

x Evaluation and Selection Committee - RFP responses for design of new municipal 

campus 

x Seattle Police Department - reorganization committee that resulted 

in Departmental restructuring 

x Explorer Scout Law Enforcement Program 

x United Way of Broward County - Board of Directors 

x Broward County Commission on Substance Abuse - Chair, Board of Directors 

x Broward County Juvenile Justice Advisory Board 

x Broward County Substance Abuse Policy Advisory Board 

x Broward Workshop - Criminal Justice Committee 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 417 of 433 PageID #:15838
97 

x Florida Department of Law Enforcement - UCR Advisory Committee 

x Alarm Association of Florida / Law Enforcement - Board of Directors (1996-

1997) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 418 of 433 PageID #:15839
Supplement to Expert Report of Michael Brasfield 

Attachment E – Bibliography of Background Source Materials 

 Following is a list of source materials that describe generally accepted policing practices, 

including at the relevant time period. The practices described include but are not limited to 

record-keeping, file maintenance, report writing, conducting homicide investigations, witness 

interrogations, supervision, etc. 

 This list of reference materials is not intended to be exhaustive and is supplemented by 

my extensive experience with police practices, including my familiarity with the policies used by 

other police departments nationwide, as well as industry standards established by organizations 

like the International Association of Chiefs of Police. 

Reference Materials Generally 

Death Investigation: A Guide for the Scene Investigator 

U.S. Department of Justice /Office of Justice Programs / National Institute of Justice 

Crime Scene Investigation: A Guide for Law Enforcement 

U.S. Department of Justice /Office of Justice Programs / National Institute of Justice 

Homicide Guide 

International Association of Chiefs of Police 

Los Angeles Police Department SOP for Homicide Investigations 

http://www.lapdonline.org/lapd_manual/volume_4.htm#710 

Murder Book 710.30 

Promoting Effective Homicide Investigations 

Police Executive Research Foundation 

Homicide Investigation Standard Operating Procedures 

John M. Howell – Police Executive Forum 

Homicide Process Mapping – Best Practices for Increasing Homicide Clearances 

A Project of the U.S. Department of Justice, Office of Justice Programs, Bureau of Justice 

Assistance 

Practical Homicide Investigation Checklist and Field Guide, Second Edition 

Vernon J. Geberth 

Techniques of Crime Scene Investigation (now in 8th edition) 

Barry A.J. Fisher 

Homicide investigation; practical information for coroners, police officers, and other 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 419 of 433 PageID #:15840
investigators 

Snyder, LeMoyne 

Practical Cold Case Homicide Investigations Procedural Manual 

Richard H. Walton 

Death Investigation: Systems and Procedures 

Randy Hanzlick 

Forensic Pathology – Practical Aspects of Criminal and Forensic Investigations 

Dominick DiMaio & Vincent J. M. DiMaio 

Death Scene Investigation: A Field Guide 

Scott A. Wagner 

Death Investigator’s Handbook – Volumes 1 & 2 

Louis N. Eliopulos 

Cold Case Homicides: Practical Investigative Techniques 

Richard H. Walton 

Homicide Scene Investigation – A Manual For Public Prosecutors 

http://www.justiceacademy.org/iShare/Library-Training/Homicide-Scene-Manual.pdf 

Death Scene Checklist Sheet 

http://www.insidethetape.com/Jan-2011-EATH%20SCENE%20CHECKLIST%20SHEET.PDF

References that Largely Pre-Date Kluppelberg Investigation 

Dr. Henry Faulds (1843-1930). A towering figure in the history of forensic sciences, it was 

Faulds who first recognized the value of fingerprints to criminal identification. The Faulds 

scrapbooks include research notes, original drawings and studies of fingerprint patterns and 

typology, as well as correspondence with individuals and crime fighting organizations around the 

world, dating from the (late 1870’s) until shortly before the doctor's death in 1930. 

International Association for Identification (www.theiai.org) founded in the (1915). 

• Sparks from the Anvil 1933-1937 

• IAI Newsletter 1940-1951 

• ID News Aug 1951 - 1987 

• Journal of Forensic Identification (JFI) 1988 - 2013 

Locard, E. L’Enquete Criminelle et les Methodes Scientifique. Paris: Ernest Flammarion, (1920). 

Homicide investigation; Frankel, Harold A. (1931) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 420 of 433 PageID #:15841
Criminology – Robert H. Gault Northwestern University (1932) 

La police scientifique. les homicides.--Les vols.--Les incendies criminels.--Les faux.--La fausse 

monnaie. Bischoff, Marc (1938) 

Homicide investigation; practical information for coroners, police officers, and other 

investigators, 

by Snyder, LeMoyne (1944, 1950, 1959, 1967, 1977) 

Law of Belligerent Occupation - The Judge Advocate General's School (1945) 

Techniques of Crime Scene Investigation (now in 8th edition) originally published in (1949) 

Techniques of Crime Scene Investigation is a classic book on how to use forensic science to 

investigate crimes. The text was first published in Swedish in 1949 by Chief Superintendent 

Arne Svensson, director of the Laboratory, Criminal Investigation Department, and 

Superintendent Otto Wendel, Criminal Investigation Department, Stockholm, Sweden. In 1955 it 

was printed in English as Crime Detection and then revised into a second, expanded American 

Edition under the title Techniques of Crime Scene Investigation in 1965. In 1981 I was invited to 

revise it in a third edition and subsequently into fourth, fifth, sixth, seventh and eighth editions. 

Kirk, P. L. Crime Investigation. New York: Interscience, John Wiley & Sons (1953). 

The detection of secret homicide; a study of the medico-legal system of investigation of sudden 

and unexplained deaths. Havard, John D. J. (1960) 

Institute on Homicide Investigation Techniques / presented by the Southwestern Law 

Enforcement Institute, Dallas, Texas; general editor: Robert A. Wilson. (1961) 

Practical homicide investigation. With an introd. by William P. Maheady. (1961) 

“We have learned the lesson of history, ancient and modern, that a system of criminal law 

enforcement which comes to depend on the ‘confession’ will, in the long run, be less 

reliable and more subject to abuses than a system which depends on extrinsic evidence 

independently secured through skillful investigation.” Escobedo v. Illinois, 378 U.S. 478, 

488–489 (1964) 

Thorwald, J. Crime and Science. Harcourrt, Brace & World, Inc.: New York, [LC Cat. no. 67-

20323]. (1966) 

Police Detective Function (W.S.U.) by V. A. Leonard (1970) 

Murder investigation. Oughton, Frederick (1971) 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 421 of 433 PageID #:15842
Fox, Richard H. and Carl L. Cunningham. Crime Scene Search and Physical Evidence 

Handbook. 

Washington, D.C.: U.S. Department of Justice, National Institute of Justice, (1973). 

Homicide: investigative techniques, by Daniel J. Hughes. (1974) 

Kirk, P.L. Crime Investigation, 2nd Edition. New York: John Wiley & Sons, (1974). 

Police: the investigation of violence / Keith Simpson (1978) 

Smyth, F. Cause of Death: The Story of Forensic Science. Van Nostrand Rheinhold Company: 

New York, [ISBN 0-442-20041-2]. (1980) 

Zonderman, J. Beyond the Crime Lab: The New Science of Investigation. John Wiley & Sons: 

New York, [ISBN 0-471-62296-6]. (1980) 

Homicide investigation standards textbook / Joseph C. DeLadurantey, Daniel R. Sullivan. (1980) 

Saferstein, R. Forensic Science Handbook, Volumes I, II, III. Englewood Cliffs, N.J.: PrenticeHall, (1982/1988/1993). 

DeForest, P.R., R.E. Gaensslen, and H.C. Lee. Forensic Science: An Introduction to 

Criminalistics. New York: McGraw-Hill, Inc., (1983). 

Rosenfield, I.; Ziff, E. van Loon, B. DNA for Beginners. Writers and Readers Publishing, Inc. 

[ISBN 0-86316-023-9, pkb.]. (1983) 

Practical homicide investigation: tactics, procedures, and forensic techniques / Vernon J. 

Geberth. (1983) 

Signature 

February 19, 2016 

Date 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 422 of 433 PageID #:15843
IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

JACQUES RIVERA, 

 Plaintiff, 

 v. 

REYNALDO GUEVARA, et al.,

 Defendants. 

)

)

)

)

)

)

)

)

)

)

Case No. 12 C 4428 

Hon. Joan B. Gottschall, 

District Judge 

Hon. Mary M. Rowland, 

Magistrate Judge 

JURY TRIAL DEMANDED 

EXHIBIT B TO THE DECLARATION OF MICHAEL BRASFIELD 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 423 of 433 PageID #:15844
Michael Brasfield and Associates, Inc. 

641 Olele Point Road Phone: 360-301-4465 

Port Ludlow, WA 98365 E-mail: brasfield@commandscene.com 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

Jacques Rivera v. Guevara, et al. 

No. 12 CV 4428 

ATTACHMENT D 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 424 of 433 PageID #:15845
1

Michael D. Brasfield - Curriculum Vitae

Education:

Bachelor of Arts, Police Administration - University of Washington, Seattle, WA

Senior Management Institute for Police - Police Executive Research Forum, Washington, 

D.C.

Professional Experience:

2003-2009 Elected Sheriff of Jefferson County, Washington

After retiring for a second time, and returning to the small rural county that I had chosen 

as my permanent retirement home, I ran for public office. This 1,815 square mile, 

predominantly rural, county has a full time resident population of only 26,000. The 

Jefferson County Sheriff's Office, established in 1853, is one of the oldest law 

enforcement organizations in the state of Washington. The Sheriff's Office budget for 

fiscal year 2008 was $4.5 million. The Office has 50 employees and a large network of 

volunteers and reserve deputies. I was re-elected to a 2nd term which began on January 1, 

2007 by an 80% majority. I retired from this office in March 2009.

2001 – 2003 Consultant and Program Director - South Downtown Foundation

Responsibility for administering several million dollars for improving public safety in the 

International District, SoDo, and Pioneer Square neighborhoods of Seattle. Coordinated 

efforts with the City of Seattle, the Seattle Police Department and various interest and 

civic groups in the area.

1995-2001 Police Chief of Fort Lauderdale, Florida

The 33 square mile city has a full time resident population of 165,000. An estimated 

additional 60,000 "snow bird" residents return to second homes in the city during the 6-

month winter season. Fort Lauderdale serves as the seat of government for a county of 

1.5 million and is in the heart of a diverse tri-county (Dade, Broward, and Palm Beach) 

population of 4 million. As one of the premier tourist destinations in South Florida, over 

12 million passengers come through the airport each year. The ocean port handles the 

second largest number of cruise ship sailings in the world. Fort Lauderdale serves as the 

governmental and business hub of the County.

The City employed a workforce of 2,600 employees and operated with a budget of over 

$334 million. IAFF, FOP, and AFSCME Unions represent the fire, police, and general 

employees, respectively. The Fort Lauderdale Police Department had a budget of $60 

million and consisted of 500 sworn positions and 300 civilian positions. In 2000 the 

department received 600,000 calls for service, dispatched over 200,000 of those calls, 

made over 20,000 arrests, and issued over 65,000 traffic citations. The Department is 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 425 of 433 PageID #:15846
2

now nationally recognized as an innovative leader in the field of community policing and 

was one of only a handful of cities nationwide to be selected as a Community Policing 

Demonstration Site by the Department of Justice. Oversaw and operated the only 

municipal jail in the state of Florida.

A small sampling of initiatives undertaken over the 6 years includes:

x First large municipal police agency in Florida to receive accreditation

x Automobile anti-theft tactics that have reduced auto thefts by nearly 35% in one 

year

x Aggressive property crime reduction efforts in the area of strengthened pawn shop 

record sharing and accountability

x Partnerships with State Probation and Parole staff in "Ride Along Programs" with 

our patrol officers to remove violators from the community

x Establishment of "Citizens on Patrol" in specially marked vehicles to enhance 

public safety

x Aggressive enforcement of traffic and "quality of life" ordinances to help 

neighborhoods

x Establishment of a Nuisance Abatement Board to address drug and prostitution 

activity

x Significant reduction in alarm false dispatches to allow increased proactive patrol

x Innovative anti-prostitution and anti-gang programs

x Federal "Weed & Seed" designation, which has allowed us to partner with a wide 

range of community and governmental entities

x Thirteen sessions of the Citizen Police Academy - a 3 month, 35 hour program 

x Summer COPJAM activities for at risk youth

x Truancy and curfew programs which have dramatically reduced the rate of 

property crimes

In 1997 undertook a city financed $10 million technology enhancement initiative for the 

Department. Half of it was for a new state of the art Computer Aided Dispatch (CAD) 

and Record Management System (RMS), and the other half for network servers, 

individual personal computers, Geographical Information System (GIS), Automated 

Fingerprint Identification System (AFIS), internet access, bar coding for property control 

and evidence, and the largest law enforcement deployment of handheld, pen based, 

Motorola Forte' computers for patrol officers.

During my 6 year tenure, we successfully competed and received nearly $8 million in 

Federal and State grants. More than forty percent of the grant funds have gone into nontraditional community and social service support programs, in lieu of police personnel 

and hardware.

During my tenure there was a dramatic improvement in the relationship between our 

unions and management. We successfully negotiated two (3 year) contracts without 

incident or rancor. Although there has been an increase in professional expectations of 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 426 of 433 PageID #:15847
3

accountability for our employees, disciplinary appeals to arbitration had been all but 

eliminated.

1990-1995 Assistant Chief - Seattle Police Department

An appointive, exempt position reporting directly to the Chief of Police - acted as the 

Executive Assistant Chief of the Department and commanded the Support Bureau. The 

Police Department employed over 1,875 personnel and had an annual budget of $120 

million.

Responsible for and oversaw the activity of nine uniquely different divisions including: 

Training; Internal Investigations; Crime Prevention: Intelligence; Communications; 

Personnel; Records & Evidence; Data Processing; and Fiscal, Property, & Fleet 

Management. As the Executive Assistant Chief, was responsible for the day-to-day 

operation of the agency including authority for hiring, discipline, and administrative 

decisions. In addition, acted as primary management labor relations and contract 

negotiator with 12 labor unions. This bureau employed approximately 100 sworn and 

450 civilians. Served as the Seattle Police Department's jail liaison executive, as well as 

jail contract negotiator. Routinely served as acting Chief of Police.

1986-1990 Major

An appointive, exempt position - command of SPD Inspectional Services Division, 

reported directly to the Chief of Police. Coordinated and implemented strategic planning 

for the entire Department and conducted periodic performance inspections of 

Departmental units. Oversaw the preparation of the Department's budget, as well as the 

formulation of departmental rules, policies, and procedures. Acted as liaison with elected 

officials and community groups.

1984-1985 Captain

Command of SPD North Precinct. Responsible for Patrol operations in an area of the city 

that encompassed a population of 200,000 people and a uniformed force of 130 

officers. The precinct contained over a dozen unique communities including the 

University of Washington. Routinely served as acting Patrol Major overseeing all four 

patrol precincts - 550 sworn personnel.

1982-1983 Captain

Command of SPD Internal Investigations Section, reported directly to the Chief of 

Police. Responsible for overseeing the investigation of alleged misconduct of nearly 

2,000 sworn and civilian members of the Department.

1980-1981 Captain

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 427 of 433 PageID #:15848
4

Command of SPD West Precinct. Responsible for Patrol Operations in the downtown 

core of the city. Major league sports facilities, waterfront maritime industries, 

transportation, and financial, retail and business headquarters serving a daytime 

population of 300,000 -command of 150 sworn officers.

1978-1979 Lieutenant

Commander of Basic Recruit Training. Responsible for the operation and administration 

of the recruit training for SPD as well as the contract recruit training with the Washington 

State Criminal Justice Training Commission for over 100 law enforcement agencies 

state-wide. Average recruit population on campus of 140 in 4 concurrent classes, as well 

as a multi-agency training staff. Also served for a brief period as a downtown watch 

commander in the downtown business area.

1975 – 1978 Sergeant

Served as supervisor in the following: Patrol - uniformed patrol operations;; Internal 

Investigations Section - investigation of citizen, departmental, and criminal allegations of 

police misconduct; Special Patrol Unit - plain clothes tactical response to priority crime 

problems, deployment at unusual occurrences, dignitary protection.

1972 – 1975 Detective

Served in the following: Accident Investigation Section - plain clothes follow-up

investigation of hit-run, serious injury and fatality motor vehicle accidents; Burglary 

Section - investigated serious crimes directed against property; Vice Section -

investigated organized crime, prostitution, pornography, liquor, and gambling activities, 

and engaged in extended undercover assignments.

1968-1971 Patrol Officer

Started with Mercer Island (WA) P.D. in 1968, and then began career with Seattle P.D. in 

1969.

Training (small sampling):

x Police Liability and the Management of Police Discipline - Americans for 

Effective Law Enforcement

x Police Technology and Efficiency - International Association of Chiefs of Police

x Total Quality Management - The Institute for Quality Service

x Assessment Center Operations and Management - Federal Bureau of Investigation

x Executive Development - Federal Bureau of Investigation

x Incident Command System – National Incident Management System – Through 

Level 4

x Gambling Enforcement and Supervision - Washington State Gambling 

Commission

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 428 of 433 PageID #:15849
5

x Labor Relations and Negotiations - Federal Bureau of Investigation and 

Washington Association of Cities

x Hazardous Materials Incident Management - National Highway Transportation 

Safety Board

x Dignitary Protection Management and Supervision - U.S. Secret Service

x Supervision of Auto Theft Investigation - National Auto Theft Bureau

x Police Traffic Supervision - Northwestern Traffic Institute

x Municipal Budget Management - Office of Management and Budget

x Training for Trainers - Washington State Criminal Justice Training Commission

x Managing Computer Operations - Department of Administrative Services

x Investment in Excellence - The Pacific Institute

x Organized and White Collar Crime - The University of Washington

x Management of Computer Fraud Investigations – USWEST

x National Center for Missing and Exploited Children - Alexandria, VA

Law Enforcement Committees & Membership:

National:

x International Association of Chiefs of Police – Honorary Life Member

x Police Executive Research Forum – Subscribing Member

x National Sheriffs’ Association – Life Member

x American Correctional Association – Member

x American Jail Association – Member

x Crisis Intervention Team International - Member

State:

x Appointed by the Governor and served as the only law enforcement member of 

the Washington State Sentencing Guidelines Commission (August 2003 – 2008)

x Appointed to, and served as the chair of the Washington State Board on Law 

Enforcement Training Standards and Education (March 2003 – 2008)

x Homicide Investigation Tracking System (HITS) Advisory Board (May 2003 –

2006)

x Executive Board member of the Washington State Sheriffs’ Association (May 

2006 – 2008)

x Washington Association of Sheriffs and Police Chiefs – Honorary Life Member

Local:

x Past chair of Jefferson County Domestic Violence/Sexual Assault Program

x Member of the Peninsula College Criminal Education Program Board

x Executive Board of Olympic Peninsula Narcotics Enforcement Task Force

x Executive Board of JeffCom 911 Communications System

x Jefferson County Law & Justice Council

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 429 of 433 PageID #:15850
6

x Olympic Law Enforcement Executives Association

Achievements (sampling):

x Past Co-Chair of Private Sector Liaison Committee - International Association of 

Chiefs of Police

x Coordinator for successful federal grant application on Community 

Policing Program (N.I.J.)

x National Institute of Justice Symposium on Closed Circuit Television for 

deterrence and investigation of crime - Washington, DC

x National Institute of Justice Symposium on Metro Area Drug Strategies -

Washington, DC

x Coordinator for federal grant application on Narcotics Strategies in Public 

Housing

x Coordinator for federal grant application on Targeting Young Adult Gang Leaders

x Federal Bureau of Investigation - National Law Enforcement Budget Advisory 

Group - Appointed by the Director of the F.B.I.

x Broward County Chiefs' Association - President and Steering & Training 

Committees

x Southeast Florida Drug Task Force - Board of Directors

x Metropolitan Broward County Organized Crime Intelligence Unit - Board of 

Directors

x Florida Police Chiefs' Association - Ethics Committee

x Visiting management assessor for cities of New Orleans (LA), Columbus (OH), 

Portland, (OR), San Francisco (CA), Bremerton (WA)

x Contract consultant (KOBA Associates) for peer review of NIJ grant work on the 

establishment of Computer Crimes Units

x Contract consultant (Federal Housing & Urban Development Grant) to visit and 

analyze 6 major U.S. cities (Boston, Baltimore, Memphis, Oxnard, Cleveland & 

Seattle) police agencies and community policing in public housing

x Subject matter and best practices expert on law enforcement personnel selection, 

screening, and back grounding – USIS Investigative Solutions Conference

x Developed statewide law enforcement employment screening and back grounding 

model for the Washington Association of Sheriffs and Police Chiefs

x Oversight responsibility for acquisition of Computer Aided Dispatch and Mobile 

Digital Terminal System

x Oversight responsibility for acquisition of Comprehensive Shared Records 

Management System

x Oversight responsibility for acquisition of Jail Booking Video Imaging System

x Oversight responsibility for management of computerized Patrol Deployment 

Model

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 430 of 433 PageID #:15851
7

x Responsibility for design and construction oversight, acceptance and start-up of 

new police precinct facility

x Evaluation of Detective Decentralization Program and Detective Case 

Management System

x Acquisition of Geo-based Automated Mapping System

Selected Publications:

x Contributor - National Institute of Justice - Off-Duty Police Employment 

Practices

x Citation - Federal Bureau of Investigation article on joint Police-Community 

Partnerships

x Author of national and state articles - alarm reduction issues and strategies

x Author of several historical articles - homicides of police officers

Prior Law Enforcement & Community Service:

x Major City Chiefs - Human Resources sub-committee

x Washington State Chiefs & Sheriffs - Information Technology sub-committee

x Mayor's Task Force on Street People and the Homeless

x Selection and oversight committee for Police Department Management Study 

consultant contract

x Selection and oversight committee for Police-Citizen Complaint Process 

consultant contract

x Executive Member - South Florida Regional Law, Safety, and Justice Committee

x Automated Fingerprint Identification System / Jails - On-site benchmark testing & 

nationwide visitation team

x Health Service and Police Community Based Alcohol Triage Program

x King County Executive - Jail Advisory Committee (JCWG)

x City of Seattle - Deferred Compensation Plan provider selection and oversight

x Evaluation and Selection Committee - RFP responses for design of new municipal 

campus

x Seattle Police Department - reorganization committee that resulted 

in Departmental restructuring

x Explorer Scout Law Enforcement Program

x United Way of Broward County - Board of Directors

x Broward County Commission on Substance Abuse - Chair, Board of Directors

x Broward County Juvenile Justice Advisory Board

x Broward County Substance Abuse Policy Advisory Board

x Broward Workshop - Criminal Justice Committee

x Florida Department of Law Enforcement - UCR Advisory Committee

x Alarm Association of Florida / Law Enforcement - Board of Directors (1996-

1997)

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 431 of 433 PageID #:15852
INDEX OF FILES RELIED UPON BY BRASFIELD 

FILED UNDER SEAL 

Homicide Investigative Files Produced at RFC2127-RFC16401 

G025122 H376814 M020288 N237929

G028593 H422157 M027036 N262285

G063126 H487637 M079435 N267450

G067109 J052070 M127008 N363181

G069345 J053513 M165445 N413068

G077193 J075073 M184949 N414150

G129819 J080925 M245807 N475901

G159909 J117497 M258570 N513129

G235531 J139200 M264219 N517875

G256674 J209456 M287641 N581836

G303248 J215119 M381429 N592324

G317267 J252204 M400227 P025834

G317507 J353821 M538914 P025950

G321911 J355220 M541953 P028950

G382131 J369257 M546558 P049272

G418721 J388481 M550042 P051734

G451229 J409858 M551461 P054396

G471800 J423347 M556260 P060434

H064504 J478062 M558552 P128067

H091575 K103034 M579697 P129569

H094573 K176170 M588005 P141860

H095844 K197321 M599001 P175665

H100760 K205158 N016505 P190627

H105557 K227675 N018105 P218019

H126865 K285989 N028256 P251800

H167635 K292921 N050133 P272087

H172729 K314297 N053000 P310965

H174403 K417078 N114280 P317758

H193697 K419172 N133637 P342256

H208106 K455932 N162782 P348565

H265414 K466033 N176796 P372509

H279780 K468422 N192214 P402641

H316198 K502173 N201263 P474894

H323287 K530917 N203334 P526822

H375595 K575912

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 432 of 433 PageID #:15853
Criminal Defense Files 

J209456 

(JR-L205069 - 

JR-L206061) 

N028256 

(JR-L207967 - 

JR-L208332) 

N162782 

(JR-L227919 - 

JR-L228812) 

P272087 

(JR-L212423 - 

JR-L212489) 

P526822 

(JR-L212490 - 

JR-L212757) 

M258570 

(JR-L223600 - 

JR-L224210) 

 

Permanent Retention Files 

J209456 

(RFC160510-

RFC160549) 

N028256 

(RFC162327-

RFC162389) 

P272087 

(RFC163445-

RFC163473) 

P526822 

(RFC163728-

RFC163753) 

M258570 

(RFC161784-

RFC161828) 

N162782 

(RFC162531-

RFC162577) 

 

Case: 1:12-cv-04428 Document #: 313-15 Filed: 09/19/17 Page 433 of 433 PageID #:15854