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Case: 1:13-cv-04924 Document #: 267-7 Filed: 07/16/18 Page 1 of 93 PageID #:1989

EXHIBIT F
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
- MAY 11,Page 2 of 93 PageID #:1990
2018
1 IN THE UNITED STATES DISTRICT COURT 1 APPEARANCES: (continued)
NORTHERN DISTRICT OF ILLINOIS
2 EASTERN DIVISION 2 Ms. Lisa Madigan, Attorney General, State
of Illinois, by:
3 ANNABEL K. MELONGO, ) 3 Ms. Shirley R. Calloway
) Assistant Attorney General
4 Plaintiff, ) 4 Office of the Attorney General
) Case No. 100 West Randolph Street
5 vs. ) 13-CV-04924 5 Chicago, Illinois 60601
) 312.814.5581
6 ASA ROBERT PODLASEK, et al., ) 6 scalloway@atg.state.il.us
) on behalf of Defendant Kyle French;
7 Defendants. ) 7
Ms. Dina M. Ninfo
8 8 Angelini, Mills, Woods & Ori Law
155 North Michigan Avenue
9 The deposition of CAROL SPIZZIRRI, called 9 Suite 400
Chicago, Illinois 60601
10 by the Plaintiff, taken pursuant to the Rules of 10 312.621.0000
dnifro@amwolawil.com
11 Civil Procedure of the United States District 11 on behalf of Defendant Ms. Carol
Spizzirri.
12 Courts pertaining to the taking of depositions, 12
Also Present:
13 taken before Barbara Anthony, CSR, RPR, CSR 13
Ms. Annabel Melongo - via the telephone
14 License No. 084-003185, a notary public within and 14
15 for the County of DuPage and State of Illinois, 15
16 taken at 180 North LaSalle Street, Suite 3600, 16
17 Chicago, Illinois, on Friday, May 11, 2018, 17
18 commencing at the hour of 9:00 a.m. 18
19 19
20 20
21 21
22 22
23 23
24 24
1 3

1 APPEARANCES: 1 INDEX
2 Ms. Julia K. Schwartz 2 WITNESS PAGE
Miller Shakman & Beem, LLP
3 180 North LaSalle Street 3 CAROL SPIZZIRI
Suite 3600
4 Chicago, Illinois 60601 4 Examination
312.263.3700 By Ms. Schwartz 5
5 jschwartz@millershakman.com 5
on behalf of the Plaintiff; Examination (Continued)
6 6 By Ms. Schwartz 150
7 Ms. Kimberlly M. Foxx, State's Attorney of 7 Examination
Cook County Illinois, by: By Ms. Nifro 304
8 Ms. Bianca Brown 8
Assistant State's Attorney Examination
9 Richard J. Daley Center 9 By Mr. Wunder 305
50 West Washington
10 Room 500 10 Examination
Chicago, Illinois 60601 By Ms. Brown 310
11 312.603.1902 11
bianca.brown@cookcountyil.gov
12 on behalf of all Cook County Defendants; 12
13 13 EXHIBITS
Mr. Christopher S. Wunder
14 Kaplan Papadakis & Gournis, P.C. 14 MARKED FOR
180 North LaSalle Street IDENTIFICATION
15 Suite 2108 15
Chicago, Illinois 60601
16 312.726.0531 16 No. 1 90
cwunder@kpglaw.com No. 2 97
17 on behalf of Defendant William Martin 17 No. 3 107
and the Village of Schiller Park; No. 4 125
18 18 No. 5 130
No. 6 134
19 19 No. 7 154
No. 8 159
20 20 No. 9 164
No. 10 172
21 21 No. 11 184
No. 12 189
22 22 No. 13 195
No. 14 198
23 23 No. 15 200
No. 16 211
24 24 No. 17 217
No. 18 222
2 4
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Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
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2018
1 EXHIBITS 1 By Ms. Schwartz:
2 MARKED FOR 2 Q Ms. Spizzirri, have you ever been
IDENTIFICATION
3 3 deposed before?
4 No. 19 224 4 A No, I haven't.
No. 20 235
5 No. 21 242 5 Q Since this is your first deposition, we
No. 22 254
6 No. 23 260 6 will just go over some general ground rules for
No. 24 264
7 No. 25 270 7 today's deposition.
No. 26 274
8 No. 27 276 8 First, as you can tell we have a court
No. 28 279
9 No. 29 288 9 reporter here today. So for her sake, I'd ask that
No. 30 290
10 No. 31 296 10 we try to not talk over each other. I will try to
No. 32 299
11 No. 33 300 11 let you finish your answers, if you try to let me
12 12 finish my questions; is that fair?
13 13 A (Shaking head.) Uh-huh.
14 14 Q Yes?
15 15 MR. NINFO: Yes.
16 16 THE WITNESS: Yes.
17 17 MR. NINFO: You didn't get to that one yet.
18 18 By Ms. Schwartz:
19 19 Q My next one is please do give verbal
20 20 answers.
21 21 A Yes.
22 22 Q Yes, no, uh-uh's, and head nods don't
23 23 translate on to the transcript.
24 24 A Thank you.
5 7

1 (Witness duly sworn.) 1 Q Is that fair?


2 CAROL SPIZZIRRI, 2 A Yes.
3 called as a witness herein, having been first duly 3 Q If I ask a question and you don't
4 sworn, was examined and testified as follows: 4 understand it, will you let me know?
5 EXAMINATION 5 A I will.
6 By Ms. Schwartz: 6 Q And if you answer one of my questions, I
7 Q Good morning, would you please state 7 will assume you understood the question. Is that
8 your name for the record. 8 okay with you?
9 A Carol Spizzirri. S like Sam, P like 9 A Yes.
10 Peter, I, two Zs like Zebra, I, two R's like 10 Q If you need a break at any time today,
11 Robert, I. 11 do let me know. The only thing I ask is if there
12 Q Before we get started I would ask 12 is a question pending that you finish answer the
13 everyone to introduce themselves. 13 question, then request a break. Is that fair?
14 My name is Julia Schwartz, I represent 14 A Yes.
15 the plaintiff, Annabel Melongo. Ms. Melongo is 15 Q I also will be taking breaks throughout
16 also on the phone line and will be listening in 16 the day as needed, but again, do feel free to ask
17 today by phone. 17 for a break at any time?
18 MR. NINFO: Dina Ninfo, for Carol Spizzirri. 18 A Thank you.
19 MR. WUNDER: Chris Wunder for Detective Martin 19 Q Is there any reason that you cannot give
20 and Village of Schiller Park. 20 truthful and accurate testimony today?
21 MS. BROWN: Bianca Brown for all Cook County 21 A No.
22 Defendants. 22 Q Have you taken any alcohol, drugs, or
23 MS. CALLOWAY: Shirley Calloway, for Kyle 23 other substances in the last 24 hours that would
24 French. 24 affect your ability to give truthful and accurate
6 8
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Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
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1 testimony here today? 1 A Okay.
2 A No. 2 Q -- with you a bit.
3 Q Are you represented by counsel today? 3 A If you mind going one by one.
4 A Yes. 4 Q What were the subject matters of those
5 Q Is that Ms. Ninfo? 5 cases?
6 A Yes. 6 A Two divorces.
7 Q Did you meet with your counsel prior to 7 Q What was the third?
8 coming in for your deposition today? 8 A The other one was a lawsuit against
9 A Yes. 9 ABC-7, Chuck Goudie, and, Peter Heimlich, Robert
10 Q Did you review any documents prior to 10 Brack -- Brack -- I can't think of his last name.
11 your deposition today? 11 Q Somebody named Robert?
12 A Yes. 12 A Yes.
13 Q What documents did you review? 13 Q Anyone else?
14 A Emails primarily. Letters from my 14 A A doctor. I can't remember his last
15 business. I think that's about all. 15 name. There were three of them, total four.
16 Q What sorts of emails did you review 16 Q Were you the plaintiff in that
17 before your deposition? 17 lawsuit?
18 A Correspondence that I had sent to 18 A Yes. The company was --
19 various different people to during my business, and 19 Q The company Save a Life Foundation?
20 also letters that I had sent through the business. 20 A Yes.
21 Q When you refer to your business, are you 21 Q Not you personally?
22 referring to the Save A Life Foundation? 22 A No.
23 A Yes. 23 Q Where was that lawsuit filed, which
24 Q I'll today, during the deposition, refer 24 Court?
9 11

1 to the Save a Life Foundation and also SALF. 1 A It was in Federal, first it was in
2 A Yes. 2 Circuit Court and then it went into Federal Court.
3 Q Is that okay with you? 3 Q Circuit Court of Cook County,
4 A That's fine. 4 Illinois?
5 Q About how many hours would you guess you 5 A Yes.
6 spent preparing for today's deposition? 6 Q Federal Court, the Northern District of
7 A About four. 7 Illinois?
8 Q That includes your time spent with your 8 A Yes.
9 attorney? 9 Q Can you describe the subject matter of
10 A That was all conclusive. 10 that lawsuit against ABC News, Chuck Goudie, and
11 Q Have you ever been a party to any other 11 the others you mentioned?
12 lawsuit apart from this litigation? 12 A That particular case was settled out of
13 A Yes. 13 court.
14 Q How many lawsuits? 14 MR. NINFO: No --
15 A Probably about three. 15 THE WITNESS: I'm not sure if it's under any
16 Q Does the three include the civil 16 confidentiality so --
17 litigation -- 17 MR. NINFO: I'm just going to interject and
18 A No. 18 put it on the record. Counsel, we talked before.
19 Q -- or three apart from -- 19 That we are unsure whether there is confidentiality
20 A Apart from. 20 to that. We will follow up and find that out. And
21 Q So four in total? 21 we can follow up with you in additional discovery
22 A Yes. 22 or what have you to get whatever information you
23 Q I would like to discuss those other 23 need. But you know, I need to instruct my client
24 three cases -- 24 not to answer any questions that may potentially
10 12
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Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
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1 violate a confidentiality agreement that may 1 A No. It was finalized. We settled out
2 exist. 2 of court.
3 By Ms. Schwartz: 3 Q When was it finalized? What year?
4 Q Ms. Spizzirri, is your understanding 4 A 2009, I believe. I cannot be certain on
5 that your attorney is instructing you not to answer 5 that.
6 in terms of specific details of how the case was 6 Q In terms of the other two cases you
7 disposed? 7 mentioned, those were two divorce cases?
8 A That's my understanding. 8 A Yes.
9 Q That's the reason -- 9 Q Where were those cases?
10 A Yes. 10 A One was in Kenosha County and one was in
11 Q -- you're not providing additional 11 Milwaukee.
12 information -- 12 Q Okay. And those were divorces for two
13 A Yes. 13 separate individuals?
14 Q -- about the disposition of this case 14 A Yes.
15 against ABC News, Chuck Goudie, and others? 15 Q Apart from the two divorce cases you
16 A Yeah. 16 mentioned, the litigation against ABC News and
17 Q And, the basis, just so I have it clear 17 Chuck Goudie and others, and this litigation, have
18 for the record is that there is a potential, 18 you been involved in any other civil lawsuits?
19 Ms. Ninfo, correct me if I am wrong on this. 19 A Not that I can remember.
20 The basis for this instruction is that 20 Q Ms. Spizzirri, I would like to go over a
21 there's maybe a confidentiality agreement out there 21 bit about your background and education. Let's
22 and you need to confirm the substance of that 22 start with your education.
23 agreement before permitting Ms. Spizzirri to -- 23 Did you graduate from high school?
24 instructing Ms. Spizzirri to answer further? 24 A Yes, I did.
13 15

1 MR. NINFO: Correct, and if there is not, then 1 Q What did you do in terms of education
2 we will supplement discovery and work with you to 2 after graduating from high school?
3 get whatever information you need relevant to 3 A Before I graduated from high school I
4 that. 4 completed a course in -- at MIT. At that time it
5 MS. SCHWARTZ: Okay. We would reserve our 5 was called MIT, which was Milwaukee Institute of
6 rights to ask follow up questions -- 6 Technology. Then I went, and later went for a
7 MR. NINFO: Sure. 7 nursing degree at Waukesha, which was a CNN, which
8 MS. SCHWARTZ: -- as necessary and 8 is a certified nursing assistant -- CNA, sorry. And
9 correspond -- I will be in correspondence with 9 then a Medical Assistant at Mount Senario College
10 Ms. Ninfo. 10 in Milwaukee.
11 MR. NINFO: Sure. 11 Q Let's go through those one by one.
12 MS. SCHWARTZ: -- at a later date. 12 So you said you were at MIT, Milwaukee
13 By Ms. Schwartz: 13 Institute of Technology --
14 Q I just want to ask a few more questions 14 A Uh-huh.
15 about that litigation. 15 Q -- before graduating high school?
16 A If I can answer. 16 A Uh-huh. I was the first in the
17 Q If you can't answer because Ms. Ninfo 17 country.
18 has instructed you not to answer for the same 18 Q What was the type of courses you were
19 reason, do let me know. 19 taking?
20 That case against Chuck Goudie, ABC 20 A It was keypunching. They had just come
21 News, and the others has it been -- is it still 21 out with keypunching.
22 ongoing or has it been -- 22 Q And then after graduating from high
23 A No. 23 school, did you immediately enroll in --
24 Q -- finalized? 24 A No.
14 16
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
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2018
1 Q -- nursing school? 1 1984. I think I got remarried in 1984. Somewhere
2 A No. 2 in the early 80's. I can't remember.
3 Q What did you do in between? 3 Q Did you get a degree from Waukesha?
4 A I worked at a bank. At Milwaukee 4 A I did.
5 Western Bank and then I worked at Home Bank in 5 Q What was that degree?
6 Milwaukee. I completed a course within the 6 A It was a certification. CNA
7 banking, a banking course, but that was within the 7 certification.
8 banking. 8 Q So you got a certification --
9 THE COURT REPORTER: Keep your voice up, 9 A Uh-huh.
10 please. 10 Q -- as a certified nursing assistant?
11 THE WITNESS: Oh, I'm sorry. Sorry. 11 A Yes. Yes.
12 MS. SCHWARTZ: If the other attorneys can't 12 Q What year was that roughly?
13 hear at any time, please do let me know. 13 A That was within that same ballpark of
14 By Ms. Schwartz: 14 the early Eighties.
15 Q Those two banks, Milwaukee Western Bank 15 Q Now, after that you testified you
16 and Home Bank, about what years would you say you 16 attended Mount Senario College?
17 worked at those two banks? 17 A Yes.
18 A '65 to '67. I think that's it. 18 Q What years?
19 Q When did you enroll in the program you 19 A That would have been the early Eighties
20 referenced related to the certified nursing 20 also.
21 assistant degree at Waukesha? 21 Q Did you attain any degree from
22 A '86, I believe. 1986. 22 Mount Senario College?
23 Q What did you do between 1967 and 23 A Same. It was a certified degree.
24 nineteen -- 24 Q What was the certified degree in?
17 19

1 A I was a mother and a wife. 1 A Medical assistant.


2 Q -- eight six? 2 Q So you became a Certified Medical
3 MR. NINFO: Let her finish her question for 3 Assistant after pursuing courses at Mount Senario
4 the record. 4 College in Wisconsin?
5 THE WITNESS: Okay. 5 A Yes.
6 MS. NINFO: And then answer. 6 Q You testified that was some time in the
7 By Ms. Schwartz: 7 early Eighties?
8 Q I'm sorry, what did you do between 1967 8 A Yeah.
9 and 1986? 9 Q Apart from MIT, Waukesha, and
10 A I was a mother and a wife. And I 10 Mount Senario, have you taken courses at any other
11 managed my father's income property business. My 11 institutions or received any other education or
12 father had been taken ill. So I was the only one 12 training?
13 who could take over. 13 A I don't believe I have.
14 Q Let's discuss the education you received 14 Q I would like to discuss then your
15 in Waukesha starting in 1986 you testified? 15 work history. Let's start with today. Are you
16 A I believe. 16 currently employed?
17 Q Did you get a degree at Waukesha? 17 A No, I'm retired.
18 A I did, but I am not sure on the date. I 18 Q How long have you been retired?
19 really apologize. I can't remember the date. 19 A 2010.
20 Q Was it in or around 1986 somewhere in 20 Q Since 2010 you haven't had any full time
21 that ballpark? 21 employment?
22 A I am trying to think back. It would 22 A No.
23 have had to have been 1980. It would -- I'm sorry, 23 Q Prior to your retirement in 2010, what
24 it must have been 1980. Because I remarried in 24 was your job?
18 20
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
- MAY 11,Page 7 of 93 PageID #:1995
2018
1 A I formed in 2000, I'm sorry. 1992 later 1 A Yes.
2 part of 1992 Save a Life Foundation. 2 Q Then from 1992 until when you left Safe
3 Q What was your role within Save a Life 3 a Life Foundation, did you have any other full-time
4 Foundation? 4 employment?
5 A I was the President/Founder. It was 5 A No.
6 after the death of my daughter. 6 Q Safe a Life was it?
7 Q Did you work at Save a Life Foundation 7 A You bet.
8 from 1992 when you founded it through 2010 when you 8 Q That was your full time job?
9 retired? 9 A That was my life.
10 A When you say work, I didn't collect a 10 Q During that period 1992 to 2010, were
11 paycheck. And I worked at a School District. 11 you always the President of Safe a Life
12 District 50 in Lake County, Illinois. 12 Foundation?
13 Q What years did you work at a School 13 A Yes.
14 District in Lake County, Illinois? 14 Q That was always your title?
15 A Late Eighties. 15 A Yes.
16 Q What was your job working in the school 16 Q Let's discuss in a bit more detail Save
17 District in Lake County? 17 a Life Foundation. What was Save a Life
18 A I was a clerk. 18 Foundation's mission?
19 Q And that was full time? 19 A To train the public and professionals in
20 A Yes. 20 life-saving skills so they could save a life in the
21 Q After working at the School District in 21 time of emergency.
22 Lake County, what was your next full time 22 Q When you left Safe A Life Foundation in
23 employment after that? 23 2010 was Safe A Life Foundation still operational
24 A That was Save a Life Foundation. I 24 or did Save a Life Foundation close at that time?
21 23

1 would work and I saved my money. I put everything 1 A It closed.


2 into starting the organization by passing 2 Q Why did Save a Life Foundation cease to
3 legislation that all police officers and 3 exist?
4 firefighters are trained in CPR and first aid 4 A We had been stalked by several
5 before they left their academy. It was a mandate 5 individuals. That's why the lawsuit started.
6 and it went to Washington. I got Federal funding 6 They went after our stockholders to disregard us,
7 to pay for that. 7 and they harassed these people so they wouldn't
8 Q I would like to discuss Save a Life 8 stay involved with us, and our funding started
9 Foundation in more detail in a moment. I just want 9 drying up.
10 to make sure that I have the time line down. 10 Q When you refer to the lawsuit, are you
11 A Right. 11 referring to the litigation against ABC News, Chuck
12 Q And understand your general employment 12 Goudie, Peter Heimlich, and others?
13 history. 13 A Yes.
14 You worked at the Lake County School 14 Q And when you say, they harassed us, who
15 District from the late 80s -- 15 is the "they" you are referring to? I just want to
16 A Uh-huh. 16 make sure I understand.
17 Q -- through to 1992 when you founded Safe 17 A Peter Heimlich, and Dr. Baratz. That's
18 a Life Foundation? 18 the name. And Robert something.
19 A Yes. 19 Q Was there anyone else who was
20 Q Did you have any other employment during 20 encompassed in that "they" of people you say
21 that time period? 21 harassed you and others that led to the closing of
22 A Not that I can remember. 22 Safe a Life?
23 Q Then in 1992 that's when you founded 23 A It was, you know, Chuck Goudie. He
24 Safe a Life? 24 tried to have others pick up on his story, and
22 24
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
- MAY 11,Page 8 of 93 PageID #:1996
2018
1 that's why we sued. 1 A I was advised by the State's Attorney.
2 Q So in or around 2010, did Save a Life 2 Q Who was the State's Attorney
3 dissolve -- 3 specifically?
4 A Yes. 4 A Bob P-o-h-e -- I can't pronounce his
5 Q -- formally? 5 last name.
6 A Yes. 6 Q Is it Bob Podlasek?
7 Q That was a result of funding having 7 A That's it.
8 dried up? 8 Q What did Mr. Podlasek say to you about
9 A Yes. 9 moving?
10 Q And your testimony is that funding dried 10 A He said that the only way that I could
11 up as a result of the actions of some of these 11 be safe is to move out of town.
12 individuals -- 12 Q And you mentioned that your home was
13 A Yes. 13 broken into, did you say?
14 Q -- Peter Heimlich, Dr. Baratz, Chuck 14 A Yes.
15 Goudie? 15 Q What was the situation with your home
16 A Yes. 16 being broken into?
17 Q Was there any other reason Save a Life 17 A My door was literally broken in half and
18 Foundation dissolved in 2010? 18 there had been somebody in my basement for some
19 A We were in good standing other than the 19 time before the door was broken down. Things were
20 funding. We just couldn't pay our bills anymore. 20 stolen from my home. My computer was tampered,
21 Q Ms. Spizzirri, you currently live in 21 cleaned out. Files, business files, personal files
22 California; is that right? 22 were stolen.
23 A Yes. Yes. 23 Q Did you ever determine who may have been
24 Q When did you move to California? 24 responsible for that break -- the braking into your
25 27

1 A 2010. 1 home?
2 Q Have you been in California since 2 A I could not say who actually did. I
3 2010? 3 assumed I knew, but I can't say because I have no
4 A Yes. 4 proof.
5 Q Prior to living in California, did you 5 My Blackberry had been tampered with.
6 live in Illinois? 6 They were able, whoever, was able to get all of my
7 A Yes. 7 emails off of my Blackberry and my GPS was engaged.
8 Q Where in Illinois? What county? 8 Q When you say your GPS was engaged --
9 A Lake County. 9 A On the phone.
10 Q What years did you live in Lake 10 Q -- what do you mean?
11 County? 11 A On the phone.
12 A 2000 -- I'm sorry. 1986 moved from 12 Q When you say "engaged," meaning it was
13 Illinois -- from Wisconsin to Illinois. 13 turned on?
14 Q From 1986 to 2010 -- 14 A Yeah.
15 A Yes. 15 Q Meaning it --
16 Q -- you lived in Lake County? 16 A Could be followed by someone from
17 A Yes. Yes. 17 outside. They never were able to find out who.
18 Q Why did you move to California? 18 Q Who is the "they"?
19 A I was advised to move out of Illinois 19 A Whoever was getting my black mails.
20 due to a lot of harassment, and my home had been 20 They were going to a third party.
21 broken into. I had been stalked and followed. 21 Q When you say, they were never able to
22 There is a word for followed, but I can't remember 22 figure out who," is it the police department or
23 the word. 23 who --
24 Q Who advised you to move from Illinois? 24 A Oh, actually who makes Blackberry? They
26 28
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI 07/16/18
- MAY 11,Page 9 of 93 PageID #:1997
2018
1 are here in -- it starts with a R. 1 Are you talking ever?
2 Q Is it Research In Motion? 2 By Ms. Schwartz:
3 A They have R O. I think it has -- 3 Q Since this lawsuit was initiated, first
4 whoever makes Blackberry here. They were 4 filed, have you spoken to anyone about the
5 contacted. And I corresponded with the State's 5 substance of the lawsuit?
6 Attorney, Julia and Bob as to them investigating, 6 A Well, yes. I had to explain it to my
7 researching. And they concluded they didn't know 7 Board, and to -- they were all aware of -- not this
8 who, but they concluded that my Blackberry had been 8 lawsuit. I'm sorry.
9 tampered with. 9 Q This lawsuit. This civil litigation --
10 Q Research in Motion concluded that your 10 A Oh.
11 Blackberry had been tampered with? 11 Q -- filed by Ms. Melongo? Let me --
12 A I got an email from them. 12 A I'm so sorry.
13 Q You worked with Julie Gunnigle and Bob 13 Q -- restate the question.
14 Podlasek? 14 Have you spoken or communicated with
15 A Yes. Not really worked with them. Not 15 anybody apart from your attorney about this
16 so much with Bob, but more with Julie. She was 16 litigation filed by Ms. Melongo?
17 aware of what was going on. I did all of the 17 A I have. I have a roommate. And he is
18 research. 18 well aware of the situation that I have been going
19 Q But no one was ever able to determine 19 through. I have had people -- Peter Heimlich has
20 who -- 20 contacted the Mayor of San Marcos to voice his
21 A No. 21 opinion about me. So I had to explain to the
22 Q -- might have interfered with the 22 officials there. I had to explain to a Board that
23 Blackberry? 23 I belong to, a volunteer Board, because they also
24 A No. 24 had been notified.
29 31

1 Q Did you believe Ms. Melongo had anything 1 Q What organization is this?
2 to do with the Blackberry? 2 A It's the San Marcos Mobilehome Residents
3 A I had no clue who did it. 3 Association. And like I said, my daughter has
4 Q Similarly with your testimony with 4 also -- is well aware.
5 breaking into your account. You testified that it 5 Q Have you spoken to anyone else about
6 was the individuals -- it may have been the 6 this litigation filed by Ms. Melongo since the
7 individuals who had been harassing you. You 7 complaint was filed?
8 thought they may have been involved; is that true? 8 A Rita Mullins.
9 A It is very possible. My ex-husband was 9 Q What did you discuss with Ms. Mullins
10 a good friend of Peter Heimlich. 10 about the case?
11 Q Did you believe Ms. Melongo had anything 11 A She was on our Board. So she has gone
12 to do with the breaking into your home? 12 through the whole synopsis of this. So she -- just
13 A I don't think so. I don't. 13 told her what was the charges that were brought.
14 Q But similarly, as with the Blackberry, 14 And she's aware that I am here today.
15 with the breaking into your home, it was never 15 Q When you saw "our Board," do you mean
16 determined -- 16 Save a Life Foundation?
17 A No. 17 A Yes.
18 Q -- who was responsible? 18 Q Did you tell Ms. Mullins you were coming
19 A No. 19 in today for your deposition?
20 Q Have you spoken or communicated with 20 A Yes, because I'm staying with them.
21 anyone about this lawsuit apart from your 21 Q You're staying at Ms. Mullins' home?
22 attorney? 22 A Yeah. Well, driving back and forth from
23 A My daughter. 23 the hotel, I'm with her. And also, a friend
24 MR. NINFO: Can you put a time frame on that? 24 Laketek. These are two close friends of mine who
30 32
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Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 10 of 93 PageID #:1998
2018
1 picked me up at the airport. 1 this case, the other defendants in this case.
2 Q Did you discuss the substance of your 2 Do you know who -- you mentioned his
3 deposition testimony here today -- 3 name earlier. Do you know who Robert Podlasek
4 A No. 4 is?
5 Q -- with Ms. Mullins? 5 A Yes.
6 A No. 6 Q How do you know Mr. Podlasek?
7 Q Did you discuss the substance of your 7 A He is the prosecutor that was introduced
8 testimony here today with anyone else apart from 8 to me back in 2007.
9 your lawyer? 9 Q 2007.
10 A No. 10 A I think.
11 Q Apart from the individuals you just 11 Q He worked on the criminal cases against
12 mentioned, have you spoken or communicated to 12 Ms. Melongo?
13 anybody else about this litigation filed by 13 A Yes.
14 Ms. Melongo? 14 Q Is that the context in which you met
15 A I believe I mentioned to Detective -- 15 him?
16 no, I wasn't -- I may have -- I am not sure. I 16 A Yes.
17 am sorry. I can't assume. 17 Q Had you met him before?
18 Q Do you know someone named Michelle 18 A No.
19 Munya? 19 Q Have you ever socialized or interacted
20 A Yes. Yes. 20 with Mr. Podlasek outside of a work setting,
21 Q Who is Michelle Munya? 21 outside of anything related to the case with
22 A She is a dear friend of mine from 1980, 22 Ms. Melongo?
23 early 1980s. When I moved down to Illinois I 23 A We had once met outside on a different
24 became friends with her. 24 matter.
33 35

1 Q Have you spoken with Michelle Munya 1 Q What was the different matter?
2 about this litigation? 2 A At the time I was doing a lot of -- I
3 A No. Not to my knowledge. 3 was still working on another piece of legislation.
4 Q Did you write a Facebook message to 4 And I had been in communication with the
5 Ms. Munya on July 29th, 2017, that said, I'll be 5 legislators. And we started talking about the
6 back. Trust me. The bimbo still cooking. Hoping 6 cyber crime that was just starting up. And most by
7 for 20m from IL. Just what IL needs, more debit. 7 now had heard through various sources that there
8 Did you write a Facebook message to her 8 was problems. It is a small network of people.
9 that said that? 9 They talk amongst themselves.
10 A I don't think so. I don't know. I 10 So we started to put together an
11 don't remember. 11 Illinois cyber crime task force meeting of the
12 Q Were you referring -- you refer to 12 minds to see how cyber crime could be dealt with.
13 someone as a bimbo. Was that Ms. Melongo? 13 And at that time is when I discussed
14 A No. I don't even remember doing that. 14 to Bob -- excuse me, I just can't pronounce his
15 Q You don't remember that Facebook 15 last name, never could -- about it, and he was
16 message? 16 interested in it because our case was the actual
17 A No. 17 first case in Illinois that nobody knew what was
18 MS. SCHWARTZ: We would ask that any Facebook 18 going on, but there was a lot of things starting.
19 or social media messages that are responsible or 19 The Sheriff's Department was having a lot of
20 relate to Ms. Melongo in this case in any way be 20 problems. And so were the constituents contacting
21 produced. 21 legislatures too.
22 By Ms. Schwartz: 22 So we pulled together a committee and
23 Q I want to ask you a few questions about 23 out of that committee came a white paper. Nothing
24 any contacts you have had with the other parties in 24 transpired after that. That was separate from Save
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1 a Life completely. 1 actually invited various people that he knew to
2 Q When you say our case was the first in 2 come to this meeting and we met at the State
3 Illinois, are you referring to the criminal 3 building for a couple of hours to discuss each
4 computer tampering case against Ms. Melongo? 4 problem, each person's problem. FCC was there.
5 A Yes. Yes. 5 Federal Communications, the Sheriff's Department,
6 Q It was the first of what kind of case in 6 Cook County, several legislatures, Ms. Mullins.
7 Illinois? 7 She was a mayor at the time. So she was bringing
8 A Any kind of computer type of incident. 8 in her examples from the municipal government.
9 That is what I was told. 9 And Fran Laketek was in business for herself and
10 Q When did you meet with Mr. Podlasek 10 she had problems too. So she brought her concepts
11 about legislation and the cyber crime initiative 11 in. So we all had a network of discussion.
12 you just referenced? 12 Q And Mr. Podlasek was at that meeting at
13 A The legislation was separate. The 13 the State building as well?
14 legislation I was doing was transferring medic 14 A Yes.
15 credentials into civilian life. Passed by the way 15 Q Was that in July of 2009 that meeting?
16 nationally. 16 A I can't remember. I believe it was.
17 And so I was down at the State Capital 17 Q So part -- you testified about two
18 trying to get this legislation passed and in my 18 meetings at which Mr. Podlasek was there. A
19 conversation with the people that I was dealing 19 meeting at a coffee shop --
20 with to get that legislation passed, we started 20 A The one-to-one meeting --
21 talking about cyber and how they were getting, 21 Q -- and a meeting at the State building?
22 these legislatures were getting phone calls from 22 A -- was with -- at the coffee shop.
23 their constituents saying they were having 23 The conglomerate, the invitation went
24 problems. And that's how that all started. 24 out by Senator Dillon.
37 39

1 And then in the hallway there was a 1 Q That's to the meeting at the State
2 reporter, who knew me from my other legislation, 2 building?
3 Terry Martin, and he interviewed me. There was a 3 A Yes, I didn't invite.
4 State Senator behind me at the time who was also 4 MR. NINFO: Just be careful. Let her finish
5 in the same situation with her constituents. So 5 and then answer.
6 he interviewed me as to this type of issues that 6 MS. SCHWARTZ: Thank you.
7 were getting larger and larger and people didn't 7 By Ms. Schwartz:
8 know how to handle them. 8 Q Apart from those two meetings, the
9 Q And in terms of that legislation, the 9 coffee shop and the meeting with the other
10 medical legislation, was Robert Podlasek involved 10 individuals at the State building, did you ever
11 in any of that? 11 meet with Mr. Podlasek outside of the context of
12 A No. 12 Ms. Melongo's criminal case?
13 Q So in terms of your meeting related to 13 A No.
14 the cyber crime issues -- 14 Q You testified that there was a white
15 A Right. 15 paper completed related to your cyber crime project
16 Q -- that's when you met with -- 16 and that was it. What ended up happening with your
17 A That's right. 17 cyber crime project?
18 Q When did you meet with Bob Podlasek 18 A Nothing came out of it. The white paper
19 about the cyber crimes? 19 was released to the people that attended the
20 A We met after work because he lived 20 meeting.
21 near Barrington and that was in the outskirts. 21 Q What is a white paper?
22 And I lived in the outskirts and so we met for 22 A It was a concept paper. What can we do
23 coffee to discuss how we could possibly put this 23 to protect citizens because at the time, you
24 together and then Senator Dillon, I think. He 24 couldn't cross the line. If you had something
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1 happen in Cook County, you couldn't go to DuPage 1 A No.
2 County. If it happened in DuPage County and an 2 Q Never met for drinks?
3 affected person in Cook County couldn't cross that 3 A No.
4 line. So that is why the municipal government 4 Q Have you spoken to Ms. Gunnigle about
5 was -- needed their thoughts in how they could 5 this lawsuit?
6 break down that line. 6 A No.
7 Q After the white paper, the concept 7 Q Have you ever emailed or text messaged
8 paper, was completed, did anything else become of 8 or called Ms. Gunnigle about this lawsuit?
9 your cyber crime initiative? 9 A No.
10 A I don't know if any of the people that 10 Q Again, when I say this lawsuit, I am
11 attended this meeting used that for their own. I 11 referring to the litigation filed by Ms. Melongo?
12 have no clue because I was more concerned of my own 12 A To my recollection I have not because
13 safety at the time and I had to leave. 13 she moved out of state.
14 Q So to your knowledge and based on your 14 Q Since Ms. Gunnigle moved out of state,
15 participation nothing else -- 15 have you had any communication with her?
16 A My participation had to be removed. 16 A I have not spoken with her.
17 Q Have you spoken to Mr. Podlasek about 17 Q Do you know Detective William Martin?
18 this lawsuit? 18 A I do.
19 A I cannot say. I do not remember. 19 Q How do you know Detective Martin?
20 Q When is the last time you spoke to 20 A He was -- he came to our office when my
21 Mr. Podlasek either in person, an email, phone? 21 Associate Vince Davis and a group of forensic
22 A Personally would have been at the time 22 computer companies that we had hired to find out
23 of trial, but not this lawsuit at the time of 23 what had happened to our computers. And they found
24 the -- that I saw him. 24 that it seemed to have come from the outside. And
41 43

1 Q July 2014, the criminal trial against 1 so they suggested that the police be summoned, and
2 Ms. Melongo? 2 Vince Davis contacted the Schiller Park Police.
3 A That's the date. I don't know the date. 3 Another gentleman, officer came over and then
4 Q The computer tampering trial? 4 maybe -- to take a statement.
5 A Okay. Yeah. 5 And then it would have been some time
6 Q You testified about her earlier as well. 6 after that that Detective Martin came over to the
7 Do you know Julie Gunnigle? 7 office and introduced himself. Because he headed
8 A Yes, I do. 8 at that time their first cyber unit.
9 Q How do you know Julie Gunnigle? 9 Q The issue you're referring to is an
10 A She was brought in 2008 for the computer 10 alleged intrusion on Save a Life Foundation's
11 tampering. That was the first time I met her. I 11 servers --
12 was called into their office to discuss what had 12 A Yes.
13 happened. 13 Q -- in late April 2006?
14 Q About how many times did you meet with 14 A Yes.
15 Julie Gunnigle in person? 15 Q That's when you testified Vince Davis
16 A I believe twice. 16 called the Schiller Park police?
17 Q Did you correspond with Julie Gunnigle 17 A Yes.
18 on the phone and over email? 18 Q And you testified that that was at the
19 A I did. 19 advice of an outside vendor?
20 Q Did you ever interact with Ms. Gunnigle 20 A Yes. Two outside vendors came in. I
21 outside of the setting of Ms. Melongo's criminal 21 can't remember their name, but anyhow two outside
22 case? 22 vendors came in and they found that it had been
23 A No. 23 hacked. I guess that's what it was called. They
24 Q Never met for coffee? 24 suggested that the police be brought in.
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1 Q Both of the outside vendors suggested? 1 Q Did you reach out to Detective Martin or
2 A Yes. Yes. 2 did he reach out to you?
3 Q And shortly after the first contact with 3 A I reached out to Detective Martin.
4 the Schiller Park police by Vince Davis, that's 4 Q Did you contact him by phone or?
5 when you met Detective Martin? 5 A By phone.
6 A When he came to the office, yes. 6 Q Why did you contact Detective Martin by
7 Q About how many times would you say you 7 phone in 2016?
8 met Detective Martin in person? 8 A Because discovered that one of my former
9 A He had come over several times to the 9 temp employees who had known Ms. Melongo also was
10 office to work with the outside contractors, learn 10 Judge Lee's law clerk.
11 from the -- what they had discovered. So he had 11 Q Is that Julia Rickert?
12 been there several times. Then we had -- my front 12 A Yes.
13 desk had -- when we would make airplane, register 13 Q Why did you reach out to
14 airplane tickets, the front desk was the one who 14 Detective Martin upon discovering that one of your
15 would take the charge card and schedule the flight. 15 former temp employees was Judge Lee's law clerk?
16 Well, our accountant had received phone 16 A Because the name would have come up
17 calls from American Express saying that our card 17 during ABC's report, which he was well aware of at
18 had been used without our consent. So he had come 18 that time because it was after the fact of the
19 over to find out how that happened. And he worked 19 tampering, but it was still public. I was kind of
20 with our front desk lady, and I can't think of her 20 looking for; is this right. I mean, I didn't know
21 name, to try and find out how this happened that 21 what the legality was of having a former employee
22 our charge card had been tampered with several 22 be the law clerk for the judge that's hearing this
23 times. 23 case.
24 But I had to do my own. I knew he was 24 Q You wanted to ask Detective Martin his
45 47

1 there. But I did my own work while he was in the 1 advice on whether that was an issue?
2 office. 2 A He suggested I contact my attorney and I
3 Q When Detective Martin came to the office 3 did.
4 to discuss the credit card issues? 4 Q Did he say anything else when you spoke
5 A Yes. He worked more with my other 5 to Detective Martin on the phone?
6 employees than he worked with me. I just knew he 6 A No.
7 was there for that purpose. 7 Q Do you recall anything else about that
8 Q If you had to put a number on the number 8 conversation with Detective Martin --
9 of times you met Detective Martin in person, what 9 A There was --
10 would you guess that number to be? 10 Q -- in 2016?
11 A Ten. 11 A There was no more.
12 Q Did you exchange phone calls and emails 12 MR. NINFO: Let her finish her question.
13 with Detective Martin? 13 THE WITNESS: I'm sorry.
14 A Yes. 14 By Ms. Schwartz:
15 Q Have you ever met with Detective Martin 15 Q If you don't mind, letting me finish my
16 outside of the setting related to the Safe a Life 16 question. I would appreciate it.
17 computer tampering or credit card issues or 17 MR. NINFO: Take a break before you answer.
18 Ms. Melongo's case? 18 MS. SCHWARTZ: Always a good tip.
19 A No. 19 By Ms. Schwartz:
20 Q Have you ever spoken to Detective Martin 20 Q Apart from the one phone call, have
21 about this lawsuit filed by Ms. Melongo? 21 you ever contacted Detective Martin about this
22 A Once. 22 litigation either in person, phone call, or text or
23 Q When was that? 23 email?
24 A 2016. 24 A I don't know. I'm sorry, I don't
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1 remember. 1 the computer tampering.
2 Q You don't recall any other contact? 2 Q You know --
3 A I don't. 3 A His name was brought into that during
4 Q Do you know Kate Garcia, formally Kate 4 that time that he had been the forensic examiner.
5 O'Hara? 5 Q So you saw Kyle French's name in the
6 A No. 6 context of the investigation --
7 Q Never met Kate O'Hara? 7 A Yes.
8 A No. 8 Q -- related to this?
9 Q Do you know James Dillon? 9 MR. NINFO: Let her finish. Just take a
10 A No. 10 breath. Just take a minute. Count to three before
11 Q Never met James Dillon? 11 you answer.
12 A No. 12 By Ms. Schwartz:
13 Q Never spoken to James Dillon? 13 Q You saw Kyle French's name in the
14 A No. 14 context of paperwork related to the investigation
15 Q Do you know Antonio Rubino? 15 into the Save a Life computer tampering issues; is
16 A No. 16 that correct?
17 Q Never spoken to Antonio Rubino? 17 A That's correct.
18 A No. 18 Q But you never actually met him?
19 Q Do you know Richard Lesiak. 19 A No.
20 A No. 20 Q Do you know Mathew Markos,
21 Q Never spoken to Richard Lesiak? 21 Dr. Mathew Markos?
22 A Doesn't sound familiar at all. 22 A No.
23 Q Just so you know, I'm naming other 23 Q Never spoken to Dr. Mathew Markos?
24 defendants in this litigation. 24 A No.
49 51

1 A Yes, I understand. Yes. 1 Q Do you know who Annabel Melongo is?


2 Q Do you know Randy Roberts? Formally 2 A Yes.
3 Executive Assistant Attorney Randy Roberts? 3 Q When did you first meet Ms. Melongo?
4 A No. No. Thank you for saying that. 4 A She worked for Robert Half and my
5 Because I saw that name, but I don't know where it 5 assistant contacted Robert Half. We needed to have
6 came from. 6 an IT administrator prior to my -- my IT had died
7 Q Have you ever met with Randy Roberts? 7 of a heart attack, and we needed someone to come in
8 A No. 8 and temporarily take that role until we could find
9 Q Have you ever spoken to Randy Roberts on 9 a permanent employee. And she replaced another
10 the phone? 10 gentleman that was placed in our office by Robert
11 A No. 11 Half who didn't work out. So Robert Half replaced
12 Q Have you ever had any contact with Randy 12 him with her. And I have to say it wasn't Robert
13 Roberts? 13 Half at the time. I think it was Careers
14 A No. 14 Consultants. They were bought up by Robert Half at
15 Q Do you know who Kyle French is? 15 the time that we engaged. And when she came in is
16 A I know only of his name. Never met him. 16 the first time I saw her.
17 Q Did you ever speak to Kyle French on the 17 Q What year did Ms. Melongo start working
18 phone or by email or any other means? 18 as a temp?
19 A No. 19 A 2005. I believe it was December or
20 Q How do you know his name? 20 somewhere around there.
21 A Only because of the lawsuit. It wasn't 21 Q How long did Ms. Melongo work for Save a
22 a lawsuit. What is it called? The complaint. 22 Life Foundation?
23 Q The complaint filed by Ms. Melongo? 23 A Until -- she was fired by Robert Half I
24 A No, the complaint that was filed with 24 think the beginning of April.
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1 Q Of what year? 1 decision to fire Ms. Melongo?
2 A 2006. 2 A I did not. Most of that -- employees I
3 Q Did Ms. Melongo always work as a temp 3 was dealt with Vince Davis. He handled all of that
4 employee or was she ever a full time? 4 comings and goings. You would call him a manager
5 A Yes. She was always a temp. She was 5 of the office.
6 never a full-time employee. 6 Q To your knowledge did Vince Davis have
7 Q How would you describe Ms. Melongo as an 7 anything to do with the firing of Ms. Melongo?
8 employee? 8 A Not to my knowledge. I know that when
9 A I got along with her. I defended her. 9 she left, he, as anybody that comes into our office
10 Apparently she had some discretions and some 10 to work temporary or full time or as an employee,
11 problems with my staff, but I wasn't in the office 11 we make sure that they have an exit to make sure
12 that often. So when I was around her, there was 12 that we give them back what they brought in, and
13 never any problems. 13 they keep what we, you know, that our supplies and
14 Q You testified there was some problems 14 things are left behind. So we have -- do an exit
15 with your staff and Ms. Melongo. What were those 15 sheet.
16 problems? 16 Q It's your testimony that the decision to
17 A Well, I thought it was because 17 fire Ms. Melongo was made by Robert Half, not Save
18 Ms. Melongo had an accent that my staff didn't 18 a Life?
19 understand. And she came out quite harsh at them. 19 A That's true.
20 So I tried to explain to my staff that they may 20 Q Why did Robert Half make the decision to
21 misunderstood her. 21 terminate Ms. Melongo --
22 Q In terms of your relationship with 22 A I don't know.
23 Ms. Melongo while she was working at Save a Life 23 MR. NINFO: Objection; speculation.
24 Foundation, how would you describe that 24 You have to take a break before you
53 55

1 relationship? 1 answer.
2 A We got along well. I even wrote -- when 2 THE WITNESS: I will take a breath.
3 she got fired from Robert Half, I wrote a letter 3 By Ms. Schwartz:
4 supporting her. 4 Q You testified that Robert Half made a
5 Q In what context did you write a letter 5 phone call to Ms. Melongo about her termination,
6 supporting her? 6 but she requested a letter; is that correct?
7 A So that they knew I was satisfied with 7 A We received an email from, Vince and I,
8 her. So it wouldn't reflect negatively against 8 and I don't know if anybody else was in on that
9 her. There must have been something going on 9 email. Where she sent it to her employer with
10 between Robert Half and her. I don't know. But I 10 Robert Half. Saying that she was not going to
11 wanted to make sure that they knew that I was 11 accept a phone call from this supervisor as a
12 satisfied with her. 12 dismissal for her employment. That he would have
13 Q Did Save a Life Foundation ever fire 13 to send her a letter, and that she was not going
14 Ms. Melongo in 2006? 14 to leave us, Save a Life, until she received that.
15 A Would you repeat that? 15 Q Did Robert Half prepare a letter?
16 Q Did Save a Life Foundation ever fire 16 A That --
17 Ms. Melongo in 2006? 17 MR. NINFO: Objection; speculation.
18 A No. She was fired by Robert Half, but 18 THE WITNESS: One, two three. I don't know.
19 she refused to be fired by a phone call. So she 19 By Ms. Schwartz:
20 told Robert Half she was going to stay employed at 20 Q At any point did you tell Ms. Melongo
21 our office until they sent her a registered letter. 21 that she was fired?
22 And apparently she received that registered letter 22 A No.
23 and left. 23 Q To your knowledge did Vince Davis tell
24 Q Did you have anything to do with the 24 Ms. Melongo she was fired?
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1 A No. 1 not.
2 Q You testified about an exit interview or 2 So then they contracted Annabel Melongo
3 exit review related to the termination of 3 to come in because she told them that she could do
4 Ms. Melongo's employment at Save a Life through 4 it, and find -- break into our system and change
5 Robert Half? What was the process for wrapping up 5 the passwords so we could get into our computers
6 Ms. Melongo's employment at Save a Life? 6 again.
7 A Just to go through her desk to make sure 7 That was her sole, sole reason that I
8 she took her belongings and kept -- didn't take our 8 knew she was hired in is to rectify, to change what
9 belongings. And at the time that we, you know, she 9 the previous guy did. After that I have no clue.
10 signed off that she took her items and that we 10 Q Was the previous guy the previous IT
11 remained with our items. One of the things were 11 temp through Robert Half was that Victor
12 any passwords that she would have changed with the 12 Rodriguez?
13 computer. Excuse me. So it was just general. 13 A Yes.
14 Q Did that exit process take place on 14 Q Did Ms. Melongo successfully refigure or
15 April 27, 2006? 15 reset the Save a Life passwords?
16 A I don't remember the date. 16 A I have no clue.
17 Q To your recollection was it some time in 17 Q Are you aware of any other projects that
18 April 2006? 18 Ms. Melongo worked on prior to her departure from
19 A I would say yes. 19 Save a Life foundation?
20 Q Were you present in the offices on that 20 A No. I don't remember.
21 date that Ms. Melongo turned in her pass -- turned 21 Q What happened after Ms. Melongo was
22 in the passwords, collected her belongings, and 22 informed that she was -- Strike that.
23 left? 23 What happened after when Ms. Melongo
24 A I don't remember. 24 came in, collected her belongings and left the Save
57 59

1 Q Do you remember anything about that 1 a Life Foundation offices.


2 date, the date Ms. Melongo left the offices of Save 2 MR. NINFO: Objection; form.
3 a Life? 3 THE WITNESS: Could you repeat that. I don't
4 A No. 4 understand.
5 Q You don't remember -- do you remember 5 By Ms. Schwartz:
6 speaking to her about her termination at all? 6 Q You testified that Ms. Melongo came in,
7 A No. 7 collected her belongings, was asked to give up
8 Q What projects was Ms. Melongo working on 8 passwords, and then left --
9 around the time she left Save a Life Foundation? 9 A Yes.
10 A Her sole purpose from what I remember 10 Q -- Save a Life offices; is that correct?
11 because I do not know anything to this day about 11 A Yes.
12 computers. 12 Q Was that her last day at Save a Life
13 The IT temp that we had before through 13 Foundation?
14 Robert Half, had changed all of the email, I'm 14 A To my knowledge.
15 sorry -- all of the passwords, and came into our 15 Q What happened after Ms. Melongo left
16 office, and my office at the end of the day. And 16 that last day?
17 in front of Vince Davis and I were talking and he 17 MR. NINFO: Objection to form.
18 said he had changed all of the passwords and he was 18 By Ms. Schwartz:
19 not going to relinquish those passwords until we 19 Q Did it --
20 gave him a full-time job. 20 MR. NINFO: Are you talking on that very day
21 So we immediately called Robert Half, 21 at that very moment or are you talking about
22 his person, his supervisor, explained the 22 forever after she left?
23 situation. They came in, Robert Half people did, 23 By Ms. Schwartz:
24 to try to break and get the passwords. They could 24 Q In the days following Ms. Melongo's
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1 departure from Save a Life Foundation after she was 1 either temp employees or full-time employees fired
2 fired from Save a Life Foundation? 2 from working at Save a Life?
3 A Yes. 3 A There was one man that was removed.
4 Q What happened in relation to Ms. Melongo 4 Q Who was that one person?
5 after that? 5 A I can't remember his name. That was
6 A I received an email, a lengthy email, 6 back in 1996. I couldn't remember his name.
7 very disgruntled email, and the only thing I really 7 Q What was the reason for his
8 remember out of that lengthy email was that she had 8 termination?
9 found a boyfriend. That's all I remember out of 9 A My IT who I had, Frank Fuller who
10 it. 10 passed, found some things on his computer that was
11 Q The lengthy email was from 11 not appropriate.
12 Ms. Melongo? 12 Q By "not appropriate," what do you
13 A Yes. For some reason she thought that I 13 mean?
14 was against her. 14 A It is embarrassing to say, but he liked
15 Q It was a disgruntled email you said? 15 young men.
16 A Yes. 16 Q You testified earlier about Victor
17 Q Did you respond to that email? 17 Rodriguez. Was he also terminated from his temp
18 A No. 18 work at Save a Life Foundation?
19 Q Did you have any other contact either in 19 A He was -- he actually quit Robert Half.
20 person or on the phone or over email with 20 Q Apart from the man about whom you
21 Ms. Melongo in the days after she was fired? 21 testified in 1996 who was terminated for
22 A She called my phone, but I did not 22 inappropriate materials on his computer, do you
23 respond. She called at work several times, but I 23 know of any other individuals who were terminated
24 did not respond. 24 from working at Save a Life Foundation?
61 63

1 Q Did you ever see her in person after 1 A No.


2 she was terminated? 2 Q I would like to ask you some questions
3 A No. 3 about Safe a Life Foundation's computer issues in
4 Q From the days following her termination 4 April and May of 2006.
5 Ms. Melongo attempted to call you a few times -- 5 One of the issues in this case is the
6 A Yes. 6 alleged intrusion on Save a Life Foundation
7 Q -- but you never actually spoke to 7 servers. Would you describe to me the intrusion
8 her? 8 that you claimed took place on Save a Life
9 A No. 9 Foundation's servers in late April of 2006?
10 (At this point in the proceedings 10 A I wish I could. I don't understand it
11 Ms. Brown left the room.) 11 at all.
12 By Ms. Schwartz: 12 Q What don't you understand?
13 Q Was Ms. Melongo the first Save a Life 13 A Anything to do with computers I'm stuck.
14 employee who you fired? 14 Q What is your knowledge of what happened
15 MR. NINFO: Objection. She stated she didn't 15 in April of 2006?
16 fire her. 16 A What I was told, which I don't
17 By Ms. Schwartz: 17 understand?
18 Q Was Ms. Melongo the first Save a Life 18 Q What were you told?
19 employee that was terminated from working at Save a 19 A I was told by the forensic gentlemen
20 Life? 20 that we hired, that Frank Fuller, IT, had put a
21 A As a temp? 21 back up tape onto our servers. We had quite a few
22 Q As a temp or as a full-time employee? 22 of them because at 2:00 o'clock it would go on and
23 A I did not do the firing. 23 it would copy everything that were on all of these
24 Q To your knowledge were other employees, 24 other servers. 2:00 o'clock in the morning.
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1 Because he knew I worked late, he wanted to make 1 police.
2 sure that 2:00 o'clock I usually go home. 2 Then Vince came to me and said, they
3 (At this point in the proceedings 3 said, contact the police.
4 Ms. Brown re-entered the room.) 4 Q Who is Vince Davis?
5 THE WITNESS: And that backup tape went on in 5 A A wonderful man.
6 2:00 o'clock in the morning, and somebody was in 6 Q What was his role at Save a Life
7 the computers at that time as that engaged and it 7 Foundation?
8 blew up the system. That's all I know. 8 A Everything. A six foot three gentleman
9 By Ms. Schwartz: 9 who was from the military, worked for the Federal
10 Q And this took place in the early morning 10 government with FEMA prior, and came to work for
11 hours of April 28, 2006? 11 me. And was my right- and left-hand man.
12 A Yes. 12 And anyhow, he was our military affairs
13 Q How did you discover that there was some 13 director because we worked with ROTC, and knew
14 issue with the computers or the servers after -- on 14 everything else.
15 or around April 28, 2006? 15 Q What years did Vince Davis work at Save
16 A We came into work 7:30 in the morning 16 a Life Foundation?
17 and turned our computers on, there was nothing 17 A I don't remember. I don't remember. He
18 there. None. None of my employees had anything. 18 seemed to be with me forever.
19 It was gone. 19 Q More than ten years would you guess?
20 Q What did you do when you discovered that 20 A Probably close to ten. I can't
21 there was nothing there on April 28, 2006? 21 remember.
22 A We thought we crashed. And we had a 22 Q You testified that Brian Salerno was
23 young man who was a temp for -- he was working on a 23 involved in bringing in a forensic company to work
24 project for us for a website, which was on-line 24 over the weekend to try to resolve the Save a Life
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1 training. His name was Christopher Sass. He was 1 computer server issues; is that correct?
2 in his office. He said, well it looked like the 2 A Yes.
3 computer crashed. Let me reboot it. 3 Q To your knowledge what work did -- was
4 Then I went into my office. Started 4 done over that weekend to try to resolve the
5 doing my own paperwork, and they came in and they 5 computer issues?
6 said we are still working on it. Can't seem to get 6 MR. NINFO: Objection; speculation.
7 it fixed. 7 You can answer, if you know.
8 Then he called his boss, Brian, 8 THE WITNESS: I'm sorry. I have no clue.
9 somebody. And had his boss come in to see if he 9 By Ms. Schwartz:
10 could fix it, and he couldn't. Then he called a 10 Q Do you have any knowledge of any efforts
11 tech company, a forensic tech company that he was 11 that were made to recover the data on the Save a
12 friends with. 12 Life Foundation computers?
13 Q Is the "he," Christian Sass or? 13 A I don't know. All I know is they worked
14 A No. His boss was Brian Salerno. 14 for days. Never went home.
15 Something like that. 15 Q When you say, "I don't know," what do
16 Q Brian Salerno? 16 you mean by that? Is that because you don't have
17 A They brought in this forensic company. 17 an understanding of the computer issues, as you
18 They worked all weekend. All weekend with -- 18 say?
19 Vince Davis was by their side. Because Vince new 19 A Yes.
20 more about computers than I did. I just know how 20 Q But you were kept appraised of what was
21 to turn them on. And they spent a lot of hours 21 going on with Vince Davis, Brian Salerno. Any
22 24/7 trying to fix the computer and they couldn't. 22 others?
23 So then is when the tech company, the 23 A To some degree. Only really that I
24 forensic said to Vince, that he should contact the 24 remember, it doesn't work yet. They couldn't
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1 explain because I didn't understand. 1 little bit more about the scantron project or what
2 Q Did they ever -- were they ever able to 2 scantron was?
3 get the computers back up and running? 3 A It is a card.
4 A Yes. 4 Q Yes.
5 Q How long did that take? 5 A And the children were given a test
6 A A week. 6 before they did their training what they actually
7 Q Was any data or files -- were any data 7 knew in saving a life, if they would get involved.
8 or files lost -- 8 If they wouldn't get involved. Did they know what
9 A Yes. 9 to do, who to call.
10 Q -- as a result of the alleged intrusion 10 And after they were trained. They would
11 on April 28, 2006? 11 take the same test and answer what they learned so
12 A Yes. 12 we could compare what they did.
13 Q Could you put a number on that data 13 Three months later we gave them another
14 percentage wise? What percent of Save a Life's 14 card to see if they retained these skills. And we
15 data or files were lost? 15 had a 97 percent retention level after 3 months.
16 A Out of the data that was lost on the 16 We were very proud of that. Kids do absorb how to
17 computers that still worked. About 90 percent was 17 save a life, not take one.
18 brought back, but we lost a couple of towers, I 18 Q So the scantron system was a way of
19 think that is what they call them, completely. 19 tracking how many children were trained --
20 Q When you say, "we lost a couple of 20 A Trained.
21 towers completely," what do you mean? 21 Q -- using Save a Life services?
22 A Are they servers where you store your 22 A Yes.
23 stuff on. I know there was a Sony that totally 23 Q Was all of the scantron information lost
24 blew up. 24 or just some of the scantron information?
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1 Q You had nothing on that Sony computer 1 A All of the scantron data was lost. We
2 could be recovered? 2 still retained the cards themselves.
3 A Right. 3 Q That is the card that the children
4 Q What types of information or files were 4 filled out?
5 lost? 5 A Yes.
6 A Almost 20 years worth of data. Mainly 6 Q As we sit here today, what percentage of
7 on the Sony had to do with our scantron, every time 7 all data that was allegedly deleted on April 28,
8 we trained a child, we had them fill out a scantron 8 2006 was later recovered?
9 card to verify what they were able to learn with 9 A When it was recovered, it didn't come up
10 our training. And that was all stored in our Sony. 10 in word form. It came up in numbers. I had to
11 And our programs were stored in our Sony. We had 11 open each one and put it into a file myself. Took
12 curriculums that we -- EMS firefighters and police 12 me four months. And often 24/7. I stayed -- I
13 officers that were EMS trained, they would go into 13 slept at the office on my conference table.
14 public schools. We had all of the Chicago public 14 And I would say that like, I would say
15 schools. And they would teach the children from 15 probably 70 percent of what I needed to be
16 Kindergarten through 12th grade life saving skills. 16 functional was retrieved, but it was difficult.
17 Something that they would need to maintain life 17 You feel like you have your one leg cutoff, and you
18 until they arrive. All of that stuff was stored on 18 are limping along.
19 the Sony. 19 Q About 30 percent was lost --
20 Q All of that information was lost? 20 A Yes.
21 A Yes. 21 Q -- permanently?
22 Q Did you ever recover that information? 22 A A lot of emails from 2000 -- no, from
23 A No. 23 1996 when we first started emails to 2000 -- I
24 Q When you say "scantron," tell me a 24 think 2001 we lost all of those emails.
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1 Q Those were never recovered? 1 to?
2 A No. 2 A Tech something.
3 Q Did you ever learn that the recovery 3 Q Was it someone from Critical Technology
4 efforts from the third-party vendors hired by SALF 4 Solutions?
5 employees, might impede a later law enforcement 5 A Yes.
6 investigation into the intrusion? 6 Q So somebody at Critical Technology
7 A No. 7 Solutions told you there was a possibility that
8 Q No one ever told you that? 8 Ms. Melongo might have something to do with the
9 A No. 9 April 28th, 2006?
10 Q What were you doing in the early morning 10 A Yes.
11 hours the night of April 28th, 2006 when the 11 Q Who was that at Critical Technology
12 alleged intrusion took place? 12 Solutions?
13 A I don't know. I don't remember. 13 A I don't remember.
14 May I use the ladies room? 14 Q What did that person say to you from
15 MS. SCHWARTZ: Now is a great time for a 15 Critical Technology Solutions?
16 five-minute break. 16 A Something to do with an email. That's
17 Let's take a five-minute break. Let's 17 all I remember.
18 go off the record. 18 Q What did that person at Critical
19 (A recess was had.) 19 Technology Solutions say about Ms. Melongo
20 By Ms. Schwartz: 20 specifically?
21 Q Ms. Spizzirri, did you come to believe 21 A I don't remember.
22 that Annabel Melongo had something to do with the 22 Q Did he say anything about how he
23 April 28th, 2006 intrusion on Save a Life 23 thought -- how or why he thought Ms. Melongo may
24 servers? 24 have been involved in the April 28th, 2006?
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1 A I don't understand. 1 A Only because of an email and I didn't


2 Q Did you ever come to believe that 2 understand what he meant.
3 Ms. Melongo had something to do with the computer 3 Q When you say, "because of an email," do
4 issues you were describing on April 28th, 2006? 4 you recall what email he was referring to?
5 A When would I have come to that 5 A IP.
6 suspicion. 6 Q IP?
7 Q Did you ever come to that suspicion is 7 A IP is the only thing I can remember.
8 my first question. 8 Q You recall there was something -- there
9 A Ever, okay. 9 being something about an IP address, is that what
10 Q Yes. 10 you mean?
11 A If I ever? Yes. I ever, but not 11 A I think so.
12 immediately, no. 12 Q In terms of the actual email, that this
13 Q When did you come to that suspicion that 13 Critical Technologies Solutions individual was
14 Ms. Melongo had something to do with the April 14 referring to, do you know anything about the
15 28th, 2006 intrusion on Save a Life servers? 15 substance of the email, the date the email was
16 A When I was told by the forensic that 16 sent, what email he was looking at?
17 there was a possibility that Ms. Melongo was the -- 17 A Oh, I'm sorry. I'm sorry. I didn't
18 came through into the computer system at night. 18 mean an email paper like that. I meant an email
19 That was the first time that there was any thought 19 address. IP. Is that what they call it? IP email
20 that. And I couldn't believe it. I didn't think 20 address. I'm not sure.
21 it was possible because we got along. 21 Q So something about an email address was
22 Q I'm sorry. 22 what this person at Critical Technology Solutions
23 A I'm sorry. 23 told you about?
24 Q Who was the forensic that you referred 24 A Uh-huh.
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1 MR. NINFO: Is that a yes? 1 him to the Rolling Meadows Court House to file a
2 THE WITNESS: Pardon me. 2 complaint.
3 MR. NINFO: Is that a yes? Is that a yes? 3 Q Did you accompany him to Rolling
4 THE WITNESS: Yes. Yes. Yes. 4 Meadows?
5 By Ms. Schwartz: 5 A Yes.
6 Q Do you recall anything about that email, 6 Q And at the Rolling Meadows Court House
7 the date it was sent, the substance of it, the 7 did you file a complaint against Ms. Melongo?
8 sender, anything about that email? 8 A I signed something.
9 MR. NINFO: Objection. She just testified it 9 Q What did you sign?
10 was an email address. Not an actual email. 10 A I don't know.
11 By Mr. Schwartz: 11 Q What was your understanding of what the
12 Q I'm sorry. Just to clarify then. I 12 complaint was that you signed?
13 think I misunderstood your answer. 13 A They needed a warrant.
14 Critical Technology Solutions told you 14 Q When you were at Rolling Meadows Court
15 something about an email address, not an actual 15 House, did you speak with the judge or did you just
16 email? 16 sign a document? What happened at the Rolling
17 A Yes. 17 Meadows Court House?
18 Q Do you remember anything about that 18 A I just stood there and signed.
19 email address? What email address it was, for 19 Q Were you before a judge?
20 instance? 20 A Yes.
21 A That it was -- her name was in that 21 Q Were you under oath?
22 email address. 22 A No. I don't think so. I don't
23 Q Her name, Ms. Melongo's name? 23 remember.
24 A Yes. 24 Q Did the judge ask you any questions?
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1 Q And that was the first link that made 1 A He asked if I was the owner and founder
2 you think Ms. Melongo may have something to do with 2 of the Save a Life Foundation. That's all I
3 the April 28th, 2006, alleged intrusion? 3 remember.
4 A Excuse me? Yes. 4 Q Did you say anything to the Judge?
5 Q Do you remember anything else about what 5 A Only that I was the owner and founder of
6 the person from Critical Technology Solutions told 6 Save a Life Foundation or president and founder.
7 you? 7 Q Anything else?
8 A No. 8 A Not that I remember.
9 Q Apart from that conversation, with 9 Q You testified that the two pieces of
10 someone from Critical Technology Solutions was 10 information that made you suspect Ms. Melongo had
11 there any other reason that you came to believe 11 something to do with the alleged intrusion on
12 Ms. Melongo may have been involved in the 12 April 28th, 2006 were a correspondence or
13 April 28th, 2006, alleged intrusion? 13 conversation you had with Critical Technology
14 A When? 14 Solutions and communication you had with
15 Q At any time? 15 Detective Martin; is that correct?
16 A Yes. I was told by Detective Martin. 16 A That's correct.
17 Q What were you told by 17 Q But you did not have any personal
18 Detective Martin? 18 information or basis to believe that Ms. Melongo
19 A That they had been able to trace the 19 had anything to do with the April 28th, 2006
20 footprint. 20 intrusion, correct?
21 Q What do you mean when you say, they were 21 A That is correct.
22 able to trace the footprint? 22 Q You testified earlier that scantron
23 A I don't know who, but somebody was able 23 information was lost during the -- after the
24 to trace the footprint. I would need to accompany 24 April 28th, 2006 alleged intrusion as were a bunch
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1 of emails and some other files. 1 A Chris Sass. He was a temporary employee
2 Was there any financial or accounting 2 and Brian Salerno. That was his boss. And he is
3 information lost in April, after the April 28th, 3 the one who received the email and traced it and
4 2006 alleged intrusion? 4 sent it to me.
5 A No. 5 Q Is that how you became aware that an
6 Q No financial information was lost? 6 email had been allegedly forwarded from your
7 A No. 7 account to Ms. Melongo's yahoo account?
8 Q You testified earlier that in the days 8 A Yes.
9 following her termination, Ms. Melongo called you a 9 Q But you testified that you never saw any
10 number of times, but you did not speak to her; is 10 email that was forwarded out of your account to
11 that correct? 11 Ms. Melongo's account?
12 A That's correct. 12 MR. NINFO: Objection; form.
13 Q To your knowledge, did any other Save a 13 By Ms. Schwartz:
14 Life employee speak to Ms. Melongo in person or 14 Q Did you ever see a copy of any email
15 over the phone in the days following her 15 that was forwarded out of your account and into
16 termination? 16 Ms. Melongo's account?
17 MR. NINFO: Objection; speculation, if you 17 A I saw it when it was forwarded to me by
18 know, answer. 18 Christian Sass.
19 THE WITNESS: I don't know. 19 Q Was it just one email that was allegedly
20 By Ms. Schwartz: 20 forwarded out of your account on May 1, 2006 or two
21 Q In the weeks after the alleged intrusion 21 emails or whatever number of emails?
22 on Save a Life systems on April 28th, 2006, who did 22 A I don't remember.
23 you speak to about the intrusion? You mentioned 23 Q What was the email or emails that were
24 Brian Salerno, Vincent Davis, someone at Critical 24 forwarded out of your account to Ms. Melongo's
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1 Technology Solutions, Detective Martin. Anyone 1 yahoo account on May 1, 2006?


2 else? 2 A I know that it was an email
3 A Our staff all knew. 3 correspondence between Brian Salerno and myself who
4 Q Anyone else? 4 was working to recover the data after they had
5 A I think my Board was notified. 5 discovered this IP address, and felt it was
6 Q Did you speak with anyone else about the 6 Ms. Melongo's email.
7 intrusion in the weeks? 7 And I remember, like I said, us
8 A I don't remember. 8 corresponding back and forth as to him coming back
9 Q You have also claimed that someone 9 to finish up, trying to get more data down. You
10 accessed your Save a Life email account without 10 know, recover more data. And then, I mentioned to
11 your permission or authorization on May 1st, 2006 11 him that Ms. Melongo had contacted me at the office
12 and forwarded emails to the account 12 and I -- the office front desk referred her to
13 Melongo_Annabel@yahoo.com; is that correct? 13 speak to Christian Sass if she had any questions,
14 A I never received it. My staff did. 14 but she didn't want to talk to him.
15 Q When you say, "it," what do you mean? 15 Q That was the general substance of the
16 A The email you're referring to, I'm 16 email that was allegedly forwarded.
17 sorry. 17 A Yes.
18 Q But you do believe that someone 18 Q When was an email or emails forwarded
19 forwarded an email from your Save a Life email 19 out of your account to Ms. Melongo's email account?
20 account to Ms. Melongo's account? 20 What day and what time?
21 A I was told by one of my employees who 21 A I don't understand.
22 received the email traced where it came from and 22 Q Do you know when an email was forwarded
23 then sent it to me. 23 out of your account to Ms. Melongo's account?
24 Q Who was that employee? 24 A I don't know if Ms. Melongo's account
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1 ever received an email forwarded to her. It was 1 email account on May 1 of 2006?
2 reverse. 2 MR. NINFO: Aside from testifying that they
3 Q What do you mean by that? 3 contacted Detective Martin?
4 A From what I saw is that Ms. Melongo had 4 By Mr. Schwartz:
5 taken an email that I had written to Brian Salerno, 5 Q Aside from what you testified to
6 Salerno, whatever, and forwarded it to my employees 6 already.
7 with a statement that she was going to expose me. 7 A Oh, okay. I don't remember anymore.
8 It was a threatening remark. 8 Q So it's your testimony that it was
9 Q That was on May 1, 2006? 9 Christian Sass who made you believe that
10 A I'm sorry, I don't know the date. 10 Ms. Melongo had something to do with accessing
11 Q Do you believe Ms. Melongo took an email 11 your email account on May 1, 2006?
12 you had written to Brian Salerno from your email 12 A Yes.
13 account? 13 Q Were there any other reasons you thought
14 A I can't -- can't swear on it. All I can 14 Ms. Melongo was involved in accessing your email on
15 say is what I was told. 15 May 1, 2006?
16 Q What were you told? 16 A No.
17 A According to Christian Sass he ran the 17 Q At the time Christian Sass told you that
18 footprints to where the email came from, and it 18 Ms. Melongo may be involved in accessing your email
19 went back to her from I don't know more than that. 19 on May 1, 2006, had you already come to believe
20 Q Did you ever have a conversation with 20 Ms. Melongo may have been involved in an April 28,
21 Christian Sass about that email? 21 2006 alleged intrusion?
22 A Yes. And he suggested I contact 22 A Only what I was told.
23 Detective Martin. 23 Q Had somebody at the time you spoke to
24 Q What did he say? What did Christian 24 Christian Sass about the May 1, 2006, email, had
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1 Sass say to you? 1 somebody already told you that Ms. Melongo may have
2 A He said that it looks like Ms. Melongo 2 been involved in the April 28, 2006 alleged
3 had penetrated my emails and we need to notify 3 intrusion?
4 Detective Martin. And I believe that Vince called 4 A Only what I was told from the forensic
5 Detective Martin back in to view. 5 technology.
6 Q Do you recall anything else Christian 6 Q From Critical --
7 Sass said? 7 A That's it.
8 A No. 8 Q From Critical Technology Solutions?
9 Q What did you say to Christian Sass -- 9 A Yes.
10 A I don't remember. 10 Q You had already spoken to Critical
11 Q -- during that conversation? 11 Technology Solutions at that point?
12 You don't remember. 12 A They had mentioned that they had found
13 A (Shaking head.) 13 her IP address.
14 Q Apart from speaking with Christian Sass, 14 Q To your knowledge did Ms. Melongo know
15 did you do anything else when you found out that 15 your email password on May 1, 2006?
16 someone had forwarded emails -- sent emails from 16 A Ms. Melongo had access to all of our
17 your account to another email account? 17 email passwords. She made them. The guy before
18 A Would you repeat that, I don't 18 her stole them all and redid our passwords, and she
19 understand. 19 is the one who broke in and made all new email
20 Q You testified that you talked to 20 addresses -- passwords.
21 Christian Sass about the emails. 21 Q After Ms. Melongo was terminated on
22 A Right, yes. 22 April 27, 2006, you did not change your email
23 Q Did you do anything else when you found 23 password?
24 out about the emails, the alleged access to your 24 A I would not have. I didn't know how.
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1 Q Why didn't you change your password 1 A At the suggestion of Brian Salerno. He
2 after Ms. Melongo was terminated? 2 suggested to bring them in.
3 A I don't know how. 3 Q What exactly was Critical Technology
4 Q Weren't other passwords on Save a Life 4 Solutions hired to do?
5 computer systems changed after Ms. Melongo was 5 A From what I understood they were
6 terminated? 6 forensics and they would be able to find out why
7 A I wouldn't know. I did not know how to 7 they couldn't -- Brian couldn't get it back up.
8 do that. It would have had to have been somebody 8 Q And the letter begins, "Carol, As per
9 else. I don't know when or where or anything. 9 our discussion, I have provided an overview of the
10 Q In the days and weeks after the 10 actions taken by Critical Technology Solutions".
11 access, alleged access to your email on May 1, 11 Did you have a conversation with Don Peters before
12 2006, did you speak to anyone else apart from 12 he sent you this letter on May 11, 2006?
13 Detective Martin, and Christian Sass about the 13 A Apparently I had.
14 email issue? 14 Q Do you recall it?
15 A I don't remember. 15 A I don't recall. It may have definitely
16 Excuse me, our staff, did you say our 16 been. He was in the office all of the time.
17 staff. Because our staff all knew about it. 17 Q Do you recall anything about your
18 Because they were emailed. I didn't hear what you 18 conversation with Don Peters --
19 said. If you mentioned our staff, yes. 19 A No, I don't.
20 Q Did you speak to any of those staff 20 Q -- before this letter?
21 members who were copied on the email from 21 A Only they are the ones who found what I
22 Ms. Melongo? 22 had said with the IP.
23 A They came to me. 23 Q Did he document what he found with the
24 Q What did they say? 24 IP in his letter summarizing what Critical
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1 A That they received this email. 1 Technology Solutions recovery and forensic efforts
2 Q I would like to walk through some of 2 were?
3 the communications with Critical Technology 3 A He may have, but even reading this, I
4 Solutions. I am handing Ms. Spizzirri Plaintiff's 4 don't understand it. It's -- you know, to some
5 Deposition Exhibit No. 1, which is Bates stamped 5 degree I understand, but, it's -- I don't
6 Attorney General 001365 to 66. 6 understand even what megabytes are.
7 (A document was marked Plaintiff's 7 Q In this letter dated May 11, 2006 from
8 Deposition Exhibit No. 1 for 8 Mr. Peters, in which he says, "As per our
9 identification.) 9 discussion, I have provided an overview of the
10 By Ms. Schwartz: 10 actions taken by Critical Technology Solutions,
11 Q Is Exhibit 1 a report by, from Critical 11 Inc., to identify and recover any lost, missing,
12 Technology Solutions that Don Peters sent you on 12 destroyed or altered data files from equipment
13 May 11, 2006? 13 owned by SALF." I don't see any reference in this
14 A I see that, yes. 14 letter, Exhibit 1, to Ms. Melongo; is that correct?
15 Q Is that a true and accurate copy of a 15 A I agree.
16 letter you received from Don Peters? 16 Q But at some point he told you there was
17 A I can't verify. It looks like it, 17 some IP address linked to Ms. Melongo?
18 but. 18 A That's what I was told.
19 Q No reason to believe it is not the 19 Q But he didn't include it in his letter
20 letter he sent you. 20 to you --
21 A That's the word, right. 21 A He did not include it in his letter.
22 Q Did you hire Critical Technology 22 MR. NINFO: Let her finish her question.
23 Solutions to assist with the computer related 23 By Ms. Schwartz:
24 efforts after April 26, 2006? 24 Q In this letter, Exhibit 1, Mr. Peters
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1 describes a Dell server and a Sony server. What 1 all I knew. And we did not get up again for a long
2 were those two servers? 2 time. And I just wanted to get back to work. I
3 MR. NINFO: Object to the form. 3 really didn't understand any of this. So I
4 THE WITNESS: One, the Sony is the one we kept 4 basically let it in Vince's hands to deal with it.
5 our -- from what I was told -- we kept our scantron 5 I had to deal with other things.
6 information on. I don't know about the Dell. I 6 By Mr. Schwartz:
7 know we had a Dell. I just sign the checks. 7 Q Did Don Peters or anyone else ever warn
8 By Ms. Schwartz: 8 you before recovery efforts were made that recovery
9 Q Are those the two servers, the Dell and 9 efforts may affect the quality of the server
10 the Sony that were affected by the alleged 10 evidence?
11 intrusion on April 28, 2006? 11 A I just wanted to get back to work.
12 A They may have been. I don't know if we 12 Q But did anyone ever warn you that
13 had more. 13 recovery efforts might affect the quality of the
14 Q I would like to turn your attention to 14 server or computer evidence?
15 the second page of Exhibit 2 -- Exhibit 1. I'm 15 A They may have, but I wouldn't have
16 sorry, excuse me. 16 understood. And I just needed to get back to work.
17 A Yes. 17 Q So you opted to move forward with
18 Q It says, "It is important to note that 18 recovery efforts?
19 following the discovery of data loss on April 28th, 19 A Yeah. Yes.
20 many technical personnel attempted to perform 20 Q Do you remember being advised by Don
21 recovery procedures on the Dell and Sony systems. 21 Peters or anyone else that the quality of the
22 These actions were appropriately matched to the 22 evidence may be questionable, if recovery efforts
23 technician's skill sets and we apparently carried 23 were made?
24 out in a good faith effort to provide recovery. 24 A I didn't really believe that anybody did
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1 With the number of personnel involved and the 1 anything to us. I thought we blew up. That's all.
2 amount of time prior to our examination, it is not 2 They may have speculated and told me things, but I
3 possible to state with complete certainty that the 3 couldn't believe that anybody would have done that
4 file tag information (dates, times, etc.) is 4 to us.
5 accurate." 5 Q My question is just whether anyone
6 Didn't this quoted statement that I just 6 warned you that --
7 read on Exhibit 1 mean that the condition of the 7 A No, I just wanted to get back to work.
8 servers could have changed between the time of the 8 MR. NINFO: Listen to her question and answer
9 alleged intrusion and the time Mr. Peters' company 9 what she is asking.
10 finished its work? 10 By Ms. Schwartz:
11 MR. NINFO: Objection; speculation. What was 11 Q My question is slightly different.
12 made -- meant by Don Peters' words. 12 A Okay.
13 By Mr. Schwartz: 13 Q My question is whether Don Peters or
14 Q Did Don Peters tell you that it would be 14 anyone else advised you that the quality of the
15 impossible to state with complete certainty that 15 evidence may be questionable, if recovery efforts
16 the file information on the servers was accurate? 16 were going to be done?
17 A Before or after the incident? 17 A They may have, but I didn't understand.
18 Q At any time did he tell you? He wrote 18 Q But do you remember any such
19 that in his letter to you; did he not? 19 conversations or discussions?
20 A Yes. 20 A No.
21 Q Did he tell that to you on the phone? 21 Q I'm handing you Plaintiff's Deposition
22 (A this point in the deposition 22 Exhibit 2, Attorney General 000106 to 113.
23 Ms. Calloway left the room.) 23
24 THE WITNESS: I know we were down. That is 24
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1 (A document was marked Plaintiff's 1 paragraph, "One scenario that caused the crash is
2 Deposition Exhibit No. 2 for 2 due to changing passwords after the separation of a
3 identification.) 3 SALF employee."
4 By Ms. Schwartz: 4 Does this refer to the changing of SALF
5 Q You hired True Consulting immediately 5 passwords after Ms. Melongo was terminated?
6 after the alleged intrusion; is that correct? 6 MR. WUNDER: Objection; speculation.
7 A Yes. That was Brian, right? 7 MR. NINFO: I join.
8 Q And this Exhibit 2 is a report from True 8 THE WITNESS: I don't know.
9 Consulting, correct? 9 By Ms. Schwartz:
10 A Yes. 10 Q If you continue down that page of
11 Q And Brian Salerno worked at True 11 Exhibit 2. It says, Under Virus/Malicious Intent.
12 Consulting? 12 "When viewing the IP log for the network, we
13 A Yes. 13 noticed than an external IP addressed logged into
14 Q Is this a true and accurate copy of 14 SALF's servers on Friday and engaged or trolled the
15 report that you received on or around April 30, 15 server for over 4 hours."
16 2006 from True Consulting? 16 (At this point in the deposition
17 A It looks like it, yes. 17 Ms. Calloway reentered the room.)
18 Q Did you review this report after 18 By Ms. Schwartz:
19 receiving it? 19 Q What is your understanding of what the
20 A I may have. 20 term trolled the servers means?
21 Q What was True Consulting hired to do for 21 A I wouldn't have known what he meant.
22 Save a Life Foundation? 22 Q This report Exhibit 2, does not state
23 A True Consulting was Chris Sass who was 23 what external IP address logged into SALF servers,
24 creating our on-line training program who then when 24 correct?
97 99

1 we -- when our computers didn't engage in the 1 A That's what it says here.
2 morning he thought we crashed. He went to the back 2 Q Did you ever ask True Consulting to
3 room to see if that needed to be rebooted. When it 3 provide information about the external IP address
4 didn't work, he called in his boss, which is True 4 that logged into SALF servers?
5 Consulting, but he was a subcontractor. 5 A I left that up to Vince.
6 Q Christian Sass worked for True 6 Q To your knowledge did Vince ever ask
7 Consulting? 7 about the IP address that logged into SALF
8 A Yes. 8 servers?
9 Q As did Brian Salerno? 9 A I think it was --
10 A Brian Salerno owned True Consulting. 10 MR. NINFO: Objection; speculation.
11 Q Was True Consulting hired to assist with 11 You can answer.
12 data recovery efforts for Save A Life Foundation? 12 THE WITNESS: I have no clue if he asked or
13 A After it happened. 13 not or if they gave him. I don't know.
14 Q And was True Consulting also hired to 14 By Ms. Schwartz:
15 help identify why the data and servers crashed? 15 Q When you say you left that up to Vince.
16 A It would speculate from there on. I 16 Did you give Vince any instruction on about the
17 wouldn't have known. I didn't know their 17 recovery efforts or what to do related to Save a
18 capability. 18 Life servers?
19 Q Do you know what True Consulting did 19 A During this investigation?
20 with respect to Save a Life Foundation computers 20 Q Yes.
21 and servers? 21 A He just voluntarily helped me out. He
22 A No. 22 just got engaged by himself.
23 Q If you turn to this exhibit, Exhibit 2, 23 Q Did you give him any guidance or
24 the second page. It states, on the second 24 instruction on what to do?
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1 A No. 1 staff that Mr. Sass traced have to do with the
2 Q Do you agree it would have been relevant 2 April 28, 2006, alleged intrusion?
3 to learn what external IP address logged into 3 A I would be just speculating. I know
4 SALF's servers on April 28, 2006? 4 that they, at the time this was written they knew
5 MR. NINFO: Objection; form. 5 somebody was in our computer. It says so here.
6 THE WITNESS: If I knew what it was, maybe. I 6 They suspected. They found an IP address.
7 didn't know what it was. 7 Apparently when Christian found the same IP address
8 By Ms. Schwartz: 8 in the email felt that Ms. Melongo had access to my
9 Q What do you mean, you didn't know what 9 email addresses or my emails, my personal emails,
10 it was? 10 but I can't remember anything else.
11 A I didn't know what an IP address was at 11 Q You can't remember how that IP address
12 the time. If someone would have explained the 12 in the emails was linked back to this April 28th,
13 whole thing to me, I was totally ignorant to 13 2006 alleged intrusion?
14 computers. 14 A Only what I was told afterwards. When
15 Q Did anyone try to explain to you that 15 Detective Martin got involved, that they were able
16 Exhibit 2 or Exhibit 1, that we have been 16 to work with True Consultant and Critical
17 discussing? 17 Technology. Were they still at the office when
18 A No. 18 this -- when Detective Martin came to the office,
19 MR. NINFO: Can I have a quick second? 19 and they worked together.
20 MS. SCHWARTZ: Yes. 20 Q Did Detective Martin tell you that?
21 (A brief interruption was had.) 21 A No, I saw him in the room with these
22 By Ms. Schwartz: 22 people.
23 Q We just had a brief break for 23 Q And did anyone, Detective Martin or
24 Ms. Spizzirri to confer with her counsel. 24 anyone from True Consulting or Critical Technology
101 103

1 I would like to turn your attention to 1 Solutions tell you the IP address found in the
2 Exhibit 2, the page marked at the bottom with 2 email that was sent to your staff, was linked to --
3 Attorney General 000111? 3 A Yes.
4 A Yes. 4 Q -- the alleged intrusion on April 28,
5 Q If you look at the very last sentence on 5 2006?
6 that page, it says, "Christian is going to try to 6 A Yes.
7 establish an IP trace to try to better identify 7 MR. NINFO: I will object to the form.
8 who/what may have been logged onto the server." 8 By Ms. Schwartz:
9 Does this refer to Christian Sass to 9 Q What did they say to you?
10 your knowledge? 10 A I believe it was Christian Sass told me
11 A Yes, ma'am. 11 that it was the same that they found during the
12 Q What is your understanding what an IP 12 trolling, that four-hour trolling that he mentions
13 trace is? 13 in here, and the email address that was connected
14 A That, from what I was told, had to do 14 to my email that was sent to my staff.
15 with an email address that traces back to the 15 Q The statement on Exhibit 2, about
16 computer it comes from. And that's what I 16 establishing an IP trace meant that as of April 30,
17 mentioned before is that Melongo's name was that 17 2006, there was some uncertainty about the IP
18 email address. 18 address that had been logged into Save a Life
19 Q Did anyone inform you whether an IP 19 servers, correct?
20 trace was achieved after Exhibit 2 was finalized? 20 MR. NINFO: Object to the form.
21 A Only what I remember is that email that 21 THE WITNESS: From what I read here.
22 was sent to my staff which Christian traced. And 22 By Ms. Schwartz:
23 had the IP address in there. 23 Q Were you aware that Christian Sass and
24 Q What did the email that was sent to your 24 Ms. Melongo did not get along?
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1 A No. 1 MR. NINFO: I mean --
2 Q Did you know anything about the 2 THE WITNESS: Not to the computer, but we did
3 relationship between Christian Sass and 3 collect on a fraudulent check. Somebody forged a
4 Ms. Melongo? 4 name. Took a check of ours and forged a name on
5 A No. 5 the check. They reimbursed us back for that. I
6 Q Do you recall any conversations with 6 don't remember anything else.
7 Christian Sass or Brian Salerno about an IP trace 7 By Ms. Schwartz:
8 apart from what you already testified to? 8 Q That fraudulent check, did that have
9 A Only what I told you as far as what they 9 anything to do with Ms. Melongo?
10 found when they were in the computer room. That 10 A I don't believe so.
11 they found this IP and email address with Melongo's 11 Q So with respect to the alleged computer
12 name connected to the I -- in the computer right 12 tampering, did you ever collect on any insurance
13 before or prior to when our back up drive went on. 13 policy for Save a Life?
14 Now, apparently from what I understood 14 A No.
15 at the time, that back up drive caused problems to 15 Q And you testified you didn't have any
16 keep some type of door open and crash our computer. 16 insurance -- Save a Life did not have any insurance
17 Q Who told you that? 17 that would cover the alleged computer tempering?
18 A Brian. True Consulting. 18 A Not at that -- no.
19 Q Do you remember anything else Brian 19 Q And who knew --
20 Salerno told you? 20 A I'm sorry. Not to my knowledge. Not to
21 A No. 21 my knowledge.
22 Q You testified earlier today that it was 22 (A document was marked Plaintiff's
23 Vince Davis that first contacted Schiller Park 23 Deposition Exhibit No. 3 for
24 Police? 24 identification.)
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1 A Yes. 1 By Ms. Schwartz:


2 Q And that was at the advice of Critical 2 Q I'm handing you Plaintiff's Deposition
3 Technology Solutions and Brian Salerno? 3 Exhibit 3, which is CCSAO 000546 to 547.
4 A One of the two. 4 Ms. Spizzirri, have you seen Exhibit 3
5 Q What happened after that initial contact 5 before today?
6 Vince Davis made with Schiller Park Police? 6 A I have seen this.
7 A A police Officer came over. 7 Q Exhibit 3 is a police report dated
8 Q Came to Save a Life offices? 8 May 5, 2006, from the Schiller Park Police
9 A Yes. 9 Department; is that correct?
10 Q Who was that police officer? 10 A Yes, ma'am.
11 A I do not remember his name. 11 Q When did you first see Exhibit 3?
12 Q Did Save a Life Foundation have 12 A I can't say. It was after the fact. It
13 insurance at the time? 13 was probably a year later.
14 MR. NINFO: Objection. 14 Q Exhibit 3 is a description of your
15 THE WITNESS: We had insurance, but not for 15 initial interview with the Schiller Park Police
16 this. There wasn't any insurance to have on 16 Department regarding the alleged intrusion on Save
17 computers at that time for intrusion. Weren't any 17 a Life Foundation; is that correct?
18 policies. 18 A Yes.
19 By Ms. Schwartz: 19 Q And on the second page of Exhibit 3 it
20 Q Did you ever collect on any insurance 20 describes a statement you made to the officer, who
21 policy related to the alleged intrusion or email 21 came into Schiller Park on May 5 -- who came to
22 forwarding? 22 Save a Life's offices on May 5, 2006 --
23 MR. NINFO: Objection. 23 A Uh-huh.
24 MS. SCHWARTZ: What's the basis? 24 Q -- correct?
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1 A Yes. Yes, ma'am. I'm sorry. 1 Q Did you tell the officer that
2 Q If you look at the signature of the 2 Ms. Melongo was terminated for performance and
3 officer on Exhibit 3, I believe that's 3 attitude problems?
4 Officer Marrazzo. Does that ring a bell? Do you 4 A I do not know that I said that.
5 recall talking to Officer Marrazzo? 5 Q Was it your understanding that
6 A Not his name. I can personally see his 6 Ms. Melongo was terminated due to performance and
7 face. 7 attitude problems?
8 Q He was a police officer? 8 A That is what I was told by Robert Half,
9 A Yeah. 9 her supervisor according --
10 Q Do you recall giving a statement to the 10 Q What --
11 officer on May 5, 2006? 11 A According to that, that letter -- that
12 A No, I do not remember. 12 email that she wrote to him, that's what I
13 Q Exhibit 3, the second page of the 13 interpreted it from.
14 document, a statement that you made. It says, 14 Q What were those performance and attitude
15 "Upon arrival R/O spoke to the reverse listed 15 problems?
16 complainant/victim/company president Carol J. 16 A As I mentioned before, I had no
17 Spizzirri who stated the following in summary, but 17 grievance, but she did have problems with other
18 not verbatim;" do you recall when you reviewed this 18 people that worked in the office.
19 Exhibit 3, reviewing whether your statement was 19 Q If you turn to the next paragraph of
20 correct and accurate? 20 Exhibit 3, it states, "On Friday 28, April '06,
21 A I did not see this at least for a year 21 between the hours of 0100-0300, an unknown offender
22 or more afterwards. 22 hacked into the computer server for SALF and
23 Q When you saw it a year or more 23 deleted all of the files in the server including
24 afterwards -- 24 financial records and account numbers. The
109 111

1 A Yes. 1 offender then entered Spizzirri's personal email


2 Q -- did you review the content? 2 account, pulled out two emails, sent them to a
3 A No. To be honest I just glanced over 3 yahoo.com email address and responded to them from
4 it. I did not review it. 4 said address."
5 Q Let's go through Exhibit 3. 5 Did you tell the Officer on May 5th,
6 First off, is 9950 Lawrence Avenue, 6 2006, that all files were deleted from the affected
7 Suite 300, is that Save a Life's offices? 7 server?
8 A Yes. 8 A I would not have. The affected server
9 Q Was May 5th, 2006 the first interaction 9 it mentions here financial records and accounts.
10 you had with someone at Schiller Park Police 10 That would not have been correct because we were
11 Department about the alleged intrusion? 11 never connected to -- our finances were never
12 A According to the police report it may 12 connected to the main -- to the computers. So that
13 have been. 13 would have been false. He misunderstood.
14 Q And on Exhibit 3, the summary states, 14 Q So it's not accurate --
15 first paragraph, page 2. "On Thursday, 27, April 15 A No.
16 '06, Spizzirri, President and Founder of Save A 16 Q -- that financial records and account
17 Life Foundation fired the above-listed 17 numbers were on the servers that were affected?
18 employee/suspect Annabel Melongo for performance 18 A That's correct. That is not accurate.
19 and attitude problems." 19 Q You would not have told him that?
20 Did you tell the officer that you fired 20 A No, ma'am.
21 Ms. Melongo? 21 Q Did you tell the officer on May 5th,
22 A I do not believe I told him that, but I 22 2006, that someone pulled two emails from your
23 can't be certain if he understood that she was a 23 personal email account and sent them to a yahoo
24 temp. 24 email address?
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1 A I think this officer was with a group of 1 Isn't it true that your emails were
2 us. And I -- because I wouldn't have been able to 2 forwarded allegedly on May 1, 2006 not April 28th,
3 testify to any of this solely. This all would have 3 2006.
4 been speculation or hearsay. The fact of even 4 MR. NINFO: I'm going to object to the form.
5 saying the financial records, I would have never 5 That is not part of the same sentence.
6 said that. And receiving the phone call, yes. I 6 THE WITNESS: I would agree with you, if I had
7 would have said that. 7 a copy of that email that was sent back, but I
8 So there may have been other employees 8 don't have it in front of me, so I can't say yes or
9 around me that were saying things that he put down 9 no.
10 here, new IT employee. There was no new IT 10 By Ms. Schwartz:
11 employee. Contacted the web server and do a trace 11 Q And farther down on this page,
12 on the evidence. The trace shows that this is not 12 Exhibit 3, the second page it says, third to last
13 an employee. He would have been Brian or True 13 paragraph. "As of the time of this report SALF has
14 Consulting or Critical Technology. They weren't 14 recovered 90 percent of the files." Is that
15 employees. They were subcontractors. 15 sentence accurate?
16 Q Just for the record your reviewing. You 16 A No. Because it does not show that we
17 are reading from, Exhibit 3, and identifying 17 lost the Sony completely.
18 certain things that you don't agree are accurate; 18 Q So 90 percent of one of servers was
19 is that correct? 19 recovered, but the Sony was not. Is that your
20 A That's correct. I am sorry. I should 20 testimony?
21 have said that. 21 A I would say that's more accurate.
22 Q So your testimony is that there were 22 Q In the next sentence on Exhibit 3, it
23 perhaps other Save a Life employees with you when 23 says, "Spizzirri stated she believes Melongo is a
24 you spoke to the officer on May 5th? 24 flight risk due to the fact that she is not a U.S.
113 115

1 A Absolutely. 1 citizen."
2 Q You said that one accurate part is the 2 Did you tell the officer on May 5th,
3 statement, "On Friday 28, April '06, Spizzirri 3 2006 that you thought Ms. Melongo was a flight
4 received a phone call from Ms. Melongo stating, I 4 risk?
5 heard you have some computer problems. I can 5 A I would not have said that.
6 help." Is that accurate, that sentence? 6 Q Why wouldn't you have said that?
7 A That would have been the front desk. I 7 A Because I would not have known at the
8 wouldn't have been me. Otherwise, because I never 8 time of this situation that she was even from
9 spoke with her. 9 Cameroon. I thought she came from Robert Half.
10 Q She was looking for you and left a 10 She was a citizen. I had no clue.
11 message to that affect? 11 They may have said that when he
12 A Apparently. 12 contacted Robert Half for her background, but I did
13 Q Then the next sentence about the new IT, 13 not say that.
14 employee, who contact the web server and do a trace 14 Q When did you learn about Ms. Melongo's
15 on the evidence. You just testified that's not 15 immigration status?
16 accurate because there was no new IT employee? 16 A When she was arrested, and I was told by
17 A Correct. That would -- 17 Detective Martin he had to contact in Washington
18 Q I'm sorry. 18 her consulate from Cameroon. That was the first
19 A -- have been True Consulting or Critical 19 time I knew that she was not a citizen and that she
20 Technology. 20 was here on an education visa.
21 Q And then the portion that I read earlier 21 Q You learned she was a citizen for the
22 about, On Friday, 28 April, the offender entered 22 first -- not a U.S. citizen --
23 your personal email account and pulled out two 23 A That was.
24 emails. 24 Q -- for the first time just prior to
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1 Detective Martin's arrest of Ms. Melongo? 1 Because he knew more about computers than I. I had
2 A I was solely obliviate. It really 2 my only -- my own job to do.
3 shocked me because she was hired by Robert Half. 3 Q Do you recall anything about that
4 Because as a company we had very strong 4 conversation?
5 regulations. If we hired someone that had a 5 A No, I do not.
6 green card, we had to report that green card. 6 Q Did Detective Martin or the other
7 And since we dealt with government stuff, we 7 officer you spoke to on May 5th, 2006, ask you for
8 would have been in violation if we didn't 8 anything in particular? Any evidence or anything,
9 report it. 9 anything else for follow up?
10 So it really put us at an odd. We had 10 A Definitely not the first officer because
11 no clue that Robert Half doesn't do a background 11 I don't think he understood what really was going
12 check, and we thought they did. So we did not 12 on. Not until Detective Martin came in and then
13 know. 13 him working with these tech -- techs. He may have
14 Q So your testimony is that you did not 14 taken some copies of what they found with him.
15 know that Ms. Melongo was not a U.S. citizen in 15 Other than that, I do not know.
16 May of 2006? 16 Q Were you given any instructions around
17 A Not until she was arrested and charged. 17 that time, early May of 2006, on how to preserve
18 That was the first I knew. 18 the computer evidence to make sure it would be
19 Q What happened after you spoke to the 19 useful for law enforcement?
20 officer on May 5th, 2006 with respect to the 20 A No.
21 investigation of the Save a Life Foundation alleged 21 Q Did you ask in early May of 2006, either
22 intrusion? 22 the first officer or Detective Martin, did you ask
23 A I believe that he left, and said that he 23 either of those individuals whether they would
24 was going to -- they had just started for a cyber 24 arrest Ms. Melongo?
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1 unit and would have -- Detective Martin headed it. 1 A No.


2 He would come over and finish up because he would 2 Q At the last sentence of Exhibit 3, that
3 know more. 3 we have been looking at on the second page it says,
4 Q Did Detective Martin come to Save a Life 4 "Complaints will be signed." The very last
5 offices that day May 5th, 2006. 5 sentence.
6 A I do not remember. 6 A Yes.
7 Q Did you speak to Detective Martin around 7 Q Did you ever sign a complaint? You
8 that time? 8 testified that you signed a complaint in the fall
9 A Not until he came to the office for the 9 of 2006, but in or around May of 2006 did you sign
10 first time. 10 any complaint?
11 Q What do you recall about that first 11 A Not to my knowledge.
12 meeting with Detective Martin? 12 Q You testified that the True Consulting
13 A The first meeting I had. He introduced 13 individuals, Critical Technology Solutions or Vince
14 himself and went right to the computer room and 14 Davis may have provided documents to
15 talked with True Consulting and Critical Technology 15 Detective Martin. Did you provide any documents or
16 and Vince. They were all in the room. 16 evidence to Detective Martin?
17 Q Were you present for that 17 A No, I did not.
18 conversation? 18 Q Are you aware of what, if any,
19 A No. 19 documents, other individuals related to Save a Life
20 Q Did you speak to Detective Martin at any 20 Foundation provided to Detective Martin or the
21 point when he came to Save a Life offices on that 21 Schiller Park Police Department?
22 day initially? 22 A All I could say is that maybe Robert
23 A I may have after he spoke with the 23 Half provided documents to them.
24 subcontractors, but would have been pretty short. 24 Q But you don't have personal knowledge as
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1 to what documents were provided to Schiller Park? 1 THE WITNESS: Yes.
2 A No, ma'am. 2 By Ms. Schwartz:
3 Q In the days after you first contacted -- 3 Q And the purpose of your contact to Dick,
4 Strike that. 4 Richard Devine was to try to get interest in
5 In the days after Save a Life Foundation 5 prosecuting the case or assistance in prosecuting
6 first contacted Schiller Park Police Department, 6 the case?
7 you also contacted then State's Attorney Richard 7 A Bringing awareness to him that it was
8 Devine; is that correct? 8 difficult for prosecutors to be willing to get
9 A I -- say that again so I am on the right 9 involved with computer hacking, and see if he would
10 page. 10 have any suggestions.
11 Q In the days after Save a Life Foundation 11 Q He wanted to see if he would have any
12 first contacted the Schiller Park police, you also 12 suggestions to?
13 contacted Richard Devine, correct? 13 A On how to proceed.
14 MR. NINFO: Objection. At any time after 14 Q How did you first make contact, was it
15 that? 15 by phone or in person?
16 By Ms. Schwartz: 16 A I looked.
17 Q In the days after. Within a few days 17 Q The first communication was in
18 after the first contact. 18 writing?
19 A Days or weeks maybe. Whenever that kind 19 A First communication was in writing.
20 of length of time. I did contact State's Attorney 20 Q Did you -- when you first contacted
21 Dick Devine. 21 Richard Devine, were you concerned that the
22 Q What form did that contact take? 22 Schiller Park Police Department wasn't doing enough
23 A That was because cyber computer hacking 23 with respect to the investigation?
24 was so brand new nobody was interested at the 24 A No. They were doing their very best.
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1 prosecutor's office to take the case. And I was 1 Q Why didn't you want to wait to let the
2 asked by or this had been brought up to me by 2 Schiller Park investigation play out? Why did you
3 Detective Martin that he couldn't find a prosecutor 3 go ahead and contact Richard Devine in early May of
4 to talk to him about this. And so I said I would 4 2006?
5 take a chance and let -- see if we can -- I'd 5 A Schiller Park Police Department was
6 write a letter to Dick Devine to see if he could 6 having difficulty getting someone to listen to them
7 find someone who would be interested in working 7 at the Attorney -- State's Attorneys office to
8 with the law officers in prosecuting. 8 secure a prosecutor.
9 Q What did Detective Martin tell you when 9 From what I was told, once you arrest
10 he told you he couldn't find a prosecutor to talk 10 someone, you have so many days to get a prosecutor,
11 to about the case? 11 otherwise it is null and void. And that's what he
12 A He basically said that computer 12 was running into is nobody wanted to hear the
13 tampering was so brand new. We were the first case 13 case.
14 in Cal -- Illinois, that no one -- even though 14 Q At the time you contacted Richard Devine
15 there were laws, nobody knew how to enforce them. 15 for the first time about the Save a Life computer
16 There was nothing to base anything on. So I just 16 issues, no arrest had been made; is that correct?
17 volunteered to write Dick Devine and see if he 17 A I believe that Ms. Melongo had been
18 could help. 18 arrested by that time.
19 Q Did Detective Martin ask if you would 19 Q How do you know Richard Devine?
20 contact Richard Devine? 20 A Through my work.
21 A No. He really just -- no. No. 21 Q When did you first meet him?
22 Q You volunteered? 22 A I cannot say when I first met him. I
23 A Yeah. 23 cannot say when I first met him.
24 MR. NINFO: Is that a yes? 24 Q Did you consider Mr. Devine a personal
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1 friend of yours? 1 was with -- I don't know.
2 A No. He was a business friend. 2 Q It says, keeping close tabs on progress.
3 Acquaintance. 3 Were you saying that the Attorney General and Dick
4 MS. BROWN: A what, I'm sorry? 4 Devine were keeping close tabs on the progress?
5 THE WITNESS: A business acquaintance. 5 A I am trying to remember back to this.
6 By Ms. Schwartz: 6 By reading it over and over again, I don't remember
7 Q I'm showing you Plaintiff's Deposition 7 this whole thing. (Examining document.)
8 Exhibit -- 8 Q Did you ever contact the Illinois
9 MR. NINFO: 4. 9 Attorney General about the Save a Life Foundation
10 MS. SCHWARTZ: -- 4. Spizzirri 000000514. 10 computer-related issues in May or April of 2006?
11 The zeros are very important. 11 A No, I did not, but I know that the
12 (A document was marked Plaintiff's 12 State's Attorney did because they needed some
13 Deposition Exhibit No. 4 for 13 forensic help. This was all brand new to them.
14 identification.) 14 I think what that meant, I think what
15 By Ms. Schwartz: 15 that meant was Detective Martin was here today.
16 Q Ms. Spizzirri, is Exhibit 4 an email you 16 That's it. Attorney General and State's Attorney
17 sent to Brian Salerno, Don Peters, and Vince Davis, 17 would have been working together. Devine is a
18 and Robert Barnes dated May 17, 2006? 18 personal friend. Keeping close tabs on progress.
19 A It appears to be. 19 Please keep all documents available. Other than
20 Q Is it a true and accurate copy of an 20 that, I don't remember anything.
21 email that you sent on that date? 21 Q You testified that the State's Attorney
22 A It appears to be. 22 did contact the Attorney General or the Attorney
23 Q I turn your attention you say, 23 General's office?
24 Dear Brian and Don - Update - Det's here today - 24 A State's Attorney had contacted the
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1 attyG and State Atty (Dick Devine is a personal 1 Attorney General's office from what I was told.
2 friend) - keeping close tabs on progress. 2 Q Who told you that?
3 Did you tell Salerno and Peters that 3 A Detective Martin because they were all
4 Dick Devine is a personal friend of yours? 4 working together. Trying to figure out how this
5 A I wrote it there, but we never went out 5 computer stuff worked. They reached out to the
6 together. It was all -- my company was my family. 6 Attorney General because he knew more than they
7 Everybody from Springfield out was my family 7 did.
8 because I had a mission to do, and that was to 8 Q Detective Martin told you that Schiller
9 change laws and do my work. So I considered 9 Park reached out to the Attorney General's
10 everybody part of my life my family. 10 office?
11 Q Why did you call Dick Devine a personal 11 A Uh-uh. Attorney General -- State's
12 friend in Exhibit 4? 12 Attorney reached out to the Attorney General's
13 A Because like I said, every -- every, 13 office because they knew they had a forensic person
14 even though it was -- my business was my family. I 14 there because they knew more than the State's
15 spent my whole life in -- I was on a mission. And 15 Attorney back in 2006 knew.
16 so anybody that was part of my Save a Life was my 16 Q Did Detective Martin or anyone else tell
17 family. So that's why I considered everybody my 17 you who at the State's Attorney office reached out
18 personal friend. I didn't have any other life 18 to the Illinois Attorney General's office?
19 outside of work. 19 A No.
20 Q In this email Exhibit 4, you say, AttyG, 20 Q Was it Richard Devine to your
21 does that refer to Attorney General? 21 knowledge?
22 A It may -- (examining document.) It 22 A No. It would have been the State's
23 would not have been because the Attorney General 23 Attorney, the prosecutor himself. If it was Bob,
24 was not at the office. It may have meant that I 24 I don't know. If it was someone else, but it
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1 was the prosecutors that were working with 1 matter to your attention, but both Mayor Rita
2 Detective Martin to reach out to the 2 Mullins and I felt it necessary since the following
3 Attorney General's office for help. 3 has caused irreversible damage to SALF."
4 Q You write in Exhibit 4, keeping close 4 Who is Rita Mullins?
5 tabs on progress. Did Richard Devine tell you he 5 A She was the Mayor of Palatine and she
6 was keeping tabs on progress? 6 was on our Board.
7 A No. 7 Q She was on Save a Life's Board?
8 Q What did you mean by that, "keeping 8 A Yes.
9 close tabs on progress"? 9 Q Did you speak with Ms. Mullins about
10 MR. NINFO: Objection; asked and answered. 10 this letter, Exhibit 5, before sending it?
11 THE WITNESS: I believe I was going to keep 11 A I don't recall.
12 close tabs on progress. 12 Q If you turn to the third paragraph of
13 By Ms. Schwartz: 13 Exhibit 5, the second sentence. It states:
14 Q How did you first meet Mr. Devine? 14 "Since Ms. Melongo had knowledge to all our
15 A I think I mentioned before that it 15 passwords our Web Designer Mr. Christian Sass
16 was -- it would have been on business. We may 16 immediately changed as many passwords he knew to
17 have met at a conference because I did deal very 17 secure entry into our system from the outside, but
18 closely with law enforcement. Had to get their 18 failed to remember our DSL line and Web/email
19 approval for them to understand why they would 19 sites."
20 support the legislation rather than oppose it. 20 What did Christian Sass do with respect
21 Q How often did you see Richard Devine 21 to the passwords after Ms. Melongo's termination?
22 around 2006? 22 MR. WUNDER: Objection; speculation.
23 A I totally saw him throughout my stance 23 MR. NINFO: Join.
24 with Save a Life maybe four - 3 times. 24 THE WITNESS: I wouldn't know.
129 131

1 Q Three times ever? 1 By Ms. Schwartz:


2 A Ever. Once was at a funeral. 2 Q He didn't tell you anything about
3 (A document was marked Plaintiff's 3 that?
4 Deposition Exhibit No. 5 for 4 A I wouldn't have had known if he told me.
5 identification.) 5 Q He must have told you something as you
6 By Ms. Schwartz: 6 included it in this letter that you wrote --
7 Q I am handing you Plaintiff's Deposition 7 A Right.
8 Exhibit No. 5. Bates numbered Attorney General 8 Q Do you remember --
9 000656. 9 A As far as the passwords I don't know if
10 Is Exhibit 5 a true and accurate copy 10 it changed. What more he did to it. He said he
11 of a letter you sent to Richard Devine on May 8, 11 changed passwords, but, as far as the DSL line,
12 2006? 12 that's a different, totally different story.
13 A It does -- I believe so. 13 It could be in-house passwords. I don't
14 Q It is addressed Dear Honorable Devine, 14 know as far as how many passwords.
15 but then Dick is in handwriting. 15 Q Do you know, apart from what is written
16 Is that your handwriting? 16 in Exhibit 5, what do know about what Mr. Sass did
17 A Yes. 17 related to the DSL line, the passwords, or anything
18 Q How did you come to be on a first name 18 else?
19 basis with Richard Devine? 19 A You know, it's been so many years. I
20 A I called everybody by their first name. 20 can only remember so much. I don't remember this.
21 Even the senators. They put the pants on the same 21 Q In the 5th paragraph of Exhibit 5, you
22 way I do. 22 write: "May 2nd, several employees alerted me that
23 Q You write in the first sentence of 23 they received a disturbing email from Ms. Melongo.
24 Exhibit 5, "It is unfortunate I need to bring this 24 Her email indicated she was responding to an
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1 emailed I sent to Brian Salerno, Pres. True 1 sheet?
2 Consulting that had been forward to her." 2 A Yes.
3 Which employees told you that they had 3 Q Is this a fax cover sheet for a fax you
4 received a disturbing email from Ms. Melongo? 4 sent dated May 8, 2006 to Richard Devine?
5 A Everybody that was listed on the CC of 5 A Yeah. Yes.
6 that email, which I was not connected to. 6 Q And the pages are a bit out of order.
7 Q What did they say to you? The employees 7 A Uh-huh.
8 when they told you about the email they received? 8 Q But it appears that the remainder is the
9 MR. NINFO: Objection; asked and answered. 9 contents of that fax; is that correct? Each page,
10 THE WITNESS: I mentioned before that they 10 if you flip it upside down, says Save a Life
11 brought it to my attention that they received this 11 foundation.
12 email from Annabel. And I was unaware at the time. 12 A Yes.
13 Then Christian Sass sent me the email after he did 13 Q Is this a fax sent out of Save a Life
14 his IP searching and then forwarded it to me. 14 Foundation's fax machine to Richard Devine?
15 By Ms. Schwartz: 15 A Not -- oh, the 312 is where Save a Life
16 Q Do you recall anything about the 16 was going, correct? Because that's not our phone
17 conversations with the employees who were cc'd on 17 number.
18 that email from Ms. Melongo? 18 Q So we are looking at Exhibit 6 upside
19 A I was shocked. I was totally shocked 19 down each page. It says Save a Life Foundation --
20 when he told me they received an email I sent to 20 A Yes. Yes, that's right.
21 someone else. That was sent to them from Annabel 21 Q And an arrow and the number 312 --
22 and what she said on that Annabel as retaliation. 22 A Uh-huh.
23 Q My question is simply do you remember 23 MR. NINFO: Don't talk over her.
24 anything about the conversations you had with the 24
133 135

1 individuals from Save a Life that were copied on 1 By Ms. Schwartz:


2 the email from Ms. Melongo? 2 Q The number 312.814.8283. Do you
3 A No. 3 recognize that phone number?
4 Q Dated May 1, 2006? 4 A I recognize it only because it's listed
5 A No, I do not. 5 here on the direct fax line to Dick Devine.
6 Q The next sentence you write on 6 Q Ms. Spizzirri, is pointing to the page
7 Exhibit 5, May 4th we contacted our web and email 7 marked Attorney General 001204. So this appears to
8 provider, WebHSP in Colorado, who was able to 8 be the contents of a Fax that was sent from the
9 footprint Ms. Melongo's actions from entry into 9 Save a Life fax machine to a number associated with
10 SALF's email system through snail mail by using my 10 Richard Devine; is that correct?
11 password, retrieve and forward two of my personal 11 A That's correct.
12 emails to her account and then email back to 12 Q And are these -- if you flip through
13 several of our employees with a personal message. 13 this document, Exhibit 6, are these the enclosures
14 A Okay. There is attachment here. Did 14 that you included with your May 8, 2006 letter?
15 you receive the attachment? 15 A Yes.
16 Q I will show you what I am identifying as 16 MR. WUNDER: Julia, do we have 1 through 15.
17 Plaintiff's Deposition Exhibit 6, attorney General 17 I notice on the top it says -- it starts with 16 on
18 001198 to 1205. 18 the first. It goes through 23. Do you see it?
19 (A document was marked Plaintiff's 19 Hold it up side down here.
20 Deposition Exhibit No. 6 for 20 MS. SCHWARTZ: Yes. Yes. I do see.
21 identification.) 21 I don't know the answer to that off of
22 By Ms. Schwartz: 22 the top of my head.
23 Q Ms. Spizzirri, if you flip to the second 23 MR. WUNDER: Okay.
24 last page of Exhibit 6 you will see a fax cover 24
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1 By Ms. Schwartz: 1 Q And if we need to consult some of the
2 Q What I -- my understanding we are 2 enclosures in Exhibit 6, we can do that.
3 looking at -- and Ms. Spizzirri, I will direct this 3 My question to you had been related to
4 as a question to you actually. 4 the sentence in Exhibit 5 about contact on May 4,
5 If we are looking at the fax cover sheet 5 to WebHSP in Colorado. So my question that I asked
6 Attorney General 001204. It states, that this fax 6 is what is WebHSP?
7 was nine pages. The fax you sent to Richard 7 A They were our hosting site, which took
8 Devine; is that correct? 8 care of our emails also.
9 A It says nine. 9 Q When you say, "hosting site," what do
10 Q This what we have here is 8 pages. 10 mean by that?
11 There may have been one additional page; is that 11 A Website, emails.
12 correct? 12 Q In Exhibit 5, you write that someone
13 A It may have been. I had a -- my front 13 from WebHSP footprinted Ms. Melongo's actions.
14 desk would do the cover sheets. So she may have 14 What does "footprinted" mean?
15 done a typo. 15 A That's the words that I learned. I
16 Q But generally speaking, were these were 16 didn't know what it was, but, according to Sass,
17 enclosures in the fax that you sent to Richard 17 that's why I asked for the attachments. That is
18 Devine? 18 how he was able to contact WebHSP, to track who got
19 A It appears to be. 19 into our, how the email was sent. He didn't do it
20 Q Do you know if there were additional 20 himself. He went to WebHSP to follow the track on
21 documents you sent to Richard Devine? 21 how we got this email.
22 A I do not. 22 Q What page of Exhibit 6 are you pointing
23 Q If you turn to the last page of 23 to right now?
24 Exhibit 6. That's a copy of your letter to Richard 24 A I'm sorry.
137 139

1 Devine, the same letter we have just been 1 Q You're pointing to an email on Exhibit 6
2 discussing that is also Exhibit 5? 2 with enclosures.
3 A Yes, ma'am. 3 A Yes, I'm sorry. I'm sorry. Yes. Okay.
4 Q And the rest apart from the fax cover 4 That would have been --
5 sheet what appear to be email printouts, correct? 5 Q If you look at --
6 A It does appear to be email printouts. 6 A -- 1 of 3.
7 Q On the fax cover sheet it says, Jinx 7 MR. NINFO: No.
8 Kotowski is listed. Who is Jinx Kotowski? 8 By Ms. Schwartz:
9 A I do not know that person, but 9 Q If you look at the bottom right hand
10 apparently I was given that name to send this to. 10 corner.
11 Q Did you call Mr. Devine's office prior 11 MR. NINFO: That is okay. Give her that.
12 to sending this fax. 12 THE WITNESS: Attorney General 001201 and
13 A I may not have. 13 Attorney General 001202, and Attorney General
14 Q How did you discover that Ms. Kotowski 14 001203.
15 was the person to or Mr. Kotowski was the person to 15 By Ms. Schwartz:
16 send a letter to Richard Devine to -- 16 Q That's the email that you were
17 A My assistant. My front desk girl may 17 testifying about which is the footprint that
18 have called to find out who to fax to. 18 Christian Sass performed?
19 Q But you don't recall any communication 19 A Yes, ma'am.
20 prior to sending this fax and letter? 20 Q Who at WebHSP was involved in
21 A No, ma'am. 21 footprinting Ms. Melongo's actions as you stated in
22 Q So let's turn back to Exhibit 5, which 22 Exhibit 5?
23 we were discussing. 23 MR. NINFO: Objection; speculation.
24 A Okay. 24 THE WITNESS: One of their techs.
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1 By Ms. Schwartz: 1 they -- it was two times that they -- she went to
2 Q Do you know the name of that person? 2 the courthouse twice. That's all I remember. I
3 A No, ma'am. 3 don't remember when I went and filed the police
4 Q Turn down -- I'm now back on Exhibit 5. 4 report for the warrant.
5 A Uh-huh. 5 Q Didn't you file a police report in late
6 Q If you turn to the second to last 6 October of 2006 months after this email was sent?
7 paragraph. 7 A I don't remember.
8 A Okay. 8 Q But as of when you sent this letter to
9 Q You write: This afternoon I and my 9 Richard Devine May 8, 2008, you did know of
10 staff received another lengthy email from 10 Ms. Melongo's citizenship --
11 Ms. Melongo. Apparently she is not satisfied with 11 A Apparently --
12 our lack of response. 12 Q Citizenship status?
13 What was the email Ms. Melongo sent you 13 A Apparently I did.
14 and your staff on May 8, 2006? 14 MR. NINFO: I told her let her finish her
15 A Turning back to Exhibit 6, Attorney 15 question.
16 General 001198. I may have been wrong. That's -- 16 THE WITNESS: I must have been wrong. I
17 maybe this afternoon -- maybe that's the page 17 really can't. The dates are so, you know,
18 that's missing. Because this is May 8th. The one 18 everything is together. I can't remember.
19 I thought he meant was April 26, but it says this 19 By Ms. Schwartz:
20 afternoon. So that might be missing. 20 Q How did you learn that Ms. Melongo was
21 Q You believe that was attached as an 21 not a U.S. citizen?
22 enclosure? 22 A It had to be told to me by someone else.
23 A Must have been. Because it's not 23 I wouldn't have had any knowledge.
24 here. 24 Q Why did you include in this letter to
141 143

1 Q Do you recall what the email from 1 Richard Devine, Exhibit 5, that Ms. Melongo is not
2 Ms. Melongo on May 8, 2006, said generally? 2 a U.S. citizen, but has a student Visa from
3 A I'd only be guessing. No, I cannot, but 3 Cameroon?
4 according to what is written here it was 4 A Because the student Visa was an
5 disgruntled. It wasn't happy. 5 education Visa and she no longer attended college
6 Q Don't you think it would be odd for 6 or schooling. And she had -- so that's the only
7 Ms. Melongo to continue to contact you if she had 7 reason that I brought it to his attention that,
8 been the one responsible for the alleged intrusion 8 that back in 2006, when you didn't have
9 and email forwarding? 9 credentials, you weren't supposed to be working
10 MR. NINFO: Objection; speculation. 10 for places like me.
11 THE WITNESS: I can't -- I can't -- I don't 11 And I didn't want to get caught for
12 know what Ms. Melongo was thinking. 12 something that I didn't know and break the law.
13 Q In the next sentence of Exhibit 5, you 13 Because at the time, it was a Federal offense if
14 write, "Ms. Melongo is not a U.S. citizen but has a 14 I didn't report someone that didn't have a green
15 student Visa from Cameroon, Africa and lives in 15 card, whatever. I mean, even people, men, in
16 Palatine which all concerns Mayor Mullins." 16 particular that had child support, I had to report.
17 A Yes. 17 So I just wanted to make sure that I was covered.
18 Q You testified earlier that you didn't 18 Q So this Exhibit 5 was you're reporting
19 know about Ms. Melongo's citizenship until she was 19 it to law enforcement to try to cover your --
20 arrested. 20 A Yes. It wouldn't -- because I didn't,
21 A Well, it must have been about that time 21 you know, even though I didn't employ her. Robert
22 that she was arrested because wasn't she arrested 22 Half did. I didn't know if there was going be
23 about May in 2006? That's the first time. She was 23 repercussions because I didn't report.
24 arrested twice or she was -- it was two times that 24 Q Did you think that Ms. Melongo was
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1 breaking the law by working on a student visa when 1 Q Were you trying to encourage Mr. Devine
2 you wrote Exhibit 5? 2 to think Ms. Melongo was a flight risk by
3 A No. I thought I might be breaking the 3 highlighting her immigration status in your letter
4 law because I didn't report it. 4 to him?
5 Q Why did you write in that sentence I 5 A Well, at the time I didn't understand.
6 just read, "Ms. Melongo is not a U.S. citizen but 6 I certainly didn't want him to know that she was --
7 has a student Visa from Cameroon, Africa and lives 7 that was a different situation completely as far as
8 in Palatine which all concerns Mayor Mullins" 8 being a flight risk. Because they did confiscate
9 Why did you write that it concerns Mayor Mullins? 9 when they arrested her, confiscated her passport.
10 A Because we were having other problems at 10 But at the time I was reading -- writing this, it
11 the same time and because Rita was the Mayor and 11 had no bearing on me that she would do that.
12 she didn't -- we had problems with this that she 12 MS. SCHWARTZ: Now, is a great time to break
13 didn't want to get involved. 13 for the lunch. So let's break here.
14 She just had that Boston -- Brown's 14 THE WITNESS: Okay.
15 Chicken Massacre. She didn't want more press into 15 MS. SCHWARTZ: Let's go off the record.
16 Palatine. That there was going to be any 16
17 repercussions with this. 17 (A lunch recess was had until
18 They had to -- Detective Martin couldn't 18 1:15 p.m. this day, May 11,
19 cross out of Schiller Park without permission to go 19 2018.)
20 into Palatine to look into, talk to Annabel without 20
21 the Police Department being notified first. 21
22 So they had to get permission from the 22
23 County first and then because they are coming into 23
24 a different jurisdiction. And they had to notify 24
145 147

1 Palatine. 1 IN THE UNITED STATES DISTRICT COURT


NORTHERN DISTRICT OF ILLINOIS
2 So she didn't want her police department 2 EASTERN DIVISION

3 to question why are the Schiller Park coming into 3 ANNABEL K. MELONGO, )
)
4 talk about Save a Life here. 4 Plaintiff, )
) Case No.
5 So they all had to be notified. So she 5 vs. ) 13-CV-04924
)
6 just didn't want anymore problems in her community. 6 ASA ROBERT PODLASEK, et al., )
)
7 Q And this says that the fact that 7 Defendants. )

8 Ms. Melongo was not a U.S. citizen was something 8


1:28 p.m.
9 that concerned Mayor Mullins. Why did that fact 9 180 North LaSalle Street
Suite 3600
10 concern Mayor Mullins? Did she tell you anything 10 Chicago, Illinois

11 about that? 11
The deposition of CAROL SPIZZIRRI, resumed
12 A Again she was on our Board, and if we 12
13
pursuant to a lunch recess.
13 were going to be breaking the law by not reporting APPEARANCES:
14 this sooner, she just was concerned that everybody 14
Ms. Julia K. Schwartz
15 was aware that -- we didn't know that we didn't 15 Miller Shakman & Beem, LLP
jschwartz@millershakman.com
16 file our side and we are just bringing it to his 16 on behalf of the Plaintiff;

17 attention. 17
Ms. Kimberlly M. Foxx, State's Attorney of
18 If there was something else that we 18 Cook County Illinois, by:
Ms. Bianca Brown
19 needed to do, we didn't want to make it. Things 19 Assistant State's Attorney
bianca.brown@cookcountyil.gov
20 were different back then than they are now. We had 20 on behalf of all Cook County Defendants;

21 different rules that we had to follow. Especially 21


Mr. Christopher S. Wunder
22 the type of people we -- I associated with. So I 22 Kaplan Papadakis & Gournis, P.C.
cwunder@kpglaw.com
23 didn't want to bring any law enforcement, red 23 on behalf of Defendant William Martin
and the Village of Schiller Park;
24 flags. 24
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1 APPEARANCES: (continued) 1 A Just because it was computer related.
2 Ms. Lisa Madigan, Attorney General, State 2 We didn't want any -- any confusion.
of Illinois, by:
3 Ms. Shirley R. Calloway 3 Q What do you mean by that?
Assistant Attorney General
4 Office of the Attorney General 4 A How can I say it. We didn't want any
scalloway@atg.state.il.us
5 on behalf of Defendant Kyle French; 5 things leaving the office or any kind of viruses or
6 Ms. Dina M. Ninfo 6 anything connected to somebody else's stuff on our
Angelini, Mills, Woods & Ori Law
7 Chicago, Illinois 60601 7 stuff. Because we had experienced it once where
dnifro@amwolawil.com
8 on behalf of Defendant Ms. Carol 8 there was some virus that was connected and it got
Spizzirri.
9 9 into our server and so we had a little problem with
10 Also Present: 10 that, but it didn't rectify. So we didn't want
Ms. Annabel Melongo - via the telephone
11 11 other people to bring their own things in.
12 12 Q You testified this morning about
13 13 something called the Brown's Chicken Massacre?
14 14 A Yes.
15 15 Q That was a concern of Mayor Mullins at
16 16 the time that you contacted Richard Devine, around
17 17 May 8, 2006; is that correct?
18 18 A Yes, only because it was such a horrible
19 19 black mark on Palatine. And she -- she didn't
20 20 discuss her -- even though she was a head of the
21 21 Police Department there as a mayor, she didn't
22 22 want any confusion that there was anything that
23 23 she was involved with as a mayor that was not, that
24 24 would put a bad light on Palatine.
149 151

1 CAROL SPIZZIRRI, 1 Q What was the Brown's Chicken Massacre?


2 called as a witness herein, having been previously 2 It was a mass homicide that occurred in the early
3 duly sworn, was examined and testified further as 3 '90's; is that correct?
4 follows: 4 A Yeah. Yes, it was. They didn't
5 EXAMINATION (Continued) 5 discover until 2002 who the people were who did the
6 By Ms. Schwartz: 6 killing because of DNA.
7 Q I just wanted to follow up on a few 7 DNA was brought in in 2002 and they were
8 points we discussed this morning, Ms. Spizzirri. 8 able to find the murders.
9 To your knowledge was Detective Martin 9 Q What was the connection between to your
10 involved in any recovery efforts related to Save A 10 knowledge between Ms. Mullins concern over the
11 Life Foundation after the alleged deletion after 11 Brown's Chicken Massacre and the issue Save a Life
12 April 28th, 2006? 12 was having in May, early May 2006?
13 A I would say no, but I am not sure how 13 A She was an elected official. By this
14 much he knew. I think he was there monitoring. 14 time we were already getting -- we were getting
15 Q Related to Ms. Melongo's employment when 15 Peter Heimlich and others with their blogs. And
16 she was working at Save A Life Foundation, did 16 they were saying bad things about Rita. And its
17 Ms. Melongo regularly bring her laptop into work 17 would affect her election again.
18 when she worked at Safe A Life Foundation? 18 So she just was concerned about her
19 A Not to my knowledge. I think I seen her 19 reputation and there was some false accusations
20 with it once, but not -- because we didn't want her 20 that were posted on some websites. She was part of
21 to do that because then it becomes our property 21 it. And they posted some nasty things about her.
22 too. 22 Q We just had been discussing prior to the
23 Q What do you mean when you say, "it 23 break, your letter to Dick Devine dated May 8.
24 becomes our property too"? 24 2006?
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1 A Yes. 1 a prosecutor as he had problems with in the past.
2 Q Which we looked at Exhibit 5 and 2 Q You say verify his concerns, what do
3 Exhibit 6. 3 mean?
4 Did you speak to Richard Devine after 4 A He was having difficulty as I said
5 you sent May 8, 2006, letter? 5 before trying to find a prosecutor to prosecute the
6 A I did not speak with him at all after. 6 case because it was such a new item.
7 Q Did you speak to anyone in Richard 7 Q What were you trying to show him by
8 Devine's office in the weeks after you sent this 8 sending these letters?
9 May 8, 2006, letter? 9 A Just that it is being followed through.
10 A I do not believe I did, at any time. 10 That his basic request, his concerns were going to
11 Except Bob. I mean, the people that were involved 11 be addressed.
12 with the case. That's it. 12 Q Let's turn to the first page of
13 Q Was that shortly after you sent the 13 Exhibit 7, which is a letter dated May 9, 2006,
14 letter, or many months after you sent the letter to 14 from Richard Devine to you. Is this a letter that
15 Dick Devine that you first spoke to Bob Podlasek or 15 Richard Devine sent in response to your May 8th,
16 someone else related to Ms. Melongo's case from the 16 letter?
17 State's Attorney's office? 17 A It appears to be.
18 A I don't know how long it was, but it was 18 Q And in it he writes, "I am forwarding
19 when Bob picked up the case he notified me that he 19 your correspondence to Randy Roberts, Executive
20 was going to be the prosecutor. That's all I know, 20 Assistant to the State's Attorney, for his review."
21 remember. 21 Is that what you were referencing when
22 Q To your knowledge did Richard Devine or 22 you said it is being followed through?
23 anyone in his office contact Vince Davis after you 23 A Yes, ma'am.
24 sent the May 8, 2006 letter? 24 Q What happened in relation to the
153 155

1 A No. 1 involvement of the State's Attorney office after


2 Q No, you don't know or no there was no 2 you received this letter from Richard Devine the
3 contact? 3 first page of Exhibit 7?
4 A I don't know. 4 A It was really out of my hands at that
5 (A document was marked Plaintiff's 5 point.
6 Deposition Exhibit No. 7 for 6 Q Were you aware Richard Devine called
7 identification.) 7 Detective Martin?
8 By Ms. Schwartz: 8 A No.
9 Q I am handing you Plaintiff's Deposition 9 Q You never heard --
10 Exhibit No. 7, which is CCSA 000185 to 187. 10 A No.
11 Exhibit 7, appears to be a fax in 11 Q -- Richard Devine called
12 reverse order. Pages are printed out in reverse 12 Detective Martin?
13 order. If you can trun to the last page. It 13 A No.
14 is a cover sheet dated May 26, 2006 from you to 14 Q You testified earlier this morning about
15 Detective Martin. And the other two pages are two 15 the Illinois Attorney Generals office. You said
16 letters to and from Richard Devine between you and 16 you had not contacted anyone in the Illinois
17 Richard Devine. Is this a true and accurate copy 17 Attorney Generals office about the Save a Life
18 of a fax that you sent to Detective Martin 18 Foundation computer issues in May or April 2006; is
19 containing your correspondence with Richard 19 that correct?
20 Devine? 20 A As far as before the prosecution, after,
21 A It appears so. 21 when?
22 Q Why did you send these two letters to 22 Q In April or May of 2006?
23 Detective Martin? 23 A No. No. I don't believe so.
24 A To verify his concerns that he could get 24 Q Apart. Pardon me.
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1 Apart from your contact with Richard 1 know what date. And I was with Mayor Mullins at
2 Devine that we have discussed, did you contact any 2 the time. She had a meeting with him.
3 other law enforcement officials about the 3 So I do not know if that was part of the
4 Illinois -- excuse me. 4 topic or not and I don't know what year it was.
5 Did you contact any other law 5 Q What was the reason for the meeting with
6 enforcement officials about the alleged intrusion 6 you and Richard Devine and Mayor Mullins?
7 in the Spring or Summer of 2006? 7 A I'm sorry, I don't remember.
8 A I would not remember. I would not 8 (A document was marked Plaintiff's
9 remember, if I did or not. 9 Deposition Exhibit No. 8 for
10 Q You testified this morning, that you did 10 identification.)
11 not -- have not spoken to Randy Roberts; is that 11 By Ms. Schwartz:
12 correct? 12 Q I am handing you Plaintiff's Deposition
13 A Yes. 13 Exhibit 8, CCSAO 002197 and 2196. So these appear
14 Q Randy Roberts testified during his 14 to be in reverse order.
15 deposition -- 15 A Okay.
16 A Yes. 16 Q So we flipped the order. 2197 and
17 Q -- as part of this litigation about a 17 second page is 2196.
18 phone call he had with you in or around May 2006 18 Is this Exhibit 8 a true and accurate
19 after -- 19 copy of an October 2008 email exchange between you
20 A Okay. 20 and Tracy Hannan?
21 Q -- your correspondence with Richard 21 A It appears to be.
22 Devine. 22 Q If you turn to the second page of
23 Do you disagree with Mr. Roberts' 23 Exhibit 8.
24 testimony that there was a phone call in May or 24 Tracy Hannan writes that -- well, take a
157 159

1 around May of 2006? 1 step back.


2 A I have to be honest with you. I would 2 Is Tracy Hannan a man or a woman?
3 have -- I forgot, if he did. I don't remember. 3 A I don't remember Tracy.
4 Q So you don't remember anything? 4 Q Do you know was Tracy Hannan your lawyer
5 A No. 5 at the time?
6 Q About any call? 6 It says, at the bottom of the second
7 MR. NINFO: Let her finish. 7 page, Tracy Hannan, Wildman Harrold Allen & Dixon,
8 By Ms. Schwartz: 8 LLP, which is a law firm. Does that refresh your
9 Q You don't remember anything about any 9 recollection whether Tracy Hannan was a lawyer?
10 call with Randy Roberts? 10 A I am starting to remember, but I don't
11 A No, I do not. 11 know if it is a girl or a man. I'm sorry, but I'm
12 Q Or any other type of communication with 12 starting to remember this. This came up and this
13 Randy Roberts? 13 was not connected to -- this is when we got
14 A No, I do not. 14 involved with other things where we were getting
15 Q Would you dispute Mr. Roberts' testimony 15 attacked by Peter Heimlich. I don't remember.
16 that he did have a call with you about the case or 16 Q So turning your attention to Exhibit 8,
17 about the investigation into the Save a Life 17 second page. Tracy Hannan says that there was a
18 issues? 18 conversation between Tracy Hannan and
19 A I am sure he did and better records than 19 Detective Martin.
20 I, and I don't remember, and I don't dispute. 20 Do you know why Tracy Hannan was
21 Q Did you meet with Richard Devine in 2008 21 speaking to Detective Martin?
22 about Ms. Melongo's case or the computer issues at 22 A I'm trying to figure out who Tracy is.
23 Save a Life Foundation? 23 We had Tom DiCianni was our attorney for
24 A I know I went to his office. Do not 24 the ABC and Peter Heimlich lawsuit. I believe that
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1 I -- this was -- so many things were happening at 1 Does this refresh your recollection as
2 the same time. I was just trying to find some 2 to when you met with Richard Devine in or around
3 order in my life in our company. 3 2008?
4 Q If you read at the bottom of the second 4 A That would have been 2008. It could
5 page of Exhibit 8 it says, "Bill and I spoke 5 have been that same time that Ms. Mullins and I had
6 earlier to Detective Martin. He said that he has 6 a meeting with him that I mentioned before.
7 created supplemental police reports relating to the 7 Q Did the meeting with Richard Devine in
8 matter involving Annabel. He would not provide 8 or around 2008 have anything to do with
9 those to us, but would allow you to obtain copies. 9 Ms. Melongo?
10 Thus, could you request any and all reports 10 A It was not pertaining to -- that's why
11 relating to their investigation from him and send 11 we didn't set the case up for that, no. It had to
12 along copies to us." 12 do with Mayor Mullins work as a mayor.
13 A I knew I needed somebody with the 13 Q What was discussed during the meeting
14 Melongo case to represent my side before I found 14 with Richard Devine in or around 2008?
15 Don Angelini. And I was hoping that somebody 15 A I don't remember, but it had to do with
16 would be able because I knew attorneys, but none 16 municipal, municipal work. Something to do with
17 of them understood this. I might have been 17 her municipal work. I cannot remember.
18 researching for help. Because, Tom Angelini like 18 Q You do remember that it did not have to
19 I said, he was handling the lawsuit that I 19 do with Ms. Melongo?
20 previously discussed, so. But I can't remember. 20 A Right. I cannot swear that her name
21 Q Do you mean Tom DiCianni? 21 wasn't brought up, but it had -- the meeting was
22 A Tom DiCianni. I'm sorry, if I messed 22 not pertaining to her. It was pertaining to
23 up. But I cannot remember how far this went. It 23 Mayor Mullins' line of work that the meeting was
24 may have been where I am trying to get help for us. 24 even scheduled.
161 163

1 Q Was the help you were seeking 1 Q Do you recall any discussion of
2 information or representation about related to an 2 Ms. Melongo or the criminal case related to
3 issue you were having with Robert Half 3 Ms. Melongo during that 2008 meeting?
4 International? 4 A It's only speculation.
5 A Robert Half and ManPower. Because 5 MR. NINFO: Don't --
6 ManPower's temp had taken our files and given them 6 THE WITNESS: -- but if anything was brought
7 to ABC. They were work-in progress files. It was 7 up, I really wouldn't know for a fact what it was
8 illegal. 8 about.
9 We didn't know until he broadcast, Chuck 9 MR. NINFO: I'm going to advise you to only
10 Goudie broadcasted that he had our documents in his 10 testify to what you remember.
11 hand. And we knew right away, that the only person 11 THE WITNESS: Okay.
12 that would have had it was our temp from Manpower. 12 MR. NINFO: And not speculate.
13 So it was Manpower and Robert Half that 13 (A document was marked Plaintiff's
14 we were trying to figure out what happened and did 14 Deposition Exhibit No. 9 for
15 we need an attorney to deal with this or because 15 identification.)
16 DiCianni was already working on the other case. It 16 By Ms. Schwartz:
17 was so confusing back then. I can't remember who 17 Q I am going to hand you Plaintiff's
18 this person is. 18 Deposition Exhibit 9 CCSAO 000209 to 212.
19 Q If you turn to the first page of 19 Do you recognize Exhibit 9,
20 Exhibit 8. 20 Ms. Spizzirri?
21 A Yes. 21 A This is more of the follow through of
22 Q You write, FYI - while you were on the 22 what we discussed before with Christian Sass.
23 phone, Dick Devine's office called to schedule mtg. 23 Q This is one of the emails about which
24 Will find out tomorrow when. 24 you testified about this morning?
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1 A Yes. 1 A As long as we are on the same page.
2 Q Who is Shontay Grant. The name of 2 Q Same text that is in --
3 Shontay Grant is at the top left of Exhibit 9. Do 3 A Yes.
4 you know who Shontay Grant is? 4 Q -- one of the pages on Exhibit 6.
5 A Shontay Grant? Where is that, Dear? 5 A Yes. Page --
6 Q Top left, first page? 6 Q Attorney General 001200. So that text
7 A Top left. No. 7 that I just read --
8 Q You never heard the name Shontay 8 A Yes.
9 Grant? 9 Q -- you wrote that email to Brian
10 A No. 10 Salerno?
11 Q But below that is a copy, a printout 11 A Yes.
12 of an email from cspizzirri@salf.dot.org to 12 Q When you wrote think we found who, what
13 Melongo_annabel@yahoo.com dated May 1, 2016 at 13 did you mean by that?
14 7:31 p.m. It appears to be a forward of an email 14 A That would all be speculation. I'm not
15 correspondence between you and Brian Salerno; is 15 sure.
16 that correct? 16 Q You don't remember what you meant when
17 A It does appear to be. 17 you wrote that?
18 Q Did you or someone at Save a Life 18 A No.
19 Foundation provide this email, Exhibit 9, to the 19 Q Were you referring to think we found who
20 Schiller Park Police Department? 20 was involved in the April 28th, 2006 alleged
21 A More than likely. I believe it would 21 intrusion?
22 have been. I'm sure it would have been because 22 A Again it would be speculation. I can't
23 that is one of the things that we -- Christian Sass 23 really remember what --
24 had notified me. 24 Q You write, Annabel called X4 and stopped
165 167

1 Q What was one of the things that 1 in three - left message on my cell offering to fix
2 Christian Sass had notified you? 2 our problem.
3 A That is when he found, as I testified 3 Were those the phone calls you testified
4 before, when he did a -- contacted WebHSP to find 4 about this morning to your -- to your phones from
5 who sent that email back to Dave Stolerow. Oh, 5 Ms. Melongo on April 28, 2006?
6 Exhibit 6. When we discussed that. Because 6 A Yes.
7 Christian would have spoke with Detective Martin 7 Q In the message or any of the messages
8 regarding what he discovered from WebH -- WebHSP. 8 that Ms. Melongo left on that day, April 28, 2006,
9 Q So testifying just about what is in this 9 does she offer to help you fix Save a Life's
10 email exhibit. Directing you to what just is in 10 computer troubles?
11 this email, Exhibit 9. There is an email half way 11 A I really don't remember. All I remember
12 down the first page from you to Brian Salerno. 12 is that she called and I did not respond.
13 A Right. 13 I believe she left a message on my cell
14 Q Subject line RE: downed system. 14 phone once, and then she phoned the office also.
15 You write, "Think we found who Annabel 15 Q You write here in this email, in
16 called X4 and stopped in three - left message on my 16 Exhibit 9, that she left a message on my cell
17 cell offering to fix our problem. Very similar to 17 offering to fix our problem.
18 former IT who corrupted system." 18 A Uh-huh.
19 Do you see what I am reading? 19 Q The problem she was offering to fix was
20 MR. NINFO: Just listen. 20 Safe a Life computer issues; wasn't it?
21 THE WITNESS: Yes, I see. It's the same one 21 A I would assume that that was why she
22 as in Exhibit 6. 22 offered that.
23 By Ms. Schwartz: 23 Q If Ms. Melongo wanted to help fix the
24 Q Yes, it is the same text. 24 problem, doesn't that suggest she wasn't involved
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1 in creating that computer problem? 1 Q If you turn to the top of the page of
2 A No. 2 Exhibit 9.
3 MR. NINFO: Objection; speculation. 3 (A phone interruption was had.)
4 THE WITNESS: No. 4 By Ms. Schwartz:
5 By Ms Schwartz: 5 Q If you turn to the --
6 Q Did you accept any of Ms. Melongo's 6 A Okay.
7 offers to help fix the computer problems? 7 Q Mr. Salerno's response to your email,
8 A No. 8 also dated May 1, 2006 is "Wow...and still wow.
9 Q You write in Exhibit 9, very similar to 9 Why doesn't she just mail in a confession." What
10 former IT who corrupted system. What was very 10 did you understand Mr. Salerno to mean?
11 similar to a former IT? 11 A That he knew more than I did.
12 A The gentleman that I mentioned before. 12 Q What do you mean by that?
13 Cannot remember his name who took all of our 13 A Because he had been working on the
14 passwords. 14 computer trying to establish it. He's the one
15 Q Victor Rodriguez? 15 that told us that they found the IP address with
16 A Yes, ma'am. 16 Ms. Melongo's email address. So that's what I
17 Q So you're saying Ms. Melongo's actions 17 assumed they -- he knew more than I did.
18 were similar to Victor Rodriguez' actions? 18 Q So your understanding of Mr. Salerno's
19 A It was -- he also had said that he 19 email, that starts wow and still wow --
20 would, but under conditions. 20 A Yes.
21 Q He would what? 21 Q -- is that he thought Ms. Melongo was
22 A That he would fix our computers and give 22 involved in the April 28th --
23 us back our passwords, but under the condition that 23 A Yes.
24 we hire him. 24 Q -- 2006 --
169 171

1 Q So you were interpreting Ms. Melongo's 1 MR. NINFO: Let her finish.
2 conduct on the day she called four times and 2 THE WITNESS: Yes.
3 stopped in three to be similar to Victor Rodriguez' 3 By Ms. Schwartz:
4 past actions? 4 Q -- intrusion?
5 A Yes, because she also wanted a job, but 5 A Yes.
6 we couldn't come up with any financial 6 Q But you didn't think that at the time?
7 understanding. 7 A At the moment, I did not.
8 Q It says in this, very similar to former 8 (A document was marked Plaintiff's
9 IT who corrupted system. Were you saying that both 9 Deposition Exhibit No. 10 for
10 Ms. Melongo and Mr. Rodriguez had corrupted some 10 identification.)
11 system? 11 By Ms. Schwartz:
12 A No. What I was referring to is that 12 Q I'm handing you Plaintiff's Exhibit
13 when she left she was under the desire to have a 13 Deposition Exhibit 10, CCSAO 3415.
14 position with our company full time. And he also 14 Exhibit 10 contains some of the same
15 wanted a position full time. 15 content from Exhibit 9 that we just discussed. In
16 Q So your testimony is that this sentence, 16 the top half of the page appears to be an email
17 these sentences, Annabel called X4 and stopped in 17 from -- a printout of an email from Ms. Melongo to
18 three - left message on our my sell offering to fix 18 a number of what appear to be Save A Life
19 our problem very similar to IT who corrupted 19 employees. Subject: How far are you going to go,
20 system. 20 Carol.
21 Is it your testimony that this is not 21 Is Exhibit 10 one of the emails that was
22 meant to accuse Ms. Melongo of being involved with 22 provided to the Schiller Park Police Department by
23 the Save a Life intrusion on April 28, 2006? 23 Save a Life Foundation?
24 A That's correct. 24 A This first here shows that it was
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1 printed off from my computer, but that I did not 1 In the email, Ms. Melongo sent to a
2 get it. It wasn't emailed to me. But it was 2 number of your staff she says -- she calls you a
3 printed off of my computer. 3 pathological liar. And then she says at the very
4 Q How is it printed off of your computer 4 end, I do hope that you're still going to have your
5 if you didn't actually receive it? 5 trial with Robert Half, I will expose you.
6 A Because it had been sent to me from 6 What was the trial with Robert Half that
7 outside sources. If you see on the top here there 7 was going on around May 1, 2006, or was scheduled
8 is something else on the top, but it says from 8 to happen in the future?
9 Melongo to these people below who were my 9 A We never sued Robert Half.
10 employees, but nothing with my name on it. My 10 Q Safe a Life never sued Robert Half?
11 name should have been on here too. 11 A No, ma'am. We were in discussion with
12 That goes along with what Brian Sass 12 them in what had happened afterwards, but we never
13 had -- no Christopher Sass had sent me to begin 13 sued them.
14 with to let me know what everybody else had 14 Q What were you in discussion with Robert
15 received. 15 Half about?
16 Q So you are referring to? 16 A Well, they were aware of Annabel not
17 A 6. 17 leaving the office when she was told to leave.
18 Q That's on Deposition Exhibit No. 6? 18 And so they felt guilty that she got placed
19 A Yes. 19 there to begin with. So they reimbursed us for
20 Q At page -- 20 the time that we paid them to employ her through
21 A See right here it shows. There's a 21 them.
22 print off by David. David got his here. Christian 22 Q Robert Half reimbursed you for the
23 Sass sent it to me. 23 entirety of Ms. Melongo's employment through
24 MR. NINFO: One second. 24 Robert Half?
173 175

1 By Ms. Schwartz: 1 A Yes.


2 Q For the record, Ms. Spizzirri is 2 Q How much approximately was that?
3 referring to Deposition Exhibit 6, page Attorney 3 A That I can't -- I can't remember.
4 General 001200? 4 Q How long did Ms. Melongo work for Save
5 MR. NINFO: No. 1201. 5 A Life?
6 By Ms. Schwartz: 6 A December 2005 until April 20 whatever,
7 Q 1201, excuse me. 7 2006.
8 A Yeah. 8 MS. BROWN: Sorry, until April what?
9 Q So let's look at both of these -- 9 By Ms. Schwartz:
10 A Okay. 10 Q Pardon me?
11 Q -- exhibits together then. 11 MS. BROWN: Until April what?
12 So the first one, Exhibit 10, someone 12 By Ms. Schwartz:
13 forwarded to you this content, which was an email 13 Q 2006 you said?
14 Ms. Melongo sent to a bunch of your employees, but 14 A 2006.
15 you were not copied on that email, correct? 15 MS. BROWN: Okay.
16 A That's correct. 16 By Ms. Schwartz:
17 Q And then, Exhibit 6, page Attorney 17 Q When did Robert Half reimburse you for
18 General 001201, is an email you received from 18 Ms. Melongo's time from December 2005 to April
19 Christian Sass about the earlier email 19 2006?
20 correspondence? 20 A Must have been 2006.
21 A Yes. 21 Q Was it after May 1st, 2006?
22 Q So we will discuss that email from 22 A I can't -- I don't know.
23 Christian Sass in a moment, but first I wanted to 23 Q So when Ms. Melongo refers to trial with
24 ask you a few questions about Exhibit 10. 24 Robert Half, what did you understand her to mean by
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1 that? 1 A Did I provide this particular email to
2 A I was confused. I still am. 2 the detective?
3 Q She wrote, I will expose you. 3 Q I'm not referring to this particular
4 Did Ms. Melongo have information about 4 email Exhibit 10.
5 you that you didn't want to get out in the public? 5 A Yes.
6 A Absolutely not. 6 Q I'm referring to any email that was a
7 Q How did you feel when you learned 7 printout or copy of the email coming from your
8 Ms. Melongo had sent this angry email to a number 8 email account to Ms. Melongo's email account?
9 of your employees? 9 A Not to my knowledge. I can't remember.
10 A Well, all of my employees knew me. And 10 Q Let's turn back to Exhibit 6 that you
11 they knew how -- they sided with me. They didn't 11 referenced.
12 feel any negative against me. They were upset 12 A Uh-huh.
13 about Ms. Melongo doing that. Saying what she 13 Q Page marked Attorney General 001201,
14 said. 14 which is an email from Christian Sass to you dated
15 Q How did you feel about Ms. Melongo 15 May 1, 2006.
16 writing this email to your employees? 16 A Yes.
17 A I was upset because I -- I -- prior when 17 Q This is one of the emails you testified
18 she was in need, I stood up for her. So I was 18 about earlier today; is that correct?
19 confused. 19 A Yes.
20 Q Were you angry that Ms. Melongo sent 20 Q At the time you sent this appears to be
21 this email on May 1, 2006 calling you a 21 11:31 p.m. on May 1st, 2006?
22 pathological liar? 22 A Yes.
23 A I was hurt. 23 Q It says -- includes the copy of the
24 Q It's correct, is it not, you never 24 content of some of the emails we just discussed in
177 179

1 provided Detective Martin or anyone else a copy of 1 Exhibit 10.


2 any email forwarded from your account to 2 And then on the second page of that
3 Ms. Melongo's account on May 1, 2006? 3 particular email Attorney General 001202. Writes
4 MR. NINFO: Objection to form. 4 ps- following is the entire email with all headers
5 THE WITNESS: I'm sorry. I -- I didn't 5 and raw code.
6 provide him with this particular -- I would say it 6 Is this the part of the email you were
7 was a collaboration between my staff and Christian 7 referring that led to reference to a particular
8 Sass to have given him. I think he may have 8 IP address?
9 stopped over to the office and everybody kind of 9 A Yes, ma'am.
10 was upset that that occurred because we were a 10 Q What part of this email led to the
11 family. Anybody that talked negative about one 11 discovery of a particular IP address that was
12 person affected all of us. 12 relevant to determining Ms. Melongo's alleged
13 So I think it was a collaboration 13 involvement?
14 between all of us that they presented this to 14 MR. WUNDER: Just object as to speculation.
15 Detective Martin. 15 THE WITNESS: I --
16 By Ms. Schwartz: 16 MR. WUNDER: You can go ahead.
17 Q Your testimony was that this email, 17 THE WITNESS: I don't understand the -- any of
18 Exhibit 10, was forwarded to you by someone else. 18 this code at all, but apparently that's what was
19 My question is -- 19 given to him through WebHSP according to what was
20 A Yes. 20 written. I don't understand this.
21 Q -- did you ever provide Detective Martin 21 By Ms. Schwartz:
22 or anyone in law enforcement a printout of just an 22 Q It is your understanding this page was
23 email that was coming from your email account to 23 generated somehow by WebHSP?
24 Ms. Melongo's email account? 24 A Well, it says for csass@salf.org on
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1 May 1st, at 20:28:24-0500, so it had to, yeah. 1 By Ms. Schwartz:
2 Vipgeek. That is a geek squad type of organization 2 Q -- email forwarding issue?
3 that worked with HSP. So received from yahoo by 3 A I'm sorry.
4 server 2, vipgeek with smtp for Sass, received 4 He just told me that it was what he was
5 Gmail, DomainKey. So that would have been sent to 5 able to detect where that email actually came from.
6 him, and I wouldn't know anything more than that 6 Q And can you point me to where on this
7 Q So you were just reading on page 7 page it shows where an email from Ms. Melongo came
8 Attorney General 001202 content about a third of 8 from?
9 the way down that page. 9 MR. NINFO: Objection; speculation.
10 And your understanding is that the part 10 THE WITNESS: If you read on Attorney General
11 that says, Server2vipgeek.com has something to do 11 001201 it says, and I don't know what -- who signed
12 with WebHSP? 12 it here. It leads me to believe she was connected
13 A Yes, ma'am. 13 to the webmail interface. I will be reviewing all
14 Q How do you know that? 14 access logs and changing passwords tonight. So
15 A Because I know vipgeek was our 15 that is when he claimed that he was going to change
16 original -- they connected us originally. They set 16 the passwords on May 1st. As soon as I have more
17 up WebHSP with our business. Vipgeek then later on 17 information to report, you will be the first to
18 went out of business, but what they did was they 18 know.
19 were like the middle man between HSP, WebHSP and 19 I had assumed that she only had the
20 us. They connected our servers with WebHSP. 20 SALF.org and perrymedic.org. In response to this,
21 Q So if you look down on the page a little 21 I changed the root passwords on all accounts. This
22 bit more, this Exhibit 6 Attorney General 001202. 22 will be -- not affect your or other emails. I find
23 This information, headers and raw code appears to 23 it highly unlikely that someone actually forwarded
24 relate to an email from Ms. Melongo, Annabel 24 anything to her and will be investigating further.
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1 Melongo to a number of Save a Life individuals with 1 Sorry you're being put through all of
2 the subject line, how far are you going to go, 2 this. I will do my best to protect your interests.
3 Carol? 3 So I believe that came from Christian
4 A Yes. 4 Sass.
5 Q You're not included in one of the 5 Q That was part of the email Christian
6 recipients, correct? 6 Sass sent to you?
7 A That's correct. 7 A Yes.
8 Q This is an email that Ms. Melongo sent 8 Q She was referring to Ms. Melongo?
9 to Save a Life employees, correct? 9 A He was referring to Ms. Melongo.
10 A That's correct. 10 Q I'm sorry, the word she, that Christian
11 Q Apart from your testimony about the 11 Sass used in that text you just read referred to
12 vipgeek and its relationship to WebHSP, does 12 Ms. Melongo?
13 anything else about -- do you understand the 13 A Oh. Yes.
14 content of this page of Exhibit 6, attorney General 14 (A document was marked Plaintiff's
15 001202? 15 Deposition Exhibit No. 11 for
16 A Do I understand the content of this? 16 identification.)
17 Q Yes. 17 By Ms. Schwartz:
18 A I do not understand the codes here at 18 Q I'm handing you Plaintiff's Deposition
19 all. 19 Exhibit 11 CCSAO 000002 through 5.
20 Q Did Christian Sass ever explain to you 20 Exhibit 11 is an email from
21 why this page was important or relevant to the -- 21 Tsupport@gmail.com to you dated May 4, 2006; is
22 A He -- 22 that correct?
23 Q -- May 1st, 2006 -- 23 A Yes, ma'am.
24 (A telephone ringing.) 24 Q Have you seen this email before?
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1 A Not sure. 1 Q Did you ever ask who wrote those
2 Q Was this email sent to you in response 2 words?
3 to some inquiry you made? 3 A I don't believe I did.
4 A I would not have made the inquiry. I 4 Q Why not?
5 don't even know who technical support is. 5 A Because there was so much going on that
6 Q Do you know what technical support is? 6 I first thought it was coming from until now, I am
7 A It is very possible -- it has a Gmail 7 seeing this, I thought it was coming from Brian.
8 though. If it is WebHSP, I'm sure they would have 8 Q Did you give Exhibit 11 to the Schiller
9 had their own. So I don't know. Gmail is a 9 Park Police Department?
10 generic. Whereas with ours, we went through a 10 A I don't know if I did or if Vince did or
11 host. So we would have our own address name. 11 if Christian Sass did. I do not remember.
12 Where you have a Gmail it is more generic. So 12 Q To your knowledge did someone from Save
13 maybe it's somebody that is within the tech field. 13 a Life Foundation give Exhibit 11 to this Schiller
14 I don't know. 14 Park Police Department?
15 Q You don't have any -- do you know why 15 A I am sure they did.
16 you received this email on May 4, 2006, what it was 16 Q You did not ask who sent or wrote the
17 in response to? 17 tsupport@gmail.com email on May 4, 2006?
18 A Well, it is in response to 5-4-06, which 18 A No.
19 goes back to the same Christian Sass' May 1st, 19 Q Even though you gave it to Schiller Park
20 2006, which we just went with Attorney General 20 Police as evidence accusing Ms. Melongo of having
21 001201 Exhibit. 21 something to do with the alleged --
22 Q Exhibit 6? 22 A I did not --
23 A Where he contacts me and says, I noticed 23 MR. NINFO: Objection.
24 you were not a recipient to this email. So he 24
185 187

1 forwarded it to me. 1 By Ms. Schwartz:


2 Q So Exhibit 11 does include that email 2 Q -- intrusion on your email?
3 you received from Christian Sass that we have been 3 MR. NINFO: Hold on. You have to let her
4 discussing which is part of Exhibit 6. But then 4 finish before you talk.
5 the top half of the first page of Exhibit 7 appears 5 I will object on the form of the
6 to be from a new email account that we haven't yet 6 question. Use of the word evidence.
7 discussed tsupport@gmail.com? 7 THE WITNESS: I did not -- I had no clue. It
8 My question is do you know why you 8 was all -- that is why we got experts in so that
9 received this email from Tsupport@Gmail.com? 9 they fix the system. I had no clue how. I didn't
10 A No, I don't. 10 know who emailed or how it was done. If it wasn't
11 Q Do you know what the content of this 11 for them telling me, I wouldn't have had any other
12 email Tsupport@gmail.com means, this first page of 12 clue.
13 Exhibit 11, top half? 13 And Christian Sass took it on his own to
14 A Well, it says here this is the actual 14 contact our web host to see if they could find out
15 record showing her sending the email from Carol's 15 what was going on. So I just assumed that the tech
16 email address to her own yahoo-based email address. 16 support was our web host, but I noticed now that it
17 Note the IP in the log. And then it goes on 17 is a Gmail. And I don't think that was a tech
18 further. The rest I don't even understand. 18 support. It may have been. I don't know.
19 Again, second message going from Carol's 19 Q So Christian Sass contacted WebHSP?
20 address to her yahoo email address. So that is all 20 A Yes, ma'am.
21 it says that I can understand. 21 Q And you assumed this tech support gmail
22 Q But you don't know who wrote those 22 address related to WebHSP?
23 words? 23 A At the time, yes.
24 A No, ma'am. 24 Q But you didn't confirm that, correct?
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1 A No, ma'am. 1 A Yes.
2 Q Detective Martin testified that someone 2 Q So is this a listing of all items you
3 at Save a Life Foundation told him his 3 thought were cyber sabotage activities by
4 Tsupport@gmail.com email address was associated 4 Ms. Melongo?
5 with WebHSP. Did you tell Detective Martin that? 5 A Yes.
6 A No, ma'am. 6 Q And it is a true and accurate copy of a
7 Q Did Christian Sass generate this email 7 document you prepared?
8 Exhibit 11, the Tech Support, Tsupport@gmail.com 8 A Yes.
9 email? 9 Might I break for two seconds to go to
10 A I don't believe he did because it says 10 the ladies room?
11 here tech support to me. It must have come from 11 MS. SCHWARTZ: Why don't we take a five-minute
12 them directly to me. 12 break now.
13 Q Do you know if Christian Sass was 13 THE WITNESS: That will be fine.
14 Tsupport@Gmail? Did he use that email account? 14 MS. SCHWARTZ: Let's go off the record.
15 A Not to my knowledge. He was working for 15 (A recess was had.)
16 the other company, Brian's company. He would have 16 By Ms. Schwartz:
17 used that. Not his own. 17 Q Should we go back on the record?
18 (A document was marked Plaintiff's 18 A Go ahead. I think I found something.
19 Deposition Exhibit No. 12 for 19 Q What was the purpose of preparing
20 identification.) 20 Exhibit 12?
21 By Ms. Schwartz: 21 A To keep me -- so much was happening in
22 Q Handing you Plaintiff's Deposition 22 my life at the time. I was being hit by all sides.
23 Exhibit 12 CCSAO 002233. Do you recognize 23 I had to keep a record so I knew what was -- things
24 Exhibit 12? 24 were going on. And I tried to do the best record
189 191

1 A Yes, ma'am. 1 from what I was told by other people, which you had
2 Q What is Exhibit 12? 2 asked me some questions, and I couldn't understand
3 A It is a run down of what I was under the 3 where I found this out when I thought of that. And
4 impression that happened at the time. 4 it basically said right here on Exhibit AG1 --
5 Q At what time? 5 001201, May 1st, from Christian Sass. When he --
6 A Of the situation. I believe it was 6 Q Exhibit 6?
7 created October -- it started in October of 2005. 7 A When he was he responding trying to find
8 Q Then in the last entry appears to be 8 where that email came from.
9 August 27, 2008? 9 And it said in here, I noticed that you
10 A Yes. 10 weren't actually included as a recipient dah, dah,
11 Q Did you draft the content of 11 dah.
12 Exhibit 12? 12 From my initial observation the link in
13 A From my recollection. I was trying to 13 this email to your email address leaves an
14 keep a running memory of what was going on. 14 interesting breadcrumb. It links to the cpanel
15 Q So the dated entries were drafted around 15 interface.
16 the time of the date and then you would add to it 16 I don't know what that is.
17 as -- 17 But then he's got an address there where
18 A Yes. 18 it says, squirrelmail. I don't know what that is.
19 Q -- things happened? 19 This leads me to believe that she was
20 And are these all -- the title of this 20 connected through the webmail interface. I will be
21 document, Exhibit 12, is Robert Half International 21 reviewing all access logs and changing passwords
22 temporary employee, cyber sabotage activities by 22 tonight. As soon as I have more information to
23 Annabel K. Melongo between October 17, 2005 to 23 report, you will be the first to know.
24 present? 24 I had assumed that she only had the Save
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1 a Life or SALF.org and perrymedic.org. In response 1 Q When was that that Detective Martin came
2 to this I changed the root password on all 2 over?
3 accounts. This will not affect your other emails. 3 A It would have been around April 2nd,
4 I find it highly unlikely that someone actually 4 2009 -- 7.
5 forwarded anything to her and will be investigating 5 Q 2007.
6 further. 6 (A document was marked Plaintiff's
7 MR. NINFO: We already went over that. We are 7 Deposition Exhibit No. 13 for
8 on Exhibit 12. 8 identification.)
9 By Ms. Schwartz: 9 By Ms. Schwartz:
10 Q So that is Exhibit 6 that you just read 10 Q I'm handing you Plaintiff's Deposition
11 from. 11 Exhibit No. 13 CCSAO 002226 to 2227.
12 A Okay. So what I got out of this is 12 Exhibit 13 is a document titled Value of
13 that's when I was told it was assumed that Annabel 13 Damages Associated With Annabel Melongo. And then
14 had got into our website. 14 at the bottom it says, total 286 -- $2,806 --
15 It was, you know, that she was the 15 excuse me. $286,154.13.
16 intruder at the time. Because that's what I was 16 A Yes.
17 told by Christian Sass who was working with 17 Q Pardon me.
18 Brian. 18 That's the same number we just read for
19 MS. SCHWARTZ: Do you mind holding on one 19 damages on Exhibit 12, correct?
20 moment. I think our phone line got disconnected. 20 A No. Damages was the $2,886.00. 2,000
21 Take a brief pause. 21 not 200.
22 (A brief interruption was had.) 22 Q Oh, you're reading from the April 2,
23 By Ms. Schwartz: 23 2007 entry on Exhibit 12, 3rd page. You're
24 Q We were talking about Exhibit 12. And 24 referring to $2,886.00 related to the American
193 195

1 you testified that the purpose behind preparing 1 Express account, correct?
2 Exhibit 12 was to help you keep a record and keep 2 A That's one, but this --
3 track of what was going on. 3 Q My question for you --
4 If you turn to the third page of 4 MR. NINFO: Listen.
5 Exhibit 12, a little more half way down the page. 5 By Ms. Schwartz:
6 Damages attached and says receipt for damages 6 Q -- was on Exhibit 12.
7 totaled 286,154.13. What was the purpose of 7 MR. NINFO: She is pointing to down here.
8 calculating the ongoing damages or receipts for 8 THE WITNESS: Oh, I'm sorry.
9 damages by Annabel Melongo? 9 By Ms. Schwartz:
10 A It was assumed at the time that our 10 Q On the bottom it says, damages attached
11 credit card had been tampered with to that amount. 11 $286,154.13.
12 And it seemed to have, from what we were able to 12 A Yes.
13 calculate, it came from the front desk. These 13 Q What did that figure relate to?
14 charges were put on our American Express over a 14 A This was done by our accountant as to
15 few months that totaled this amount. 15 how much we actually spent.
16 Q You said at the time. At what time are 16 Q How much you spent related to what?
17 you referring to? 17 A To our computer tampering whatever you
18 A That would have been April 2nd, 2009. 18 want to call it.
19 By that time we had experienced that loss on our 19 Q And that's what that figure I just read
20 credit card, American Express. It was 20 $286,000 related to?
21 unauthorized. 21 A Yes.
22 Detective Martin came over and he 22 Q And that's also reflected in Exhibit
23 spotted a link to Melongo having access to the 23 12?
24 front desk. So he canceled that access. 24 A It reflects into 12 as well.
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1 Q And was -- 1 By Ms. Schwartz:
2 A Some of the things. 2 Q I'm showing you Plaintiff's Deposition
3 Q Was Exhibit 12 prepared by you or your 3 Exhibit 14 CCSAO 09270 to 74.
4 accountant or someone else? 4 Is Exhibit 14 a true and accurate copy
5 A 12 was me and the value of damages -- 5 of an email that you sent to Robert Podlasek on
6 Q Referred to -- 6 February 14, 2010?
7 A -- on 13 was our accountant put this 7 A It appears to be.
8 together. 8 Q And you're sending -- you're sending to
9 Q What was the purpose of putting together 9 him that same Tsupport@gmail.com that we just
10 a total of damages? 10 discussed as Exhibit 11?
11 A We had to come up and -- what is his 11 A It appears to be.
12 name? Bob, the State's Attorney. 12 Q And the subject line is Annabel's
13 Q Podlasek? 13 footprint evidence, correct?
14 A Thank you. 14 A Yes.
15 He wanted to know how much we lost. So 15 Q Why did you send the tech support email
16 our accountant put together this and fax'd it over 16 to Mr. Podlasek on February 14, 2010?
17 to him as to how much we lost. 17 A I would have done that if he requested
18 Q I'm turning your attention to the 18 it.
19 May 4th entry on Exhibit 12. May 4th, 2006. 19 Q Do you recall if he requested it?
20 A May 4th. 20 A I would only have if he would have
21 Q Which is on the second page of 21 requested it.
22 Exhibit 12 towards the bottom. 22 Q And then at the end you said, you wrote,
23 A Yes. 23 I sent same to Det. Martin in case this evidence
24 Q It states, Christian Sass True 24 was lost.
197 199

1 Consultants temp traced and printed those email 1 Did you also send the tech support email
2 footprints from Spizzirri's emails to Melongo's 2 to Detective Martin?
3 email server and back to Spizzirri and SALF staff. 3 A It's very possible I did.
4 What does that sentence I just read 4 (A document was marked Plaintiff's
5 refer to? 5 Deposition Exhibit No. 15 for
6 A Exhibit 11. 6 identification.)
7 Q So that's a reference to Exhibit 11? 7 By Ms. Schwartz:
8 Are you saying in Exhibit 12, the 8 Q I'm handing you Plaintiff's Deposition
9 portion I just read that Christian Sass prepared 9 Exhibit 15 CCSAO 005385. Have you seen Exhibit 15
10 Exhibit 11, drafted the email that was in 10 before?
11 Exhibit 11? 11 A No.
12 A I just put it down that I received it 12 Q Were you aware that anyone with Save a
13 because it's on the same. I don't know who 13 Life Foundation administrator credentials could log
14 technical support is. I just, like I told you 14 on to all employees emails and see sent and
15 before, I didn't know. I just assumed it was the 15 received emails?
16 same. 16 A No.
17 Q You just assumed Christian Sass had 17 Q Were you aware there was an email
18 something do with Exhibit 11? 18 address called administrator@SALF.dot.org?
19 A I thought it was his. That's why I put 19 A No. I did not know that until later.
20 it together. 20 Q When did you learn that?
21 (A document was marked Plaintiff's 21 A Mercury Consultants they had problems in
22 Deposition Exhibit No. 14 for 22 2008. They were a computer firm in our office
23 identification.) 23 building. They came up to find out what was going
24 24 wrong with our computer system. And they found out
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1 that Ms. Melongo was still on as an administrator 1 with Robert Barnes and Vincent Davis of Save a Life
2 in 2008 on our server. As an administrator on our 2 Foundation on May 17, 2006?
3 computer. They contacted WebHSP, who confirmed it 3 A I wouldn't doubt it. I don't know the
4 and changed the code. There should be. I got that 4 dates.
5 in writing, but I did not know anything before that 5 Q Did you hear about any meeting between
6 about administration. 6 Detective Martin and Robert Barnes and Vincent
7 Q Did you have an administrator access to 7 Davis?
8 the email, administrator@SALF.org? 8 A Not that I can remember.
9 A I would have had partial administration 9 Q Did you give Save a Life employees or
10 that I could get into various boxes at will, but as 10 any of Save a Life third party vendors any
11 far as emails, no, I couldn't. 11 instruction or guidance of what to say to law
12 Q Did Christian Sass have administrator 12 enforcement at any time?
13 access in late April early May 2006? 13 A No.
14 A No. 14 Q Did Detective Martin or anyone in law
15 Q Did anyone else to your knowledge have 15 enforcement, State's Attorney's office, Attorney
16 administrator access in late April early May 16 General's office, any other agency ever ask you to
17 2006? 17 examine Save a Life Foundation computers or
18 A Not to my knowledge. 18 emails?
19 Q What do you know about the investigation 19 MR. NINFO: Objection; form.
20 that was done by the Schiller Park Police 20 THE WITNESS: Did anybody within any of the
21 Department in 2006? 21 agency investigate our emails?
22 A Well, I know that Detective Martin did a 22 By Ms. Schwartz:
23 background check and at that time he told me they 23 Q Your actual -- the electronic emails.
24 had found a folder in our computer that belonged 24 I'll repeat the question.
201 203

1 to Ms. Melongo that had the University of Missouri, 1 A Please.


2 Kansas or Kansas, Missouri. And in there was 2 Q Did anybody in law enforcement in any
3 documents of a police report where a professor 3 agency ask whether they could examine the Save a
4 there had accused Ms. Melongo for posting 4 Life Foundation computers and servers for
5 pornographic things on the professor's website or 5 analysis?
6 emails. And the Dean had confronted Ms. Melongo 6 A I thought they were doing that in the
7 and relieved her from the university. And that 7 back room. I didn't know. I don't know.
8 Detective Martin followed up and spoke with the 8 Q Did anyone ever ask you -- did anyone in
9 police officer who was looking -- involved with the 9 law enforcement ever ask you whether Save a Life
10 case. That was told to me by Detective Martin and 10 Foundation's computers or servers could be
11 that is, I believe, the same time I found out that 11 analyzed?
12 she was here on an education, an education visa. 12 A Not to my knowledge. I just assumed
13 Because that's how she was in this college. 13 that that's what they were doing in the back room.
14 And when they relieved her from that 14 Q Did anyone in law enforcement ever ask
15 college, she moved up to Palatine and went to 15 you if they could make copies of the contents of
16 college at Roosevelt. So whatever date that was, 16 Save a Life Foundation's computers or servers?
17 that's all I remember. 17 A Again, I -- I gave everything and gave
18 Q Did Detective Martin tell you anything 18 them the full. If they wanted to do whatever they
19 else about the investigation he and Schiller Park 19 wanted to do, they could do it. They didn't have
20 Police were doing in 2006? 20 to ask.
21 A No. 21 Q Did Detective Martin or anyone else in
22 Q Were you -- 22 law enforcement ever examine your personal
23 A Not to my aware. 23 computer?
24 Q Were you aware that Detective Martin met 24 A I was linked to the server. The main
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1 server. 1 I'm asking about law enforcement specifically.
2 Q Did anyone -- did Detective Martin or 2 So my question is, did you show
3 anyone in law enforcement go on to your own 3 anyone in law enforcement, Detective Martin,
4 personal computer? 4 any Assistant State's Attorney, anyone from the
5 A I didn't have a personal computer. It 5 Attorney General's office, did you ever show anyone
6 was all linked together. 6 in law enforcement your email interface, your email
7 Q Did you have a work computer at all? 7 inbox, your email sent box, your email thrash
8 A No. I only connected to the main hard 8 folder?
9 drives. 9 A That is what I am trying to say. We
10 Q Did you have a desk top that you did 10 lost everything from up to 2000 about 1 or 2.
11 work on when you worked at Save a Life? 11 Everything was gone for emails. All of the other
12 A I had my PC whatchamajigger there. And 12 emails came up when they recovered. Came up as
13 it was roped into the main, the main server from. 13 numbers, D, I'll never forget that, D124, D123,
14 Q So my question is did anyone, 14 D1 -- So I had to open each one and put them in a
15 Detective Martin or anyone else in law enforcement 15 personal file. So you couldn't go actually in and
16 ever examine your PC, your personal computer? 16 see an account of all of the emails because there
17 A You mean, our tower? 17 was nothing there unless it was put back in.
18 Q I mean, your personal computer that you 18 Q We just went over this morning an email
19 did work on, your PC? 19 exchange you had with Brian Salerno.
20 A I'm sorry. But we were all so linked 20 A Yes.
21 together. Nothing that was on mine couldn't have 21 Q -- from May 1 --
22 been seen by somebody else, if they had the ability 22 A I see what you're saying.
23 to see it. So I don't -- they didn't ask me 23 Q -- 2006?
24 particularly. I gave them authority to do whatever 24 A Now --
205 207

1 they needed to do. 1 MR. NINFO: Let her speak.


2 Q Are you aware of anyone ever looking at 2 By Ms. Schwartz:
3 your personal computer? Not the servers, but 3 Q My question is did anyone from law
4 your -- 4 enforcement --
5 A No. 5 A Yes.
6 Q -- PC? 6 Q -- ever ask you to open up your email
7 A No, I know. No, I'm not aware of 7 interface and go through your inbox, your sent
8 anything like that. 8 mail, your thrash, for those emails that were --
9 Q Did you ever show anyone in law 9 A Oh.
10 enforcement your email interface? Did you go 10 Q -- still available? Did anyone ever ask
11 into your email account and show your sent 11 to do that?
12 messages, your thrash messages, your inbox on the 12 A No. No. I'm sorry, I misunderstood
13 computer? 13 you.
14 A They had access to everything when they 14 Q Did you ever consider whether the
15 had to bring us back up. So like I said, all our 15 original electronic evidence from your email would
16 emails -- everything was in little numbers. And 16 have been better than giving printouts to law
17 all had -- nothing came back up on a computer. 17 enforcement?
18 Everything was all numbers when it did come up. I 18 A Never considered that.
19 had to go through each one individually and put 19 Q Did you ever look into your sent folder
20 them into the certain files. 20 on your email to see whether emails had been
21 Q I'm not asking about the recovery 21 forwarded out of your account on May 1, 2006?
22 efforts -- 22 A No, I never did.
23 A Oh. 23 Q Why didn't you do that?
24 Q -- that the third-party vendors did. 24 A I'm ashamed to say I didn't know you
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1 could do that. 1 Q Did you file a police report related to
2 Q Did Detective Martin ever give you any 2 the May 2006 American Express charges?
3 instructions on how to preserve any computer 3 MR. NINFO: Just listen to her. Answer the
4 evidence to make sure it was useful for law 4 questions.
5 enforcement? 5 THE WITNESS: I really don't know. I don't
6 A No. 6 know the dates.
7 Q Did anyone else ever give you any 7 (A document was marked Plaintiff's
8 instruction on how to preserve computer evidence to 8 Deposition Exhibit No. 16 for
9 make sure it was useful for law enforcement's 9 identification.)
10 investigation? 10 By Ms. Schwartz:
11 A No. 11 Q I'm handing you Plaintiff's Deposition
12 Q You testified earlier that you contacted 12 Exhibit 16. CCSAO 000044 to 45.
13 or communicated with the Schiller Park Police about 13 Have you seen Exhibit 16, Ms. Spizzirri,
14 unauthorized charges on Save a Life's credit card; 14 before today?
15 is that correct? 15 A I don't remember this one at all.
16 A Yes. 16 Q Exhibit 16 is a police report dated
17 Q How did you learn about unauthorized 17 May 18, 2006. States that an officer was
18 charges on Save a Life's credit card in 2006? 18 dispatched to 9950 Lawrence Avenue, that is Save a
19 A Oh. 19 Life's address about credit card fraud and spoke to
20 Q Start with 2006. 20 you about the allegations of credit card fraud.
21 A American Express contacted our 21 My question relates to the bottom of
22 accountant that they recognized unauthorized -- I 22 second page of Exhibit 16. It says the possible
23 shouldn't say unauthorized. Suspicious charges 23 offender Melongo is an ex-employee and has tempered
24 because of the type of charges we had before were 24 with computer files upon termination of employment.
209 211

1 airplane tickets. Not going to Ebay or buying on 1 Did you tell an officer around this
2 line. So they contacted the accountant. The 2 time, May of 2006 that Ms. Melongo was the possible
3 accountant contacted me. And that's she then 3 offender for computer -- for unauthorized credit
4 contacted Schiller Park police to let them know 4 card use charges.
5 that we just had this intrusion of American 5 A This very possibly could have been my
6 Express. 6 accountant because I don't even remember this one.
7 In fact, one time, Detective Martin was 7 Just because my name is on here does not mean that
8 at the office when my accountant had gotten a phone 8 I was there at the time.
9 call from American Express saying that another 9 Q You don't remember meeting with --
10 charge had been -- was suspicious. 10 A I do not remember this one at all.
11 So then Detective Martin went to the 11 Q You don't remember meeting with an
12 front desk and did his thing and found that 12 officer on May 18, 2006?
13 Ms. Melongo had access to our front desk through 13 A No, the Amazon I don't remember at all.
14 yahoo. 14 Q What about Ebay. It Says on Exhibit 16
15 Q When was that? 15 $235 worth of merchandise was purchased from --
16 A That's why I have the printout. 16 $320 worth of merchandise was purchased from
17 (Examining document.) That would have been 2007, 17 Ebay?
18 about April 2nd. 18 A All of these would have been gone
19 Q Let's stick with the 2006 credit card, 19 through and notified through our accountant. Not
20 credit card issue. At some point in May of 2006, 20 me. American Express would have been contacting
21 you identified unauthorized charges on the Save a 21 our accountant. And if she would have found
22 Life Amex; is that correct? 22 something, she would have notified.
23 A That would have been American Express, 23 Q Were you aware that Robert Barnes also
24 yeah. 24 contacted the Schiller Park Police Department in
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1 June of 2006 about unauthorized automatic 1 something to do with it?
2 clearinghouse debits on Save a Life's Chase 2 A It was in a police report that she knew
3 account, Chase Bank account? 3 the party that received the merchandise.
4 A I remember that. 4 Q That's why you included this line of
5 Q And Schiller Park Police followed up on 5 June 22nd --
6 that, that allegation, correct? 6 A Yes, ma'am.
7 A Yes. 7 Q -- 2006?
8 Q Isn't it true that no unauthorized use 8 (At this point in the proceeding
9 of credit cards or bank accounts was ever linked to 9 Ms. Brown left the room.)
10 Ms. Melongo specifically? 10 By Ms. Schwartz:
11 A That's correct. Didn't know who did it. 11 Q In May, June, and July of 2006, how
12 Q Ms. Melongo was never arrested or 12 often did you speak to Detective Martin?
13 charged for any unauthorized use of credit cards or 13 A I couldn't say.
14 bank accounts, correct? 14 Q A handful of times. More than ten
15 A No. 15 times? Can you guess?
16 Q Were you aware that a few other names 16 A Probably more than ten times.
17 came up in the investigation of the unauthorized 17 Q What was the purpose of those
18 credit card and bank account allegations? 18 communications?
19 A I was aware of that. 19 A I think they were questions he had
20 Q Did any of those names -- were any of 20 about -- well, the charge cards alone was several
21 those names familiar to you? Did you know any of 21 times. And the emails that we had received and
22 the names that came up? 22 then we received another email from a KR --
23 A No, they weren't to me. 23 kharma @SALF.org, which was not our email address.
24 Q So you didn't know of an Andrea Chase. 24 And someone had created it from our -- to let us
213 215

1 A No. 1 know that ABC was being watched. So I mean it made


2 Q Or Andrea Smith? 2 it look like it was coming from our company, but
3 A No. 3 nobody with a kar -- kharma@SALF existed.
4 Q Someone named Tanya Spears. 4 Q You testified earlier that you never met
5 A No. 5 or spoken to Kyle French; is that correct?
6 Q Let's turn back to Exhibit 12. Turn to 6 A Not to my knowledge. I don't believe
7 the second page at the very bottom. June 22, 2006, 7 I ever did. I may have, but I don't remember.
8 entry. 8 Q What did you know about the work of Kyle
9 A June. 9 French on the Save a Life Foundation computer
10 Q It says X2 Credit AX card charges 10 tampering investigation --
11 totally $375.42 called Schiller Park Police 11 A I was --
12 Detective Martin - canceled card. 12 Q -- on Ms. Melongo's case?
13 Why was this allegation included on a 13 A I'm sorry.
14 list of cyber sabotage activities by Annabel K. 14 Q Go ahead.
15 Melongo if it was never proven or shown that she 15 A I was only told by Bob and
16 had any involvement in the credit card 16 Detective Martin several individual times that
17 allegations? 17 Mr. French was an expert in forensic computers.
18 A According to the police report, which I 18 And he was helping them understand what it was
19 vaguely remember, Detective Martin went to these 19 about, and how this all worked.
20 individuals that you named even though I don't know 20 Q What did you know about the work of
21 who they are. And did come back that Ms. Melongo 21 Shahna Monge. Now her last name is Voita from the
22 did know the individual, and that was in the police 22 Illinois Attorney General's office?
23 report. 23 A I didn't know anything except that I was
24 Q So you still thought Ms. Melongo had 24 in the police report that she -- I believe went
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1 with Detective Martin to -- under a warrant. 1 were there, but they didn't enforce them because
2 But other than that, I don't know who 2 they didn't know how.
3 she was. Never met her. 3 Q What made you think Mr. Roberts was
4 Q You reviewed the Schiller Park Police 4 involved in the investigation of Ms. Melongo or of
5 Report about the computer tampering investigation? 5 the Save a Life Foundation computer issues?
6 A Only after the fact. I was never given 6 A Because of Attorney, State's Attorney
7 anything. 7 Devine's letter to me saying that he had assigned
8 Q When did you review the police report? 8 Randy Roberts to follow up. That's why I assume
9 A When it was on line. 9 they were working together.
10 Q When it was on line on Ms. Melongo's 10 Q Was there any other reason you thought
11 website? 11 Mr. Roberts was involved in the investigation of
12 A And Peter Heimlich's. 12 the Save a Life Foundation computer tampering
13 Q Before then you hadn't reviewed them? 13 allegations?
14 A No. 14 A No.
15 (A document was marked Plaintiff's 15 Q You write in the end of the first full
16 Deposition Exhibit No. 17 for 16 paragraph, I've been informed that not only were
17 identification.) 17 they able to positively identify the person who
18 By Ms. Schwartz: 18 committed the crime, reimburse charges made against
19 Q Handing you Exhibit No. 17. 19 our American Express credit card and the party who
20 Melongo_004398. 20 received the purchases, but secure some of the
21 Is Exhibit 17 a true and accurate copy 21 loose data, which is so vital for this Foundation.
22 of a letter you wrote to Richard Devine, 22 Were you able to recover funds from
23 November 2, 2006? 23 American Express card?
24 A I believe it is. 24 A They struck the charges.
217 219

1 Q And in this letter, Exhibit 17, you 1 Q Who is they?


2 express gratitude for Randy Roberts and 2 A American Express dropped the charges.
3 Detective Martin's work; is that correct? 3 Q Were you able to recover all of the
4 A Yes. 4 American Express charges?
5 Q Why did you write this letter 5 A Yes. Yes.
6 Exhibit 17? 6 Q Why did you mention the American Express
7 A Just to thank. To follow through 7 charges in this letter since there was no
8 And given an update. Because I mean, computer 8 conclusion that Ms. Melongo specifically had any
9 stuff was not known at that time. 9 involvement in American Express charges?
10 Q At the bottom you write, the relentless 10 A It was reported to the Police
11 examination by Mr. Roberts and Schiller Park 11 Department. And since they were all working
12 Detective Martin is a credit to you as Illinois 12 together on it, it became public record. So just
13 State's Attorney for the perseverance in stopping 13 wanted to say that we were fine because we already
14 crime. 14 had sent out a notice that we had lost money. I
15 What was the relentless examination you 15 wanted to make sure they knew that we recovered it.
16 were referring to with respect to Mr. Randy 16 Q You sought damages from Robert Half
17 Roberts? 17 International related to the alleged intrusion;
18 A At that time I understand that he was -- 18 didn't you?
19 they were all working together. This was all brand 19 A Did not sue them. They on their own
20 new to them. And they spent hours and hours trying 20 offered to reimburse us.
21 to put it all together. I know that they worked 21 Q How much did they reimburse you?
22 hard to try and understand this. 22 A I do not remember.
23 Because like I said, this was all brand 23 Q Did you request that they reimburse --
24 new. We were the first in the state. And the laws 24 Strike that.
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1 You requested around $100,000 from 1 (At this point in the proceedings
2 Robert Half due to the computer tampering 2 Ms. Brown reentered the deposition.)
3 allegations, correct? 3 By Ms. Schwartz:
4 A That was -- that was due to -- what's 4 Q Then it goes on to state that, The total
5 his name, the first one. 5 amount claimed resulting from the significant
6 Q Victor Rodriguez? 6 damage SALF sustained is $114,541.87. This was
7 A Yes. Melongo was an afterthought. 7 damage that Save a Life Foundation claimed was a
8 Because that was a follow up. But we sued for -- 8 result of Ms. Melongo's actions?
9 we presented a suit to Robert Half for that -- for 9 A This was added to the existing we had
10 him. 10 with -- I cannot say. I'm not sure. It has been
11 Q For Victor Rodriguez? 11 so long. I cannot say, but we never followed
12 A For Victor Rodriguez. 12 through on this at all.
13 Q Did not relate to Ms. Melongo? 13 Q You never received any money --
14 A Did not in the beginning. I guess the 14 A Never. No money --
15 name of that attorney I can't remember his name. 15 Q -- from --
16 But then Tom DiCianni, he talked with Robert Half 16 A -- for the damages.
17 at the end, and we settled that they would 17 We settled for the cost of employment.
18 reimburse us for the charges only. No. No. They 18 Got reimbursed for that, but the rest of it did
19 only offered us $12,000, and we never followed 19 not.
20 through on it. Because again, we were never -- we 20 Q That cost of employment here that, line
21 were never -- we never went through. We got 21 item here appears to be $46,518?
22 nothing for it. 22 A No. It was $12,552.
23 Q Did you ever seek compensation from 23 Q That appears to relate to --
24 Robert Half International related to your 24 A I'm sorry. I'm sorry.
221 223

1 allegations against Ms. Melongo? 1 It was only for their salaries. Not for
2 A She came on second, but we never 2 the damages that they -- I don't remember how much
3 followed through. Never. Never followed through 3 we recovered from the salaries. I know we
4 on that. 4 recovered some, but I don't remember how much.
5 (A document was marked Plaintiff's 5 Q Save a Life Foundation recovered --
6 Deposition Exhibit No. 18 for 6 A Just.
7 identification.) 7 Q -- the amount paid for Ms. Melongo's
8 By Ms. Schwartz: 8 salary?
9 Q I'm showing you Plaintiff's Deposition 9 A And I believe some for Rodriguez too.
10 Exhibit 18, CCSAO 002043. 10 Q But Save a Life Foundation did not
11 Exhibit 18 is letter from Thomas D. 11 recover any additional amount apart from the
12 DiCianni to a Joel Kaplan. 12 salaries?
13 A Uh-huh. 13 A No, ma'am.
14 Q Have you seen Exhibit 18 before? 14 Q You also received some amount from
15 A Yes, I have. That's what I was saying. 15 insurance for losses related to Ms. Melongo; is
16 We never followed through on it. 16 that true?
17 Q But you did request compensation? 17 MR. NINFO: Objection; asked and answered.
18 A At the time. 18 THE WITNESS: I don't know. Like I said, it
19 Q And this says, in the first paragraph, 19 was a check and that was not her. And there was
20 Ms. Melongo caused serious damage to SALF's 20 American Express. Didn't name her. I don't
21 computer system, and has since been indicted for 21 remember anymore than that.
22 computer fraud and theft arising out of that 22 (A document was marked Plaintiff's
23 damage. 23 Deposition Exhibit No. 19 for
24 24 identification.)
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1 By Ms. Schwartz: 1 A Well, she definitely was working with my
2 Q I'm showing you Plaintiff's Deposition 2 ex-husband because she had him up there. And she
3 Exhibit No. 19, CCSAO 000183. 3 was working with Peter Heimlich because she had him
4 Exhibit 19, is a letter from Zurich 4 up there. And she had some other associates she
5 Insurance to Schiller Park Police Department 5 was working with.
6 listing as the insured Save a Life Foundation. 6 Q Who is your ex-husband? What is his
7 A Okay. 7 name?
8 Q Have you seen Exhibit 19 before? 8 A Gordon Pratt.
9 A Now I recollect this. I didn't remember 9 Q Your name was mentioned on the Illinois
10 it. 10 Corruption website, correct?
11 Q It states that: "Maryland Casualty 11 A How many times?
12 Company insured the victim Save a Life Foundation 12 Q Your name was mentioned a number of
13 for the above-referenced loss in which former 13 times on the Illinois corruption website, correct?
14 employee Annabel Melongo vandalized my insured's 14 A Yes.
15 computer data system." 15 Q And the descriptions of you were not
16 Did you make a claim to Maryland 16 favorable; is that correct?
17 Maryland Casulaty Company for insurance? 17 A That's correct.
18 A It's very possible that my accountant 18 Q How did it make you feel, Ms. Melongo's
19 did. 19 website?
20 Q It states that, Maryland Casulaty paid 20 A Painful.
21 $5,000 for repairs for Save a Life Foundation? 21 Q Why was it painful?
22 A It says that here. 22 A Because it went into my daughter's
23 Q Did you dispute that amount was paid? 23 death. And that's not something you want to do
24 A I can't testify to that. I don't know 24 when you're trying to make something good out of
225 227

1 for sure. 1 life. It was very nasty. And to call my oldest --


2 Q Apart from the salaries from Robert 2 my youngest daughter a whore. It was horrible.
3 Half, the insurance, the $5,000 insurance that we 3 She didn't deserve it. She lost two of her sisters
4 just saw in Exhibit 19, are you aware of any other 4 and then have to be called a whore on top of it.
5 amounts that Save a Life or you received related to 5 Q Are you saying Ms. Melongo -- somewhere
6 the April 28, 2006, intrusion? 6 on the Illinois corruption website, one of your
7 A Not to my knowledge. I don't recall. 7 daughters was called a whore?
8 Nothing to me personally. It would have only been 8 A Yes.
9 through the company. 9 Q And Ms. Melongo -- Strike that.
10 Q Have you seen the website 10 The Illinois Corporation website also
11 Www.Illinoiscorruption.net? 11 linked an ABC News report done by Chuck Goudie; is
12 A Yes. 12 that correct?
13 Q When did you first learn of the website 13 A Yes.
14 www.Illinoiscorruption.net? 14 Q Which was critical of you in the Save a
15 A I got an email from a friend of 15 Life Foundation?
16 Ms. Melongo's along with the Attorney General, the 16 A Yes. But it was later taken off. It
17 State's Attorney, and along with everybody else. 17 was only on Peter Heimlich's blog. He only had a
18 Q When? 18 link to Peter Heimlich's blog.
19 A That was in 2009. 19 Q Ms. Spizzirri, if at any time you need
20 Q What was your impression of 20 to take a moment, please do let me know.
21 Ms. Melongo's website, Illinois Corruption 21 A Okay.
22 website? 22 Q Do you need a moment?
23 A Fabricated. 23 A I always need a moment when I am
24 Q What do you mean when you say that? 24 thinking of my kids, but move on.
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1 Q Did you talk to anyone about 1 information where I am living and my personal
2 Ms. Melongo's website? 2 email. I was called in to the mayor's office.
3 A Yes. 3 I mean it was embarrassment. Not only
4 Q Who did you talk to? 4 that. My daughter up in LA. She was stalked by
5 A Everybody knew about it. Bob. 5 this same person who claimed to be a reporter.
6 Q Mr. Podlasek? 6 They found her. I didn't know where to go. I was
7 A Yes. Because every transcript, ever 7 scared to death even to go outside of my house.
8 piece of paper, ever police report, everything was 8 Q Did you ever talk to Detective Martin
9 up there, and Bob protested to the Judge that 9 about Ms. Melongo's website?
10 that's not the way to present a case. That because 10 A He knew about it. They said they were
11 she was pro se, she could do that. 11 monitoring it.
12 Q Someone said because she was pro se she 12 Q Detective Martin told you he was
13 could do what? 13 monitoring it?
14 A She could take all the transcripts and 14 A All of them. State's attorney.
15 motions and all of the court documents, reports, 15 Q Did you talk to Julie Gunnigle about the
16 and post it up there on her internet. 16 website?
17 Q Who told you that? 17 A She knew about it. She knew about it
18 A Bob. He tried to get the Judge to take 18 when she was emailed.
19 it down. It was taken down for a while. 19 It ruined my daughter's career by the
20 Q Did you ask Mr. Podlasek to try to get 20 way, just to let it on the record.
21 the website taken down? 21 MR. NINFO: You want to take a break?
22 A No, I did not. He felt it was not good 22 MS. SCHWARTZ: We can take a break.
23 to have it up there because documents, like motions 23 MR. NINFO: Take a break.
24 and hearings and things like that, if a regular 24 MS. SCHWARTZ: I was about to move on to
229 231

1 attorney did it, they would be penalized, but 1 another subject.


2 because she was pro se, she did it anyhow. 2 (A recess was had.)
3 Q Did you talk to anyone else about the 3 By Ms. Schwartz:
4 website? 4 Q Ms. Spizzirri, I'd like to start, turn
5 A Everybody knew about the website. 5 back to Exhibit 12, Cyber Sabotage Activities by
6 Because it was linked from one place to another. 6 Annabel Melongo document. So we talked a bit about
7 Q Did you talk -- 7 this earlier. The April 2nd, 2007 entry on the
8 A She had about 20 different links. And 8 third page.
9 what they didn't, they put in the newspaper. 9 A On the third page?
10 Q Who is the "they" you are referring 10 Q Yes. The page marked at the bottom,
11 to? 11 CCSAO 002232.
12 A Well, after my house was broken in and 12 A It's on the third page. April you said?
13 everything else happened and I had to move to 13 Q April 2nd, 2007?
14 California, with my neighbor. We bought a house 14 A April.
15 out there. He knew what was going on. So we 15 Q April 2nd, 2007?
16 bought a house together for my protection. 16 A Uh-huh.
17 Within -- I was told don't tell nobody where you 17 Q You write that it was discovered --
18 are. I only gave the State's Attorney my. 18 "discovered Melongo had access to front desk
19 Phone number so they could get in touch 19 computer where all credit card transactions were
20 with me. Within two months, they found me. And 20 performed for travel." Canceled, and then, "(see
21 had an article put in the San Diego Reader with 21 AT&T/Yahoo attachment) Canceled card - cancel
22 pictures of my house where I was living. And 22 Melongo's access."
23 accusing me of all sorts of things. The mayor 23 Did you believe that Ms. Melongo had
24 received a phone call wanting my personal 24 somehow logged into the Save a Life front desk in
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1 or around April 2007? 1 Consultants?
2 A Detective Martin found that access. 2 A Because we were having problems with our
3 That's all I know. 3 log in.
4 Q What did Detective Martin tell you? 4 Q When did you hire Mercury Consultants?
5 A He disconnected the access and he made a 5 A That would have been on 10/4. Or no,
6 printout. 6 I'm sorry, it was like 10/4/07. It must have been
7 Q What was the printout? 7 July 9, 2007.
8 A It was that her name was on the yahoo 8 Q Why do you say it must have been
9 account to get into that front desk. 9 July 9th?
10 Q Was Ms. Melongo ever arrested or charged 10 A That is the date I have here. And I do
11 related to this alleged access in April of 2007? 11 remember him saying that.
12 A No. 12 Q Do you mean July 9, 2008?
13 Q Was there any other follow up apart from 13 A Yes, I'm sorry. Yes.
14 the conversation with Detective Martin about the 14 (A document was marked Plaintiff's
15 alleged access in or around April of 2007? 15 Deposition Exhibit No. 20 for
16 A Not to me, but I believe that he did 16 identification.)
17 interview the people who received some of the 17 By Ms. Schwartz:
18 things that were charged to the American Express. 18 Q I would like to hand you Plaintiff's
19 Q But the American Express charges were 19 Deposition Exhibit 20 CCSAO 012532.
20 not -- were not ever tied to Ms. Melongo, 20 Do you recognize Exhibit 20,
21 correct? 21 Ms. Spizzirri?
22 A No. 22 A Yes, I do.
23 Q How is it possible that Ms. Melongo 23 Q This is series of emails between you and
24 would have access to Save a Life front desk 24 David Hobbs, Dave Hobbs of Mercury Consulting dated
233 235

1 April 2007 given that the passwords were changed 1 July 9, 2008.
2 after the alleged intrusion in 2006? 2 A Yes.
3 A I don't know. 3 Q Is it a true and accurate copy of email
4 MR. NINFO: Objection; speculation. 4 correspondence you had with Dave Hobbs?
5 By Ms. Schwartz: 5 A Yes.
6 Q What was your answer? 6 Q Let's start with his bottom half of
7 A I don't know. 7 Exhibit 20, which is an email from Mr. Hobbs to
8 Q If you turn to the entry dated, July 9, 8 you, at 12:56 p.m. on July 9, 2008.
9 2008. It states that, "Mercury Consultants 9 He states that quote, "The DSL service
10 discovered on 10/4/07 SALF's DSL service was 10 was changed from static to dynamic on 10/04/07;" is
11 changed from static to dynamic the notes for the 11 that correct?
12 account listed Nic Pro Dynamic the only one who'd 12 A Yes.
13 have access was the Account originator Annabel 13 Q He also stated in that second paragraph
14 Melongo, who was the only person having the 14 of his email. Quote, "In the SALF network
15 password information to change the account." 15 documentation, it states that the account
16 What is Mercury consultants? 16 originator is Annabel Melongo who may have provided
17 A They are a computer like a forensic. 17 specific personal information which could be used
18 Like -- like, Brian. 18 to make a change to the account."
19 Q Brian Salerno? 19 Mr. Hobbs in this email does not state
20 A Uh-huh. 20 with certainty that Ms. Melongo must have changed
21 MR. NINFO: Yes? Is that a yes? 21 the DSL service; does he?
22 THE WITNESS: Yes. 22 A According to Exhibit 12, I have a note
23 MS. SCHWARTZ: 23 on there, that WebHSP on July 22, 2008, Mercury
24 Q Why did you hire or engage Mercury 24 Consultants discovered administer cpanel no longer
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1 working and DSL line changed. Mercury contacted 1 Q You wanted him to say that it had to
2 SALF's host, WebHSP, discovered Melongo had 2 have been Ms. Melongo who made the change to the
3 assigned herself as administrator prior to leaving. 3 DSL?
4 WebHSP reset password (See Mercury notes) Melongo 4 MR. NINFO: Objection. That is not what that
5 actions allowed her complete access to front desk 5 document says.
6 computer where AX, American Express Card charge 6 THE WITNESS: No, I didn't ask him to do that.
7 originated and explained why each time American 7 I asked him for an explanation.
8 Express reissued a new card/number it was 8 By Ms. Schwartz:
9 compromised because Melongo had access four 9 Q You included quoted language that you
10 occurrence -- four occurrence - police report on 10 wanted him to include; didn't you?
11 file. Melongo also had total access to SALF's 11 A I wanted him to tell what he found out
12 website to make changes to content at will and 12 from his own and what he told me and what WebHSP
13 also SALF's emails. 13 had told him.
14 Q So you were just reading from 14 Q You were trying to pin blame on
15 Exhibit 12, page CCSAO 002232? 15 Ms. Melongo for this DSL issue on July 9, 2008;
16 A Yes. 16 were you not?
17 Q My question is Exhibit 20. 17 A No, I was not trying to pin anything on
18 A Yes. 18 her. I was trying to tell -- I wanted him to put
19 Q Is a July 9, 2008 series of emails. And 19 it in writing what he discovered, and what he told
20 it appears to correspond to you or July 9, 2008 20 me.
21 entry, in Exhibit 12. 21 Q Did he ever respond to this email of
22 So my question is, Dave Hobbs' email to 22 July 9, 2008?
23 you on July 9, 2008, Exhibit 20, does not state 23 A Well, what he wrote here is his
24 that Ms. Melongo must have had something to do with 24 explanation of what he found out.
237 239

1 the DSL change, correct? 1 Q The bottom half of --


2 MR. NINFO: Objection; form. 2 A Yes.
3 THE WITNESS: Just says that -- it states that 3 Q -- Exhibit 20?
4 the account originator is Annabel Melongo. So she 4 There was no further follow up after
5 would have had to made her -- she is the 5 that?
6 originator. 6 A No.
7 By Ms. Schwartz: 7 Q Let's turn now to that July 22, 2008
8 Q Right. That's all it says, is that 8 entry that you were just referring to. It states,
9 she's the originator. 9 that the DSL line changed and the Cpanel
10 So I would like to turn your attention 10 administrator no longer worked, which you just read
11 to your response that same day. The top of the 11 from a bit earlier. This is again Exhibit 12.
12 page. You write, could you include that, quote, 12 A Uh-huh.
13 since Carol Spizzirri would have been the only one 13 Q It also states Mercury contacted SALF's
14 who could have authorized this movement from DLS to 14 host, WebHSP, discovered Melongo assigned herself
15 Static Dynamic, and I didn't (I thought we were on 15 as administrator prior to leaving. WebHSP reset
16 DSL until you stated below) the only person who 16 password. Melongo actions allow her complete
17 would have had access and prior knowledge to 17 access to front desk computer where AX card charges
18 (passwords) would have been Annabel because you 18 originated, and explained why each time AX reissued
19 have been doing our web/computer repairs. 19 a new card/number it was compromised because
20 You wrote that sentence I just quoted? 20 Melongo had access four occurrences, police
21 A Yes. 21 reports, filed.
22 Q You were asking Mr. Hobbs to put that 22 You write here that Ms. Melongo somehow
23 content that you wrote into his summary? 23 had access to the front desk computer in July of
24 A To give an explanation. 24 2008?
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1 A That was what was told me by Mercury 1 ftpsalf. If possible, can you let us know any of
2 Consultants. 2 the details as to why, when, how this password was
3 Q But in the entry we discussed earlier 3 changed?"
4 dated April 2007, the note, cancel Melongo's access 4 You were contacting John Burns on
5 is written. 5 July 22nd, 2008, about resetting the password for
6 Was Ms. Melongo's access to the front 6 administer email accounts and trying to figure out
7 desk computer not canceled in April 2007? 7 why the password had been changed?
8 A I believe it was. The front desk was 8 A Yes.
9 canceled, but that Static whatever that is was 9 Q At the top right it says, Annabel
10 still engaged as administrator. 10 related in handwriting. Is that your
11 Q Why -- 11 handwriting?
12 A I can't remember. I'm sorry. I can't 12 A Yes, it is.
13 remember that. 13 Q Ms. Melongo's name isn't on this page or
14 Q Why did you write that Melongo actions 14 any other pages of Exhibit 21. Why is this listed
15 allow her complete access to front desk computer? 15 as Annabel related?
16 A Because that's what was told me. 16 A I don't know who received this. It may
17 Q Who told you that? 17 have been from my own files that I had. I don't
18 A Dave Hobbs, Mercury Consulting. 18 know why. It is my handwriting, but it would have
19 Q Did he tell you that on the phone or did 19 been my file that I would have put it in.
20 he write that? 20 Unless I sent it over to someone else.
21 A He told -- when he was up in our office, 21 I don't recall.
22 he was working with WebHSP on the phone. And they 22 Q If I turn to the next page of Exhibit
23 were looking to see why we were having problems and 23 21, CCSAO 2064 at the bottom, page 2. This appears
24 that's what they discovered both of them. 24 to be John Burns' response to your email inquiry.
241 243

1 Q You write in Exhibit 12, July 22, 2088 1 He writes, "I cannot tell when someone
2 entry that WebHSP had discovered that Ms. Melongo 2 would have changed the password or how they would
3 assigned herself to be an administrator prior to 3 have done it. It would have to be someone with
4 leaving. 4 access to do so."
5 I would like to show you Plaintiff's 5 Q So Mr. Burns from WebHSP couldn't tell
6 Deposition Exhibit No. 21. CCSAO 002063 to 68? 6 you how the password was changed, correct?
7 MR. NINFO: Yes. 7 A That's what he said.
8 (A document was marked Plaintiff's 8 Q But in your summary of Exhibit 12, of
9 Deposition Exhibit No. 21 for 9 the July 22, 2008 entry, you say, Melongo had
10 identification.) 10 assigned herself as administer prior to leaving.
11 By Ms. Schwartz: 11 A That's what I was told by Mercury. By
12 Q Exhibit 21 is a series of emails between 12 this time, my staff had reduced significantly.
13 you and support at WebHSP.com which is John Burns; 13 Q So this entry, Exhibit 12, says, Mercury
14 is that correct? 14 contacted SALF's Host WebHSP, discovered Melongo
15 A Yes. 15 assigned herself as administer.
16 Q Let's walk through them one by one. 16 This email, that same date, Exhibit 21,
17 Your email is the first page of Exhibit 21. 17 the second page does not identify Ms. Melongo as
18 A Yes. 18 having anything to do with the password, correct?
19 Q You write, "We discovered that the 19 A I had said that.
20 password to administer email accounts with cpanel 20 Q Pardon?
21 no longer works. We called WebHSP tech support and 21 A I had said that.
22 they verified that the password is no longer 22 Q If I turn to the page at the bottom
23 working and that we should send an email to request 23 marked CCSAO 002066.
24 a change in the password for the account - username 24 A I'm sorry. I'm lost.
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1 Q If you look at the bottom of the page. 1 card charges originated and explained why each time
2 2066. 2 AX reissued a new card/number it was compromised
3 A Which one? 3 because Melongo had access."
4 MR. NINFO: One more. 4 Were you accusing Ms. Melongo there of
5 By Ms. Schwartz: 5 being involved with unauthorized American Express
6 Q 2066. One more. This one. 6 charges?
7 A This way. 7 A I -- I put down what I was told by
8 Q It is dated Wednesday, July 23, 2008? 8 Mercury. Mercury is the one who told me that's
9 A This is Wednesday, July 23rd at 8 -- 9 what he saw when he went on the DSL line whatever,
10 MR. NINFO: It is the same email, I think. 10 the cpanel from inside our office. So I just put
11 By Ms. Schwartz: 11 down what I was told. I didn't know anything more
12 Q 8:51. There are a few duplicates. 12 than that.
13 A I see. 13 Q A computer forensic expert was able to
14 MR. NINFO: Yeah. 14 tell you information about how -- who was making
15 By Ms. Schwartz: 15 American Express charges?
16 Q So that's an email you wrote -- 16 A No. It was the front desk and it seemed
17 MR. NINFO: It's not the same number, but same 17 like it was only the front desk that was
18 email. 18 compromised. That coincided when Detective Martin
19 You're on 66, right? 19 came over and he found that the front desk had
20 MS. SCHWARTZ: I am on 66. 20 Melongo's name along with yahoo. And that was the
21 MR. WUNDER: Is that an email. 21 only computer in our office that had that on. So
22 By Ms. Schwartz: 22 it just coincided with what he had said previously.
23 Q You wrote John Burns copying Dave Hobbs 23 But we didn't know that it was still -- that there
24 of Mercury Consulting. 24 was any access with administration with
245 247

1 "Is there any way you can find the date 1 Ms. Melongo's name on it.
2 our email password was changed?" You wrote that, 2 Q When --
3 correct? 3 A That's Exhibit 20.
4 A Yes. 4 Q When are you referring to you didn't
5 Q And then he responded, if you turn two 5 know that there was access with Ms. Melongo's name
6 more pages ahead to the one marked 2068 at the 6 on it. What time period are you referring to?
7 bottom? 7 A Oh, when we first had the American
8 A Uh-huh. 8 Express charges were being put on our card. We had
9 Q He wrote to you, "Unfortunately I cannot 9 no clue why we would be getting new charge cards
10 tell when it would have changed." Correct? 10 and then each charge card got tamp -- got charged
11 A Yes. 11 against it.
12 Q So based on this email correspondence 12 Detective Martin came over and he went
13 WebHSP wasn't able to provide any information about 13 to each computer. He saw that the front desk had
14 the changing of the administrator password on the 14 Ms. Melongo's yahoo name on it, that she had access
15 Save a Life email, right? 15 to it. And so he took a picture. Printed out a
16 A That's correct. 16 picture with her name on it. And I don't know if
17 Q Were there any other written 17 he disconnected it. I don't know anything about
18 correspondence with WebHSP showing who had changed 18 that.
19 the password? 19 Q Was that in 2007 or 2008?
20 A Okay. No. I don't see anything that 20 You testified earlier that was in April
21 WebHSP was able to identify. 21 of 2007.
22 Q In Exhibit 12 in the July 22, 2008 22 A Must be. May have been 2007. I can't
23 entry, where you say, "Melongo actions allow her to 23 remember.
24 complete access to front desk computer where AX 24 Q Let's stick to 2008.
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1 A Okay. 1 Q -- Charitable Trust Division?
2 Q It says you filed a police report. Is 2 A Yes.
3 that correct? 3 Q Did you send Exhibit 12 to Cook County
4 A That was at the time that our charge 4 State's Attorney's office?
5 cards were tampered. 5 A I don't know.
6 Q July 22nd, 2008? 6 Q Did you ever send it to Bob Podlasek,
7 A No. 2007. I don't think we had 2008. 7 Julie Gunnigle?
8 Q I'm reading off the July 22, 2008 entry 8 A I know that he had a copy, but I don't
9 where it says police reports filed. 9 think he got it from us. It's possible. I don't
10 A Yes. 10 know.
11 Q Did you file a police report in July of 11 Q The next entry of Exhibit 12, third page
12 2008? 12 says, August 27, 2008, grand jurors found Annabel
13 A I think that police reports were filed 13 K. Melongo committed the offense of Computer
14 on 2007. Even though I entered it at 2008. I -- 14 Tampering.
15 I'm sorry. I'm -- I can't. I can't remember the 15 Did you believe that Ms. Melongo had
16 dates. 16 been convicted of computer tampering on August 27,
17 Q Was Ms. Melongo ever arrested or charged 17 2008?
18 with anything related to any of these allegations 18 A The grand jury indict her.
19 you list under July 22nd -- 19 Q It was just an indictment, correct?
20 MR. NINFO: Objection. 20 A Yes.
21 By Ms. Schwartz: 21 Q I'd like to go back to Exhibit 13 we
22 Q -- 2008? 22 discussed earlier.
23 MR. NINFO: Asked and answered. 23 A Uh-huh.
24 THE WITNESS: No. 24 Q You testified Exhibit 13 was prepared by
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1 By Ms. Schwartz: 1 Save a Life accountants for the purpose of


2 Q As a general question about this 2 calculating the damages associated with
3 Document Exhibit 12. Did you ever send it to the 3 Ms. Melongo?
4 State's attorney, Assistant State's Attorney or 4 A Of --
5 anyone else in this case? 5 Q Is that --
6 A Yes, I did. 6 A It was -- I'll get it straight.
7 Q What was the purpose of sending it to 7 It was prepared by our accountant as to
8 the Assistant State's Attorney? 8 the loss of our computer being shut down.
9 A Because they were receiving -- they were 9 Didn't -- because this -- I should have had a
10 getting letters from outside sources including 10 date on here. This was after she had -- this was
11 Peter Heimlich, my ex-husband, and they wanted 11 prepared for the State's Attorney.
12 clarity on what was going on. So I sent it over to 12 Q It was sent to the State's Attorney?
13 them. 13 A Yes.
14 Q Who did you send it to within the 14 Q Was it sent some time in 2008 after
15 State's Attorney's office? 15 Exhibit 12 was prepared?
16 A The charitable trust where we always 16 A Yes.
17 submitted our paperwork. 17 Q Now, a lot of these damages charged are,
18 Q What is the charitable trust? 18 you include attorneys' fees in here; is that
19 A That is the Attorney General, Illinois 19 correct?
20 Attorney General's office charitable trust when you 20 A Yes.
21 have a nonprofit, you have to report to them. 21 Q And you also include fees paid to Robert
22 Q You said you sent Exhibit 12 to the 22 Half International, correct?
23 Attorney General's office -- 23 A That is true.
24 A Yes. 24 Q Was that partially the salary that was
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1 eventually reimbursed to Save a Life Foundation? 1 By Ms. Schwartz:
2 A That was part of the salary, yes. 2 Q I'm handing you Plaintiff's Deposition
3 Q Had the salary been reimbursed at the 3 Exhibit No. 22 which is Spizzirri 000001068 and 69.
4 time this document was created? 4 Is Exhibit 22 a true and accurate copy of an email
5 A I don't know. 5 you sent Robert Podlasek on November 17, 2009?
6 Q You also include in this list or your 6 A It appears to be.
7 accountant included in this list, $11,827.77. 7 Q You write, "I'm requesting present to
8 Related to AMEX and Office Depot credit card 8 you a Victim's Impact Statement against Annabel."
9 fraud? 9 What did you mean when you said Victim's Impact
10 A Yes. 10 Statement?
11 Q You testified earlier that was never 11 A When -- I was under the impression at
12 linked to Ms. Melongo; isn't that right? 12 the time that you go to court, that a person who is
13 A True. 13 a victim of some crime can write an impact
14 Q So why is it listed as an item in a 14 statement.
15 document entitled Value Of Damages Associated With 15 In other words, you can voice your
16 Annabel Melongo given to the State's Attorney's 16 opinion and how you feel. And that's why I said
17 office? 17 that, but then it was delayed, and I never had a
18 A I didn't prepare this. So I don't know 18 chance to do. I just kind of went for a wash. It
19 why she put that in. 19 was a -- we were planning on going to Court where I
20 Q Did you review this document before it 20 was going to testify, and then it got postponed
21 was sent to the Cook County State's Attorney's 21 into another -- something else came up where she
22 office? 22 was charged separate from me, and it got postponed.
23 A I don't believe I did. 23 Q What did you want to say in a Victim
24 Q At the bottom SALF employee time is also 24 Impact Statement?
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1 listed in the amount of $32,360. 1 A How it affected the company that I


2 A Yes. 2 created and I didn't think it was -- I tried to be
3 Q How did you calculate that amount or how 3 good to her. And didn't feel that she was just in
4 did your accountant calculate that amount? 4 trying to injure our company.
5 A She took the employees that were working 5 Q Is there anything else you would have
6 that stayed behind to work on it over the period of 6 said in the Victim Impact Statement?
7 time to get the computer up working with be it 7 A No. Not at this time.
8 Vince Davis or Dane Neal or I can't think who else 8 Q You also write in this email,
9 was involved with trying to get this computer back 9 Exhibit 22, "Additionally I request charges of
10 up. 10 cyberstalking be brought against her - I received
11 And that is where she came up with that 11 three emails related to her blog, several prior and
12 amount. 12 you have charges against her already for having
13 Q Were those hourly employees or were they 13 access to and tampering with my personal emails."
14 salaried employees? 14 A What had happened, and I will explain
15 A I believe that there were -- it was a 15 this. She was sending out personal subpoenas to,
16 combination between the both. Because I had two 16 from what I understand, 100, nearly 150 subpoenas
17 that were salary and couple that were hourly. 17 to all of our stakeholders, our employees,
18 Q Was your time included in $32,000 18 et cetera, including myself. Each person contacted
19 figure? 19 me and said what is this all about. She wanted
20 A No. 20 them to all come in from all over the country and
21 (A document was marked Plaintiff's 21 testify their relationship with me. I contacted
22 Deposition Exhibit No. 22 for 22 the State's Attorney. Spoke with Julie, Julie,
23 identification.) 23 help me out.
24 24 Q Gunnigle.
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1 A That's it. 1 just told them what was happening. They took over
2 And she was livid because that did not 2 from there.
3 come from the Court. She did this on her own. 3 Q Why did you care if third parties
4 And this was not the first time she had 4 responded or didn't respond to a subpoena?
5 done it. She had been told not to do it. So they 5 A Because when they sent it over, I
6 put a squash order. Then I had to contact 6 couldn't understand why they were contacting --
7 everybody and tell them not to come. She later did 7 she was contacting all of these people that were
8 it again, sending subpoenas out to ABC, Chuck 8 connected. They were from different agencies of
9 Goudie, and Vince Davis and a bunch of others, 9 the Federal Government, all sorts of people that
10 which they squashed again. 10 she had sent these subpoenas to. So when I called
11 So she was constantly doing legal work 11 Julie and said, this is what I was getting phone
12 on her own and confusing the Court without 12 calls. She was upset. She asked me for the people
13 permission from the Court. 13 who had emailed or not emailed, fax'd me their
14 So it was a constant routine. Never 14 subpoenas. And then I fax'd them over to her and
15 knew any day what was expecting -- what we were 15 then she followed through to find out who else had
16 expecting. So it was harassing. 16 been subpoeaned and that's when I was told that
17 Q And that's why you want Cyberstalking 17 they were like 130 or something subpoenas that went
18 charges because you felt the subpoenas Ms. Melongo 18 out.
19 had served were harassing? 19 Q Who were the people that contacted you
20 A And along with her website. 20 about their subpoenas?
21 Q Did Mr. Podlasek ever respond to your 21 A Our Board members, Vince Davis, Rita
22 request for cyberstalking charges? 22 Mullins. I can't remember all of them. Vince did
23 A Not the cyberstalking. Only stopping 23 show up. He didn't know it was squashed. So they
24 the subpoenas. 24 let him go. He had to take off of work.
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1 Q Some of those subpoenas were quashed? 1 Q Did you not want people like Vince Davis
2 A All of them were. 2 and Rita Mullins sharing information with
3 Q Why were you involved in following up 3 Ms. Melongo?
4 with third-party subpoena recipients about that? 4 A She didn't have the authority to do
5 A Because they contacted me and asked me 5 that. That's why they were upset. The Court never
6 what it was all about. 6 granted her. She was doing this on her own as a
7 Q And you told them you didn't have to -- 7 pro se. She never notified the Court that she had
8 they didn't have to respond to subpoenas? 8 these subpoenas out there.
9 A No. No. When they were calling me, I 9 Q Did you ever file a police report
10 didn't know what was going on. So I called Julie 10 related to cyberstalking against Ms. Melongo?
11 and said -- so she said, who were they. And they 11 A No.
12 were to fax her. Because I even got faxes myself 12 Q I'm referring to Exhibit 22 now where
13 from the people that she had subpoenaed. So I sent 13 you say at the end, "shall I file a police report?"
14 that over to them. And then she called them and 14 Did you ever follow up and file a police report?
15 told them they were squashed. Not to come. 15 A No.
16 Some people did show up. And they had 16 (A document was marked Plaintiff's
17 to meet them at the door from what I understand. I 17 Deposition Exhibit No. 23 for
18 wasn't there. And they told them that the -- it 18 identification.)
19 was false. A false subpoena that the Court didn't 19 By Ms. Schwartz:
20 approve of it. 20 Q I'm handing you what has been marked as
21 Q Did you ask Julie Gunnigle or Robert 21 Plaintiff's Deposition Exhibit 23 CCSAO 09268. Is
22 Podlasek to help get any of those dozen of 22 Plaintiff's Deposition Exhibit 23 a true and
23 subpoenas quashed? 23 accurate copy of an email that you sent to
24 A I didn't know what squashed meant. I 24 Julie Gunnigle and Robert Podlasek on May 13, 2010?
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1 A There is one redaction. Apart from the 1 intelligent and --
2 redaction. 2 A Well, she knew her computer.
3 It appears that it's possible that I sent 3 Q Did Podlasek or Julie Gunnigle ever
4 this. 4 follow up on your email about Blackberry hacking?
5 Q Do you have any reason to doubt -- 5 A We did contact and I can't -- I am
6 A No. 6 sorry, I can't remember the name of the company
7 Q -- that this is a true and accurate 7 that owned Blackberry here in California -- in
8 copy? 8 Chicago. Started with an R. And they followed up
9 A Right. 9 and emailed me back and said that my Blackberry had
10 Q In this email you're saying that your 10 been hacked. But they had turned it off. And it
11 Blackberry emails have disappeared? 11 was too late for them to follow through, but it had
12 A Yes. 12 been hacked.
13 Q You asked Mr. Podlasek to send a 13 Q By too late to follow through, what do
14 subpoena to Blackberry? 14 you mean?
15 A Yes. I actually was sitting in front of 15 A There is some kind of program or some
16 Julie and Bob at the time that my Blackberry was -- 16 kind of -- I don't know how they do that.
17 the emails were coming in and they were 17 But they said they had whoever was --
18 disappearing. And they were the ones that said 18 had gotten into my computer -- into my Blackberry
19 that it looks like you got hacked. So then, how 19 disengaged the program before they could follow I
20 do you find out if you're hacked? You got to go to 20 guess the footprints.
21 Blackberry. 21 Q So Blackberry wasn't able to determine
22 Q And the subject line of this email, 22 who --
23 Exhibit 23, is Annabel-Blackberry? 23 A No.
24 A Yes. 24 Q -- hacked your Blackberry?
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1 Q Did you think Ms. Melongo had something 1 A No. But they knew I was hacked.
2 to do with your Blackberry hacking? 2 By this time my house had been broken
3 A At the time I did. 3 into, files stolen, and things like that. And
4 Q Why did you think that? 4 then, there was a document that only I had. It was
5 A Because there were things that were 5 a handwritten document. It ended up on one of the
6 going around. Around me that they would never have 6 websites. And I knew that it was either
7 known about unless they had my emails to follow 7 Ms. Melongo or Peter Heimlich's website. I can't
8 through on it. 8 remember. But, whoever broke in my house had taken
9 Q Who is they? 9 that handwritten document.
10 A Whomever was gathering up the emails. 10 Q What was -- what did the handwritten
11 Q Why did you think that person was 11 document say?
12 Ms. Melongo who was gathering up emails? 12 A It was from a person in about 2007, dah,
13 A I thought she was the only one who had 13 dah, dah. In 1997 or 8 from the Department of
14 been intelligent enough to know how to do it. I 14 Education because we received a grant from them.
15 certainly wouldn't have known. 15 And I wanted to know how to report to the
16 Q You thought Ms. Melongo had hacked in 16 Department of Education because there's a
17 your Blackberry because she was intelligent enough 17 procedure. And this person from the Department of
18 to be able to do it? 18 Education wrote a handwritten note and said that
19 A That -- I hadn't experienced this. And 19 the Department of Education doesn't work that way.
20 I was just going through such horrendous things 20 They don't request quarterly reports.
21 that were happening. That I just assumed. I may 21 (A document was marked Plaintiff's
22 have been wrong, but I assumed. 22 Deposition Exhibit No. 24 for
23 Q Your testimony is you assumed 23 identification.)
24 Ms. Melongo was involved because she was 24
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1 By Ms. Schwartz: 1 "found my home was broken in again, (X5) through
2 Q I'm handing you email Bates which would 2 garage." Is that one of the break-ins you
3 be Plaintiff's Deposition Exhibit No. 24 CCSAO 3 testified about earlier?
4 09132. 4 A Yeah.
5 Is Exhibit 24 a true and accurate copy 5 Q And in the next paragraph, second to
6 of an email you sent Julie Gunnigle on June 26, 6 last paragraph, you write, There must be more to
7 2010? 7 Annabel that meets the eye. Please follow the
8 A Uh. 8 money exclamation mark.
9 MR. NINFO: Is that a yes? 9 A Yeah.
10 THE WITNESS: I don't know the date, but I 10 Q What did you mean by that?
11 recognize the name on here. 11 A By this time I knew that Peter Heimlich
12 By Ms. Schwartz: 12 and my ex-husband and Annabel were working
13 Q What name do you recognize? 13 together. They had it on the Internet.
14 A Malcolm Chester. 14 Q What made you think Ms. Melongo was
15 MR. NINFO: Oh, Julie. Yeah. 15 working with Peter Heimlich and your ex-husband?
16 THE WITNESS: I recognize this inside. 16 A They posted it. They said they were
17 By Ms. Schwartz: 17 good friends.
18 Q You recognize? 18 In fact, when Melongo was in court one
19 A The name inside. 19 day, she emailed Peter and thanked him for all of
20 MR. NINFO: She got distracted. 20 the support he gave her. Then she had my
21 By Ms. Schwartz: 21 ex-husband on her website linked to his false
22 Q You recognize this email that you 22 accusations.
23 sent? 23 Q So what made you think that Ms. Melongo
24 A Yeah. 24 might have something to do with the break-in?
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1 Q And is it a true and accurate copy of 1 A Well, I'm not saying that she had.
2 email you sent? 2 Because I can't say that she had, but I had
3 A Apparently it is. I recognize the 3 suspicions that my ex was involved. And I did file
4 name. 4 a police report, and tried to get an order of
5 Q The subject is more web support for 5 protection again.
6 Annabel. What were you sending Ms. Gunnigle 6 Q Ms. Melongo on June 26, 2010, she was
7 related to Ms. Melongo? 7 detained in the Cook County jail; wasn't she?
8 A Well, Mr. Peter Heimlich contacted this 8 A I don't know when she went in.
9 Lee Cary and accused me of some vicious things 9 Q She was detained in the Cook County
10 about my mental state. So he named names and I had 10 jail at the time you wrote this email. She
11 this attorney, Malcolm Chester contact the people 11 couldn't have been involved in breaking into your
12 that were involved in this accusation and he came 12 home; is that right?
13 back saying it was false. 13 A I'm not saying she did. I said that I
14 Q Who came back saying it was false? 14 believe that my ex-husband did. And I filed police
15 A A doctor who was wrongly accused of 15 report under that. Although, I couldn't even prove
16 calling -- saying that I was psychopath, child 16 that, but I did file a police report. Whoever,
17 abuser, and about 20 other things. So I hired 17 broke in my house, broke my door in half. She
18 Malcolm Chester to verify that I was not a 18 couldn't have done that.
19 psychopath or child abuser, which was all posted 19 Q You write there, must be more to Annabel
20 in this Lee Cary's article and sent everywhere. 20 than meets the eye. Please follow the money.
21 Q That's the link that you included in 21 What does follow the money mean?
22 Exhibit 24? 22 A It's a statement. Wherever, you know,
23 A Yes. 23 there is something you got to follow the money.
24 Q You also state in the third paragraph, 24 That was just a statement.
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1 Q What money were you referring to? 1 because of that?
2 A There's got to be something that I 2 A Yes. Then the article -- my ex put an
3 couldn't understand what was going on. 3 article in the newspaper where I lived with links
4 I really didn't understand why all of 4 to the websites, Melongo's website and to Peter's.
5 these people were coming against me. Then I find 5 It was --
6 out later on, if Peter hated his father and his 6 Q Did Mr. --
7 father was on our Medical Board. That is why he 7 A -- horrible.
8 wanted to destroy me. My ex, I won't even describe 8 Q Did Mr. Podlasek ever give you an
9 why he -- had a couple orders of protection on him. 9 attorney referral?
10 But I couldn't understand. I just couldn't 10 A No.
11 understand, but when the websites were linked 11 Q Did you ever find an attorney?
12 together, then I started understanding they are 12 A Got one.
13 working together. 13 Q Did you ever find an attorney related to
14 Q At the end of Exhibit 24 it says, 14 this stalking in California that was alleging going
15 "Before I leave, would like to meet for your 15 on?
16 directions." 16 A No. Nobody wanted to deal with this
17 What directions were you seeking from 17 crap.
18 Ms. Gunnigle? 18 Q In the next paragraph on Exhibit 25, it
19 A By now I had sold my house. I was 19 says, "Read of case your colleagues are prosecuting
20 vacating. And I wanted to make sure that if there 20 - Judge ordered all (websites/related) to be taken
21 was anything I needed to do before I left, 21 down - Can you make this possible in this case
22 everything was packed. I was on my way. I didn't 22 too?"
23 want -- I didn't -- nobody knew where I was going 23 Were you asking Ms. Gunnigle to try to
24 except them. And I wanted to meet and make sure 24 get Ms. Melongo's website taken down?
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1 that if they needed my access or any questions, 1 A Yes. Because everything was posted.
2 that I was available. 2 They even had problems with that being up there.
3 Q Did you meet with Julie Gunnigle before 3 They finally did get it down for a while.
4 you left for California? 4 Q You wanted -- you were asking
5 A No. 5 Ms. Gunnigle to try to get it taken down?
6 (A document was marked Plaintiff's 6 A If there is a way. I mean, because
7 Deposition Exhibit No. 25 for 7 everything was there.
8 identification.) 8 Q You write at the end of this. I need
9 By Ms. Schwartz: 9 some vindication. What did you mean by, "I need
10 Q I'm handing you Plaintiff's Exhibit 25. 10 some vindication"?
11 CCSAO 09185. Is Exhibit 25 a true and accurate 11 A Because everything that was posted
12 copy of an email you sent to Julie Gunnigle on 12 was -- I was -- I was stealing money. I was this.
13 August 23, 2010? 13 I was that. There was such horrible accusations up
14 A Yeah. 14 there. It wasn't true.
15 Q About half way down the page you write. 15 Like I said, they were calling the city,
16 "Has Bob found an attorney referral for me? Been 16 to try to get me in trouble. In fact they called
17 looking around myself. No one believes this...I'm 17 one -- I went to a fundraiser for a politician. As
18 really desperate - can you help me?" 18 soon as I -- the following week, they notified the
19 What were you really desperate about 19 politician who happened to be the State's Attorney
20 when you sent this email? 20 there, and said that I was a thief. They sent the
21 A My daughter was being stalked. I was 21 money back.
22 being stalked in San Diego. They found me. Even 22 Everything I did. Everywhere I went,
23 though I tried to hide. 23 they followed me. I was stalked from mail. I
24 Q You were looking to hire an attorney 24 couldn't do -- I couldn't live a life. My daughter
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1 had the same thing. She was 100 miles away. 1 blog?
2 Fairly newly married. And I was afraid her husband 2 A I wouldn't have written this, if it
3 wouldn't believe her and walk from her too, but he 3 didn't happen, but I forget about it completely.
4 stuck with her. He's A good guy. And he stuck 4 Q What was that conversation?
5 with me too, but when you're accused of being a 5 A I don't know.
6 child abuser and everything else, you want some 6 Q Had you been in contact with Ms. Melongo
7 vindication that you're a good mother. I was 7 at all after --
8 single and three kids, and I took care of them 8 A No.
9 myself. And to be accused of a child abuser isn't 9 Q -- the alleged intrusion on May 1,
10 very nice. 10 2006?
11 MR. NINFO: Take a breath. 11 A No.
12 By Ms. Schwartz: 12 Q Did you speak to her any time after
13 Q So you wanted vindication -- 13 May of 2006?
14 A Yes. 14 A Not -- not -- no. I did see her at the
15 Q -- against Ms. Melongo because of the 15 court house once. Then I was told never to come
16 content on her website -- 16 back to the courthouse again.
17 A Yes. 17 Q Who told you never to come back to the
18 Q -- you thought it was false? 18 courthouse?
19 A I wanted to be cleared. 19 A Bob.
20 By the way, they did this to every 20 Q Why did he tell you that?
21 person I knew from the politician to Gery Chico. 21 A It wasn't safe.
22 MR. NINFO: Wait for a question. 22 Q Why did he think it wasn't safe?
23 THE WITNESS: I mean, everybody. 23 A He just said it wasn't safe.
24 MR. NINFO: Wait for a question. 24 Q Bob Podlasek told you, you couldn't come
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1 There is no question. 1 to the courthouse or shouldn't come to the


2 (A document was marked Plaintiff's 2 courthouse because it wasn't safe?
3 Deposition Exhibit No. 26 for 3 A Right. I don't remember this.
4 identification.) 4 (A document was marked Plaintiff's
5 By Ms. Schwartz: 5 Deposition Exhibit No. 27 for
6 Q I'm handing you Plaintiff's Deposition 6 identification.)
7 Exhibit 26, Spizzirri 000001067. 7 By Ms. Schwartz:
8 Is Exhibit 26 a true and accurate copy 8 Q I'm handing you Plaintiff's Deposition
9 of an email you wrote to someone named Gary 9 Exhibit No. 26. CCSAO --
10 Cunningham and Robert Podlasek on January 6, 2010? 10 MR. WUNDER: 27.
11 A You know, I forget about this. 11 By Ms. Schwartz:
12 Q Does this email -- do you now think this 12 Q 27. Excuse me CCSAO 012511 to 12.
13 is an email you sent? You remember sending this 13 Does Exhibit 27 letter you wrote to
14 email? 14 Lisa Black of the Chicago Tribune on November 25,
15 A I must have, but I forgot about this 15 2010?
16 completely. 16 A Is a response in here?
17 (At this point in the proceedings 17 Q There is no response in this document
18 Ms. Calloway left the room.) 18 that I printed out.
19 By Ms. Schwartz: 19 My question is just are these two
20 Q You say -- you write Bob, this is Gary 20 pages a letter that you sent to Lisa Black
21 who found a taped conversation between her and I 21 November 25th, 2010?
22 and posted it on her blog. 22 A I believe so.
23 Did you believe that Ms. Melongo had 23 Q And in it you write, prior to
24 taped a conversation with you and posted it on her 24 Ms. Melongo's arrest, she established herself,
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1 reading the second paragraph. 1 A They contacted.
2 "Prior to Ms. Melongo's arrest, she 2 Q Sorry?
3 established herself as SALF's Network Account 3 What?
4 Originator, allowing her free access to passwords 4 A Go ahead.
5 and its website till 2008." 5 Q Why were you contacting Ms. Black
6 Again you're accusing Ms. Melongo of 6 Chicago Tribune reporter?
7 having accessed -- 7 MR. NINFO: Objection; asked and answered.
8 A Well, according -- 8 THE WITNESS: They contacted me.
9 Q -- Save a Life's system in 2008? 9 By Ms. Schwartz:
10 A According to Mercury Consultants. 10 Q Was an article ever published about
11 Q Then you write, "This is demonstrated by 11 Ms. Melongo or your discussions with Lisa Black?
12 numerous SALF postings on blogs and websites and 12 A She did write something.
13 may have been a contributing factor to my 13 Q Did you ask Ms. Black of the Chicago
14 Blackberry being compromised." 14 Tribune to attend Ms. Melongo's trial?
15 You testified earlier that Blackberry 15 A Not to my knowledge.
16 couldn't determine who was involved in your 16 (A document was marked Plaintiff's
17 Blackberry being compromised; isn't that correct? 17 Deposition Exhibit No. 28 for
18 MR. NINFO: Objection; asked and answered. 18 identification.)
19 By Ms. Schwartz: 19 By Ms. Schwartz:
20 Q But you wrote this about your Blackberry 20 Q Handing you Plaintiff's Deposition
21 in November 2010 to a Chicago Tribune reporter? 21 Exhibit 28. CCSAo 09127.
22 A Yes. 22 Do you recognize Exhibit 28?
23 Q Why did you write that? 23 A I don't remember this.
24 A Because she contacted me. 24 Q Do you have any reason to dispute you
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1 Q But why did you write that Ms. Melongo 1 wrote this email to Lisa Black and somebody named
2 had been involved in your Blackberry being 2 phernon@Tribune.com December 9, 2010?
3 hacked? 3 A I don't know if I -- I don't remember
4 A Because of the things that she 4 this at all, I'm sorry.
5 questioned me on for an article she was writing 5 (At this point in the proceedings
6 about me. 6 Ms. Calloway reentered the room.)
7 Q What did she question you on that made 7 By Ms. Schwartz:
8 you accuse Ms. Melongo of being involved in the 8 Q You testified at Ms. Melongo's criminal
9 Blackberry? 9 trial in July of 2014; did you not?
10 A I don't remember what it was. But she 10 A Yes.
11 was getting stalked by my ex-husband regarding 11 Q Before you testified at Ms. Melongo
12 Melongo and my relationship. What had happened. 12 criminal trial, did you speak to anybody about your
13 Q So you accused Ms. Melongo of being 13 testimony?
14 involved with your Blackberry being compromised 14 A The State's attorney.
15 even though -- 15 Q Did you prepare with the State's
16 MR. NINFO: Objection. Argumentative. That 16 Attorney for trial?
17 is not what it says. 17 A Yes.
18 By Ms. Schwartz: 18 Q Who was the State's Attorney you
19 Q Did you tell the Chicago Tribune 19 prepared for with for Ms. Melongo trial?
20 reporter, Ms. Melongo may have been involved in 20 A I can't think of her name. It wasn't
21 hacking your Blackberry? 21 Bob. Can't think of her name.
22 A I don't remember. 22 Q Was it Debjani Dasgupta or Nancy Zarkos?
23 Q Why were you contacting Chicago Tribune 23 A She was tall, dark hair. I can't
24 reporter about -- 24 remember her name.
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1 Q How long did you meet with the 1 actual -- when we went. When I had to testify.
2 Assistant State's attorney's office -- assistant 2 Q It was hearing in Ms. Melongo's case?
3 State's attorney prior to Ms. Melongo trial? 3 A Uh-huh.
4 A Probably 45 minutes to one hour. 4 MR. NINFO: Is that yes?
5 Q Did they give you any suggestions about 5 By Ms. Schwartz:
6 your trial testimony? 6 Q And?
7 A No. 7 A Uh-huh.
8 Q Do you remember anything they said about 8 MR. NINFO: Is that a yes?
9 your trial testimony? 9 THE WITNESS: Yes. I'm sorry.
10 A I can't remember. 10 By Ms. Schwartz:
11 Q Did you talk to anyone else apart from 11 Q What did your husband's presence in the
12 the Assistant State's Attorney about your trial 12 courtroom have to do with whether or not the
13 testimony in Ms. Melongo's criminal trial? 13 hearing had to be canceled?
14 A Detective Martin was there. 14 A You have no idea what I went through
15 Q Did you speak to Detective Martin? 15 with him. I was a basket case seeing him.
16 A Hello. Good bye. Nothing much more. 16 Q That is why?
17 Q Do you know result in Ms. Melongo 17 A I couldn't. I couldn't continue.
18 computer tampering trial. Do you know what 18 Q So the hearing to had to be canceled,
19 happened in the trial? 19 rescheduled for that reason?
20 A Oh, yes. I was -- I think the last 20 A (Shaking head.)
21 person that -- just give me a second. Ah. I 21 Q Is that a yes?
22 got -- I got a freeze. A brain freeze. 22 A Yes, I'm sorry.
23 There was two. First time we went my 23 Q Do you know what date or year that was
24 husband showed up for her. So they postponed it. 24 roughly?
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1 And rescheduled the hearing. 1 A Hold on. I forgot.


2 And second time we went -- could you 2 Q You are aware that Ms. Melongo was --
3 repeat that question again. I'm sorry. 3 I'm sorry, you thinking?
4 Q The question was do you know the result 4 A No, that is all right.
5 of Ms. Melongo computer tampering trial? I'm 5 Q I will give you moment. I didn't know.
6 referring to the trial in July of 2014? 6 A Go ahead, please.
7 A Of the result of her trial? Yes. I do. 7 Q You don't know what date that was?
8 Q What is it? 8 A No, I don't.
9 A They dismissed it. 9 Q Were you aware that all of the criminal
10 Q Who told you that? 10 charges brought against Ms. Melongo were
11 A The State's Attorney's office. 11 eventually --
12 Q Were you disappointed when you heard the 12 A Dismissed.
13 case was dismissed? 13 Q -- dropped or disposed of?
14 A Well, it was supposed to be under a 14 A Yes.
15 jury. And the jury was sent out. And the Judge 15 Q Were you aware that Ms. Melongo spent
16 ruled from the bench. 16 nearly two years in the Cook County jail?
17 Q Were you disappointed that the judge 17 A Did not pertain to me.
18 ruled to dismiss the case? 18 Q Why do you think it didn't pertain to
19 A I never went through something like 19 you?
20 this. I didn't know what to expect. 20 A Because I was computer tampering and the
21 Q You testified that something had to be 21 other one was eavesdropping. I had nothing to do
22 rescheduled because your husband, ex-husband was 22 with that.
23 present in court. When was that? 23 Q Did it cause you any regret that
24 A I don't remember. It was before the 24 Ms. Melongo was never convicted of any of the
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1 charges against her? 1 life again. I wanted to be free. But I went to a
2 MR. NINFO: Objection; form. 2 lot of uneasy things.
3 THE WITNESS: Only that I went through such 3 Q Did you have any involvement in the
4 hell on -- with false accusations, being stalked, 4 investigation on Ms. Melongo for allegedly
5 and everything else. Besides that, God put me here 5 threatening a public official?
6 for a reason and he took it away for a reason. 6 A No, that was a surprise to me.
7 By Ms. Schwartz: 7 Q The Attorney General Charitable Bureau
8 Q You testified that you were aware that 8 investigated Save a Life finances as we know; did
9 Ms. Melongo was prosecuted for criminal 9 it not?
10 eavesdropping; is that correct? 10 A We did a close out. And because of way
11 A That again was not anything to do with 11 we closed out, everything was fine. They talked
12 me. So I was limited to know about that. 12 with our accountant and never heard from them
13 Eavesdropping did occur with -- with 13 again.
14 other people that were with the original case. But 14 In fact, I know that they were hounding
15 had nothing to basically do with me. 15 the attorney generals office because they posted it
16 Q Did you have any involvement whatsoever 16 on line all of the time. And the attorney general
17 in the investigation or prosecution of Ms. Melongo 17 said everything was, what do they call that. There
18 for criminal eavesdropping? 18 was nothing there.
19 A No. 19 A There was nothing there.
20 Q How did you become aware that 20 Q The Attorney General's office reached a
21 Ms. Melongo was investigated or prosecuted for 21 conclusion.
22 criminal eavesdropping? 22 A Oh, yeah. Yeah.
23 A Because she -- she put it on her blog 23 Q Was that in writing?
24 everywhere. 24 A Yeah. Yeah. It was sent to Peter
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1 It was brought to my attention by the 1 Heimlich.


2 State's Attorney's office. So that was about the 2 Is that it?
3 extent that I know. It was before our case, our my 3 MR. NINFO: Just.
4 case was postponed. So they could deal with the 4 (A document was marked Plaintiff's
5 eavesdropping. 5 Deposition Exhibit No. 29 for
6 I probably would say that that was 6 identification.)
7 probably the only thing that upset me. Since the 7 By Ms. Schwartz:
8 eavesdropping came in after, I felt that our 8 Q One moment. I'm handing you Plaintiff's
9 computer tampering should have been taken care of 9 Deposition Exhibit No. 29. CCSAO 09O35.
10 first, but. 10 Is this a true and accurate copy of an
11 Q Were you upset the prosecution elected 11 email to Robert Podlasek and Julie Gunnigle on
12 to start pursuing the eavesdropping case and put 12 August 5, 2010?
13 the computer tampering case on hold? 13 A Okay.
14 A It upset me because it gave her time to 14 Q Is this an email that you sent to Julie
15 do -- I can't think of the word. I -- she did 15 Gunnigle and Robert Podlasek with attachments
16 subpoenas and retrieved all six years of my banking 16 related to Attorney General investigation?
17 records during that time and went after my American 17 A This was the first, yeah. But then
18 Express to do the same. 18 there was follow up.
19 And then I notified the State's Attorney 19 Q Follow up email with Robert Podlasek and
20 office and he put a squash on it. I think that is 20 Julie Gunnigle?
21 what it is called. And retrieved all of my banking 21 A No. By the Assistant Attorney General.
22 records at the time of the hearing. And I would 22 Q Let's talk about this document.
23 like to have had it all done and over with my 23 A Okay.
24 portion of it, because I wanted to be -- have a 24 Q Exhibit 29 first.
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1 A Uh-huh. 1 MR. NINFO: According to my stopwatch.
2 Q You sent him email August 5, 2010, and 2 MR. WUNDER: Not down to the exact minute.
3 attached an email from someone at the Illinois 3 By Ms. Schwartz:
4 Attorney General Charitable Trust Bureau from two 4 Q SO is Exhibit 30 a true and accurate
5 days earlier August 3, 2010. That is the second 5 copy of an email you sent to Julie Gunnigle and
6 page of Exhibit 29, correct? 6 Robert Podlasek dated August 10, 2010.
7 A Uh-huh. Yes. 7 A I can't be -- it looks real.
8 Q And you ask -- that's someone name Trudy 8 Q You write, you write about someone named
9 Motyka, correct? 9 Steven Garrels is that Save a Life's auditor?
10 A Apparently. Uh-huh. 10 A Yes, ma'am.
11 Q And you ask, in the 4th paragraph first 11 Q You say he, quote, "He received a letter
12 page of Exhibit 29. Why does she need more. I 12 from Charitable Trust Trudy Motyka - whom we
13 filed in timely matter SALF's tax statement filed 13 discussed last week, asking for information, much
14 out by C.P.A. and copy of IRS report. You are 14 duplicated from what Charitable Trust already has
15 referring to Trudy Motyka request for information 15 on file and what I personally sent"
16 about Save a Life Foundation? 16 And then at the bottom you said, "This
17 A Yes. 17 has escalated into harassment and Steve would
18 Q Why were you asking Julie Gunnigle and 18 appreciate your guidance."
19 Robert Podlasek what to do about the Attorney 19 Are you referring to Mr. Garrels, your
20 General Office request? 20 auditor's, communications with Trudy Motyka as
21 A Because I was confused. I didn't know 21 harassment?
22 how to handle this. I did everything by the book. 22 A No, ma'am.
23 Q In the letters from Trudy Motyka that 23 Q What was the harassment referred to in
24 are attached she is requesting financial 24 Exhibit 30?
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1 information about Save a Life Foundation; isn't 1 A Lee Cary. He claimed to be a reporter
2 she? 2 and he was constantly calling him. And he was
3 A Yes. 3 affiliated with Peter Heimlich.
4 Q Did you respond to her email dated 4 Q So what is the relevance of the mention
5 August 3, 2010? 5 of Trudy Motyka of the Illinois Attorney General's
6 A I did. 6 office in this email?
7 Q Did she respond to you after that? 7 A We reported to them four times a year.
8 A No. Because our accountant our C.P.A. 8 As far as our Charitable, our financial statements.
9 we had ever year we had four times a year we had 9 Q So did you ever accuse Ms. Melongo of
10 C.P.A. that wasn't connected to our independent 10 destroying financial records from Safe a Life
11 C.P.A.. Do our reports. And so the C.P.A. 11 Foundation?
12 followed up. And that was it. That was the end. 12 A No, ma'am.
13 Q Then there was no further follow up from 13 Q Did you ever accuse Ms. Melongo of
14 Trudy Motyka. 14 destroying accounting records from Save a Life
15 A No, ma'am. 15 Foundation?
16 (A document was marked Plaintiff's 16 A No, ma'am.
17 Deposition Exhibit No. 30 for 17 Q Were any financial records destroyed
18 identification.) 18 After the April 28, 2006 alleged intrusion?
19 By Ms. Schwartz: 19 A No, ma'am.
20 Q Handing you Plaintiff's Deposition 20 Q So in November, in November of 2006,
21 Exhibit No. 30. CCSA0 09979. 21 ABC News in Chicago aired two investigative reports
22 MS. NINFO: Did we have on the record count. 22 by Chuck Goudie about you and Safe a Life
23 MR. WUNDER: We are at 6:38 or so according to 23 Foundation; is that correct?
24 my calculation. 24 A Yes, ma'am.
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1 Q I'll refer to those as the Chuck Goudie 1 A No. That is not all correct.
2 reports just for simplicity sake. Is that okay? 2 Q Why is that incorrect?
3 A Okay. 3 A He accused me of being responsible for
4 Q Is that okay with you? 4 the death of my daughter and he filled in the
5 A That's fine. 5 blanks.
6 Q When did you learn about the Chuck 6 Q He also accused you of misstating your
7 Goudie reports? 7 credentials and educational credentials; didn't
8 A I'm sorry, I don't quite understand that 8 he?
9 question. When did I learn of the Chuck Goudie 9 A That I answered correctly. And he put
10 reports? 10 in the blanks.
11 Q When did you first see Chuck Goudie's 11 Q I'm just asking you what his allegations
12 investigative reports on TV? Was it around the 12 were. Right now I am not asking whether they are
13 time they aired? 13 true or what he alleged.
14 A No. It was -- when did he show up at 14 I'm just asking what Chuck Goudie's
15 our office, you're referring to? 15 allegations were in the reports in November of
16 Q My question is, there were two news 16 2006?
17 investigative reports on ABC local news, by Chuck 17 MR. NINFO: Answer her question, okay.
18 Goudie, I believe. 18 By Ms. Schwartz:
19 A Right. 19 Q Did those reports of Chuck Goudie allege
20 Q It was November 16 and 17th of 2006; is 20 that you misstated your educational credentials?
21 that right? 21 A That is what he said.
22 A Yes. 22 Q And did those reports by Chuck Goudie
23 Q When did you first learn of those two 23 allege that Save a Life had inaccurately
24 reports November 16 and 17th, 2006 ABC News 24 represented how many individuals were trained by
293 295

1 reports? 1 the organization?


2 A Well, he showed up at our office. And I 2 Were those Chuck Goudie's allegation.
3 was willing to speak with him. I had nothing to 3 A That was his allegations.
4 hide. And so I treated him like any other 4 Q I'd like to go over a few of those
5 reporter. I showed him all what we did. And proof 5 allegations. I would lake to discuss your
6 that we did what we did. 6 credentials first.
7 And then, when I gave him verification 7 In promotional materials for Save a Life
8 to prove what we did, it seemed to go on deaf ear. 8 Foundation, you represented that you were a
9 And then to find out that he reported something 9 registered nurse; is that correct?
10 that was fraudulent. 10 A That was only on the website, which I
11 Q So my question was simply, did you -- 11 did not control.
12 I know -- so Chuck Goudie I know came to your 12 There were other times that there were
13 office and interviewed you prior to the Chuck 13 articles because I dealt with this type of medical
14 Goudie reports -- 14 stuff, they assumed, but I always wrote on all of
15 A Yes. 15 my documents president/founder.
16 Q -- being aired, correct? 16 Q So you were not a registered nurse?
17 A Yes. 17 A No.
18 Q Once those reports were aired on 18 Q Have you ever been a registered nurse?
19 television, did you learn about them right away, 19 A No.
20 right after they came out? 20 (A document was marked Plaintiff's
21 A I did, yes. 21 Deposition Exhibit No. 31 for
22 Q And the Chuck Goudie reports, allege 22 identification.)
23 that certain statements about your credentials were 23 By Ms. Schwartz:
24 inaccurate. Is that correct? 24 Q I'd like to direct your attention to
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1 Plaintiff's Deposition Exhibit 31. Melongo_006060 1 By Ms. Schwartz:
2 to 6067. 2 Q I'm referring to the second page, bottom
3 MR. NINFO: I will object to this whole line 3 right corner, of Exhibit 31. So this bottom right
4 of testimony just for the record because it is 4 corner where it says RN, second page of Exhibit 31,
5 completely irrelevant to Annabel Melongo, her 5 that is inaccurate, correct?
6 charges, her criminal case, or anything of this, 6 A That is inaccurate.
7 but go ahead. 7 (A document was marked Plaintiff's
8 By Ms. Schwartz: 8 Deposition Exhibit No. 32 for
9 Q Is Exhibit 31 an application for Federal 9 identification.)
10 assistance, Ms. Spizzirri? 10 By Ms. Schwartz:
11 A Yes. 11 Q I'm handing you Plaintiff's Deposition
12 Q And it's essentially an application for 12 Exhibit No. 32. CCSAO 008053 to 8054.
13 grant money; is that right? 13 A Even here it says only president
14 A This was an extension of a grant. Wait 14 founder. It doesn't say RN.
15 a second. 2004. 2004. I can't remember what day, 15 Q For the record, Ms. Spizzirri was
16 but it is possible this is the date, yes. 16 referring to the page marked Melongo_006063.
17 Q And is that your signature on the bottom 17 Ms. Spizzirri, is Exhibit 32 a true and
18 left of the first page of Exhibit 31? 18 accurate copy of my -- apart of Save a Life annual
19 A Right. That is how I signed 19 report from 2006, 2007.
20 president/founder. 20 A It appears to be.
21 Q If you turn to the second page, at the 21 Q If you could turn to second page of
22 bottom right under where it says highest degree 22 Exhibit 32.
23 earned it says RN BS. 23 A Uh-huh.
24 A This -- 24 Q It says, Safe a Life Foundation, SALF, a
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1 Q So my question for you, Ms. Spizzirri? 1 not-for-profit Foundation was founded in 1993 by
2 A Yes. 2 Carol J. Spizzirri, RN. That's an inaccurate
3 Q On this document, that you submitted for 3 statement as well, correct?
4 Federal grant, and that you signed, you say your 4 A That is true. It wasn't written by me.
5 highest degree earned was RN, registered nurse? 5 It was written by my staff.
6 A They -- the person who filled this out, 6 Q In other documents refer to you as
7 probably was my accountant at the time and assumed. 7 B.S.N., which is a Bachelor of Science in Nursing,
8 Because I mean, my -- these are standard forms that 8 correct?
9 would have been filled out like in accounting 9 A That would be what that would represent.
10 department. And if I wasn't at the office, they 10 Q Did you ever have a B.S.N., Bachelor of
11 would just fill it out and pass it on. 11 Science in Nursing?
12 Q You didn't review this before you signed 12 A No.
13 it? 13 Q Is there any promotional materials from
14 A And I may not have signed it because I 14 Save a Life Foundation that said you had a B.S.N.
15 can't see it. It may have been electronic because 15 A Was inaccurate.
16 my signature was -- 16 Q Was inaccurate?
17 MR. NINFO: Right. 17 A Right. I didn't make the promotional
18 THE WITNESS: -- on file. 18 material. I trusted others.
19 MR. NINFO: Are you pointing to a signature of 19 (A document was marked Plaintiff's
20 hers on the second page? 20 Deposition Exhibit No. 33 for
21 MS. SCHWARTZ: No, the signature is on the 21 identification.)
22 first page? 22
23 MR. NINFO: Oh. 23
24 24 By Ms. Schwartz:
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1 Q Handing you Plaintiff's Deposition 1 By Ms. Schwartz:
2 Exhibit No. 33, which is Melongo_002169 to 2170. 2 Q My question was, isn't it true that your
3 Is Exhibit 33 a true and accurate copy 3 daughter died in single vehicle car crash?
4 of your biography from the Save a Life Foundation's 4 MR. NINFO: Same objection. Argumentative.
5 Website, which had been retrieved June 14, 2006? 5 THE WITNESS: It depended who you spoke to.
6 A I basically don't know if it is true and 6 By Ms. Schwartz:
7 accurate when it was taken. 7 Q Did the death certificate state that
8 Q At some point did your biography on Save 8 your daughter passed away in single vehicle car
9 a life website say B.S.N after your name? 9 crash?
10 A I just saw that after it was brought to 10 A Yes, the death certificate said that.
11 my attention. Because I did not do our website. I 11 Q So this statement in Exhibit 32, that
12 had no time for that. 12 she passed in a hit and run incident is inaccurate;
13 Q This statement on Exhibit 33, Carol J. 13 isn't it?
14 Spizzirri, B.S.N. is inaccurate as well, correct? 14 MR. NINFO: Objection and form.
15 A Yes. That is inaccurate you said? 15 THE WITNESS: It depended who you spoke
16 Q Inaccurate. 16 with.
17 A Yes. 17 By Ms. Schwartz:
18 Q Let's turn back to Plaintiff's 18 Q I'm asking you?
19 deposition No. 32. You write in the second page 19 A According to what I was able to find
20 of -- it says in the second page of Plaintiff's 20 out, it was from witnesses, it was another car
21 Deposition Exhibit 32. Save a Life Foundation was 21 involved.
22 founded quote, "After her 18-year old daughter, 22 MS. SCHWARTZ: I have no further questions.
23 Christina Jean Spizzirri, bled to death following A 23 MR. NINFO: I just have a couple very very
24 hit and run incident on Labor Day, 1992." 24 quick questions.
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1 Isn't it true that your daughter passed 1 EXAMINATION


2 away in A single vehicle car crash, not A hit and 2 By Ms. Ninfo:
3 run accident? 3 Q Have you personally ever told anybody
4 MR. NINFO: Objection. Argumentative. 4 that you were a registered nurse?
5 THE WITNESS: I had -- I had a few prominent 5 A No.
6 doctors review my daughter's death certificate, 6 Q Okay. You are a certified nursing
7 hospital run sheet, et cetera, et cetera. And they 7 assistant, correct?
8 concluded that she bled out before EMS arrived. 8 A Medical assistant.
9 Simple first aid would have saved her life. 9 Q And you had -- you have a certified
10 The coroner is an elected official with 10 nursing assistant as well?
11 no medical background. So I depended on outsiders 11 A That's correct.
12 that had a reputable. One was Dr. Lance Becker, 12 Q You have both of those certifications
13 University of Chicago Medical Center. And 13 with medial background, correct?
14 Dr. Ernesto Preto, University of Pitsburg Medical 14 A Correct.
15 Center, both emergency room physicians and 15 Q Did any of the grants that Save a Life
16 world-renowned review her -- all of the run sheet, 16 Foundation ever received were they in any way,
17 everything. And it was their conclusion that she 17 shape, or form, ever dependent on the fact that you
18 bled out and simple first aid would have saved her 18 were a registered nurse?
19 life. 19 A No.
20 Q My question was not about medical cause 20 MR. NINFO: I have nothing further.
21 of death? 21 Chris.
22 MR. NINFO: Listen to her question. 22 MR. WUNDER: I just have a few things.
23 23
24 24
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1 EXAMINATION 1 I believe you testified earlier that
2 By Mr. Wunder: 2 when the -- I believe its Marrazzo, an
3 Q Ms. Spizzirri, you gave specific 3 Officer Marrazzo came and spoke to you and the
4 testimony about the effects of the intrusions on 4 other SALF employees, that he spoke to a group of
5 the SALF servers and the email systems earlier. I 5 you; is that correct?
6 just want to clarify exactly the source of your 6 A I really -- I can't remember that.
7 testimony, if you will? 7 Q There was a statement on here that you
8 A Please. 8 said was inaccurate when you first testified and it
9 Q Is it fair to say that you're depending 9 is regarding the fact that she is -- where is that.
10 on other peoples' assessments of the situation 10 That she was a -- she is not a U.S. citizen and a
11 regarding the intrusions? 11 flight risk. That is on Exhibit 3. Do you see
12 A I'm sorry. 12 that there?
13 Q I'm tying to figure out what you know 13 A Yes, sir.
14 from personal knowledge and what you have been told 14 Q Okay. When you testified earlier you
15 by other people about the intrusions that happened 15 gave testimony about that, and also if you look on
16 on the SALF system. 16 Exhibit 5, this is letter that you wrote to Dick
17 A It was -- 17 Devine, where you also make that same statement.
18 Q Okay. 18 Do you see that at the bottom there?
19 A Okay. 19 A Yes.
20 Q Is your knowledge based solely on what 20 Q So does it help refresh your
21 other people told you happened regarding the 21 recollection that when the officer took this report
22 intrusions? 22 that you did, know that she was a foreign
23 A Yes. 23 national?
24 Q Those people were the investigators 24 A It was apparently between the 6th and
305 307

1 involved; is that correct? 1 the 8th between those two days that it was brought
2 A Yes. 2 to my attention at that time. I am not sure how I
3 Q And those people were the third-party 3 would have known that. I cannot remember how I
4 vendors that you hired -- 4 found out that she was here on a visa, an education
5 A Yes. 5 visa. I would suspect that it came from the
6 Q -- is that correct? Yes? 6 investigation of the police into her background.
7 A Yes, sir. 7 Because Robert Half did not do any background,
8 Q So you're more or less deferring to them 8 they didn't require background check from what I
9 when it comes to the specifics of the intrusion; is 9 found out.
10 that correct? 10 So between the time of the incident and
11 A Absolutely. 11 the time of my statement, as when I discovered
12 Q Okay. And then that is regarding the 12 that.
13 affects of the intrusions. How about how the 13 Q And there are no other inaccuracies in
14 intrusion actually happened, your deferring to 14 this report; is that correct?
15 third parties? 15 A I don't think so. No.
16 A Yes, sir. 16 Q And also just real quickly, Exhibit 6.
17 Q Okay. I would like to look at 17 A Yes.
18 Exhibit 3 real quick. Then if you don't mind also 18 Q You gave some testimony interpreting the
19 Exhibit 5. Kind of at the same time. 19 code and the metadata that is on attorney General
20 A Okay. 20 1202.
21 Q Do you have both of those in front of 21 A 1202.
22 you? 22 That's Exhibit 6.
23 A Yes. 23 Q That's correct.
24 Q I want to clarify a couple of things. 24 A 1202.
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1 Q It is few pages in? 1 A No.
2 A Oh, I see. 2 Q Okay.
3 MR. NINFO: The little one. That number. 3 A I mean, I'm sorry. I should -- I'm
4 THE WITNESS: Okay. 1202, okay. 1201 or 4 speaking out of -- are you talking about the whole
5 1200? 5 Attorney General's office?
6 By Mr. Wunder: 6 Q No. No. I said Cook County State's
7 Q 1202. 7 Attorney?
8 A Oh, okay. 02, okay. Got you. 8 A Oh, Cook County State's Attorney? No.
9 Q And there is a some code there and some 9 Q And --
10 metadata. You gave some testimony earlier about 10 A Except for Dick Devine, you know, before
11 that. Do you actually know what any of that data 11 this happened. Are you referring to?
12 there means? 12 Q Okay.
13 A No. 13 A I'm sorry, I misunderstand.
14 Q No? 14 Q Okay. And you voluntarily reached out
15 A No. I just saw words and it looked 15 to the then State's Attorney Dick Devine to do
16 good. 16 what?
17 Q Okay. So when you were giving your 17 A I knew of Mr. Devine briefly from being
18 testimony, you're more or less speculating as to 18 introduced by one of our Board members in the past.
19 what that means; is that correct? 19 And my Board member Mayor Rita Mullins knew him
20 A Yeah, right. Right. 20 quite well. And that's how the first meeting I
21 Q Okay. 21 reached out to him because this was, I was told the
22 A I recognize the vip geeks. Vip geeks. 22 first time that a computer not tampering but when
23 Because they were the ones that connected us to the 23 somebody intrudes. Computer intrusion, had a
24 website. They were like an independent. And so 24 occurred in Illinois even though there were laws on
309 311

1 that's what drawed my attention to that. 1 the books, but no one had ever really prosecuted.
2 Q Okay. So let's go to Exhibit 11 real 2 So when it came time that they had, the
3 quick. 3 Schiller Park Police had done investigation as to
4 A Yes, sir. 4 who might have been involved with why we went down,
5 Q Now, you also gave some testimony about 5 he was having difficulty finding a prosecutor, who
6 the searches here and about this data here. Is it 6 wanted to take the case, due to the fact that no
7 also correct that you don't really know what any of 7 one had done it before.
8 this. Any of this means? 8 MS. BROWN: Okay. Okay thank you.
9 A I do not. 9 No more questions.
10 Q Okay. I just wanted to clarify. 10 THE WITNESS: Okay.
11 Clarify that. 11 MS. SCHWARTZ: Nothing further.
12 A Yeah. 12 MR. NINFO: Waive.
13 MR. WUNDER: That's all I have. 13 DEPOSITION CONCLUDED
14 THE WITNESS: Thank you. 14
15 MR. WUNDER: Thank you. 15
16 MS. CONWAY: I have no questions. 16
17 THE WITNESS: Yes. 17
18 MS. BROWN: I have a couple questions. 18
19 EXAMINATION 19
20 By Ms. Brown: 20
21 Q Did you have any conversations with 21
22 anyone from the Cook County State's Attorney's 22
23 office prior to Ms. Melongo being charged with the 23
24 computer tampering? 24
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1 STATE OF ILLINOIS ) < Dates > April 2nd, 2007 268:6 May 8 152:23
)SS: "May 2nd 132:22 232:7, 232:13, May 1 87:1, 207:21 May 8, 2006 130:11,
2 COUNTY OF DU PAGE ) 001201, May 1st 232:15 May 1, 2006 83:20, 135:4, 136:14,
192:5 April 2nd, 2009 84:1, 85:9, 87:11, 141:14, 142:2,
10/04/07 236:10 194:18, 195:3 87:15, 87:19, 151:17, 153:5,
3 10/4/07 234:10 April 30, 2006 97:15, 87:24, 88:15, 153:9, 153:24
I, BARBARA ANTHONY, a notary public within 10/4/07. 235:6 104:16 89:11, 115:2, May 8, 2008 143:9
4 12, July 22, 2088 August 10, 2010 134:4, 171:8, May 8th 141:18,
and for the County of DuPage and State of Illinois, 242:1 291:6 175:7, 177:21, 155:15
5 27, April '06 110:15 August 23, 2010 178:3, 179:15, May 9, 2006 155:13
do hereby certify that CAROL SPIZZIRRI appeared 28 april 114:22 270:13 208:21, 275:9 May, june 215:11
6 28, April '06 111:20, August 27, 2008 May 1, 2016 165:13 November 16
before me on May 11, 2018 as a witness in a cause 114:3 190:9, 251:12, May 11, 2018. 293:20, 293:24
7 5, May 4th134:7 251:16 147:18 November 17, 2009
now pending and undetermined in the United States 5-4-06 185:18 August 3, 2010 May 11, 2006 90:13, 255:5
8 April 2, 2007 195:22 289:5, 290:5 91:12, 92:7 November 2, 2006
District Court Northern District of Illinois April 20 176:6 August 5, 2010 May 11, 2018 1:23, 217:23
9 April 2006 44:13, 288:12, 289:2 313:8 November 2010
10
Eastern Division, wherein Annabel K. Melongo, 57:18, 156:18, December 2005 May 13, 2010 260:24 277:21
is the Plaintiff vs. ASA ROBERT PODLASEK, et al., 176:18 176:6, 176:18 May 17, 2006 November 25, 2010
11 April 2007 233:1, December 9, 2010 125:18, 203:2 276:14
are the Defendants in Case. No. 13 CV 04924 234:1, 241:4, 280:2 May 18, 2006 November 25th,
12 241:7 February 14, 2010 211:17, 212:12 2010 276:21
I further certify that the said CAROL April 26 141:19 199:6, 199:16 May 1st 181:1, October 17, 2005
13 April 26, 2006 90:24 January 6, 2010 183:16 190:23
SPIZZIRRI was by me first duly sworn to testify the April 27, 2006 57:15, 274:10 May 1st, 2006 82:11, October 2008
14 88:22 July 2014 42:1 176:21, 179:21, 159:19
truth, the whole truth and nothing but the truth in April 28, 2006 65:11, July 22, 2008 182:23, 185:19 "one 99:1
15 65:15, 65:21, 236:23, 240:7, May 2006 152:12, $100,000 221:1
the cause aforesaid before the taking of his 69:11, 72:7, 244:9, 246:22, 157:18, 201:13, $11,827.77. 253:7
16 87:20, 88:2, 249:8 201:16, 211:2 $114,541.87. 223:6
deposition; that the testimony given was 93:11, 101:4, July 22nd 249:19 May 26, 2006 154:14 $12,000 221:19
17 103:2, 104:4, July 22nd, 2008 May 31, 2019 314:14 $12,552. 223:22
stenographically recorded in the presence of said 168:5, 168:8, 243:5, 249:6 May 4 139:4 $2,806 195:14
18 170:23, 226:6, July 23, 2008 245:8 May 4, 2006 184:21, $2,886.00 195:24
witness by me, and afterwards reduced to 292:18 July 23rd 245:9 185:16, 187:17 $2,886.00. 195:20
19 April 28th 93:19, July 29th, 2017 34:5 May 4th 197:19, $235 212:15
typewriting, and that the foregoing is a true and 171:22 July 9, 2007 235:7 197:20 $286,000 196:20
20 April 28th, 2006 July 9, 2008 234:8, May 4th, 2006 $286,154.13. 195:15,
correct transcript of said testimony. 73:11, 73:23, 235:12, 236:1, 197:19 196:11
21 74:4, 74:14, 75:9, 236:8, 237:19, May 5 108:21 $32,000 254:18
I further certify that there were present 75:24, 78:3, 237:20, 237:23, May 5, 2006 108:8, $32,360. 254:1
22 78:13, 80:12, 239:15, 239:22 108:22, 109:11 $320 212:16
at the taking of this deposition the aforementioned 80:19, 80:24, July 9th 235:9 May 5th 113:24 $375.42 214:11
23 81:3, 81:22, June 14, 2006 301:5 May 5th, 2006 110:9, $46,518 223:21
counsel. 103:12, 115:2, June 22, 2006 214:7 112:5, 112:21, $5,000 225:21, 226:3
24 150:12, 167:20 June 22nd 215:5 116:2, 117:20, '65 17:18
April 2nd 210:18 June 26, 2010 265:6, 118:5, 119:7 '67. 17:18
313 315

'86 17:22 084-003185 1:20, 236:22, 237:15, 17th 293:20, 293:24


1 I further certify that I am not counsel (see 232:20 314:13 242:1, 244:8, 18 222:6, 222:10,
)SS 313:2 09127. 279:21 244:13, 246:22, 222:11, 222:14
2 for nor in any way related to any of the parties to 09132. 265:4 250:22, 251:3, 18-year 301:22
09185. 270:11 251:11, 252:15 180 1:22, 2:5, 2:28,
3 this suit, nor am I in any way interested in the <0 > 09268. 260:21 12. 193:8, 193:24, 148:17
000000514. 125:10 09270 199:3 196:6, 197:19, 18222 4:43
4 outcome thereof. 000001067. 274:7 09979. 290:21 214:6, 237:21, 184 4:36
000001068 255:3 09O35 288:9 240:11, 250:3, 187. 154:10
5 IN TESTIMONY WHEREOF, I have hereunto set 000002 184:19 276:12 189 4:37
000044 211:12 1200 309:5 19 224:23, 225:3,
6 my hand this 30th day of May A.D., 2018. 000106 96:22 <1 > 1201 174:5, 174:7, 225:4, 225:8,
000111 102:3 1 4:26, 90:5, 90:8, 309:4 226:4
7 000183. 225:3 90:11, 92:14, 1202 308:24, 309:4 19224 5:5
000185 154:10 92:24, 94:7, 1202. 308:20, 195 4:38
8 000209 164:18 101:16, 136:16, 308:21, 309:7 1967 17:23, 18:8
9 000546 108:3 140:6, 207:10 1205. 134:18 198 4:39
000656. 130:9 1. 93:15 12189 4:37 1980 33:22
10 001198 134:18 10 172:9, 172:13, 125 4:29 1980. 18:23, 18:24
001198. 141:16 172:14, 172:21, 12:56 236:8 1980s 33:23
11 ___________________________ 001200 174:4 174:12, 178:18 12th 70:16 1984. 19:1
Barbara Anthony, CSR, RPR 001200. 167:6 10. 174:24, 179:4, 13 4:38, 195:7, 1986 18:9, 18:15,
12 CSR No. 084-003185 001201 140:12, 180:1 195:11, 195:12, 18:20, 26:12,
Expires May 31, 2019 174:18, 179:13, 10/4. 235:5 197:7, 251:21, 26:14
13 183:11, 185:21, 100 3:8, 256:16, 251:24, 313:14 1986. 17:22
192:5 273:1 13-CV-04924 1:9, 1992 21:1, 21:2,
14 001202 140:13, 10172 4:35 148:9 21:8, 22:17,
181:8, 182:15 107 4:28 130 4:30, 259:17 22:23, 23:2, 23:10
15 001202. 180:3, 11 4:36, 184:15, 134 4:31 1992. 301:24
181:22 184:19, 184:20, 14 198:22, 199:3, 1993 300:1
16 001203. 140:14 186:2, 186:13, 199:4 1996 63:21, 72:23
001204. 136:7, 137:6 187:8, 187:13, 14198 4:39 1996. 63:6
17 001365 90:6 189:8, 198:7, 15 4:40, 200:5, 200:9 1997 264:13
002043. 222:10 198:10, 198:11, 15. 136:16 1:15 147:18
18 002063 242:6 198:18, 199:10, 150 4:8, 256:16 1:28 148:16
002066. 244:23 310:2 154 4:32
19 002197 159:13 11. 198:6 155 3:16
002226 195:11 113. 96:22 159 4:33 <2 >
20 002232 237:15 11:31 179:21 16 4:41, 136:17, 2 4:27, 93:15, 96:22,
002232. 232:11 12 189:19, 189:23, 211:8, 211:13, 97:2, 97:8, 98:23,
21 002233. 189:23 189:24, 190:2, 211:16, 212:14 99:22, 101:16,
005385. 200:9 190:12, 190:21, 16. 211:12, 211:22 102:2, 102:20,
22 008053 299:12 191:20, 194:2, 164 4:34 104:15, 181:4
0100-0300 111:21 194:5, 195:19, 17 4:42, 217:16, 2,000 195:20
23 012511 276:12 195:23, 196:23, 217:21, 218:1, 2. 99:11, 110:15,
012532. 235:19 196:24, 197:3, 218:6 207:10, 243:23
24 02 309:8 197:5, 197:22, 17. 217:19 20 5:6, 70:6, 230:8,
04924 313:14 198:8, 232:5, 172 4:35 235:15, 235:19,
314 316
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 81 of 93 PageID #:2069
2018
235:20, 236:7, 277:9 24/7. 72:12 307:11 290:8, 298:7 169:18, 170:4, addressed 99:13, 175:12, 313:21
237:23, 240:3, 2008. 163:4, 200:22, 242 5:7 30 72:19, 290:17, accountants 252:1 223:8, 237:5, 130:14, 155:11 AG1 192:4
266:17 248:24, 249:7, 25 5:11, 270:7, 291:4, 291:24 accounting 81:2, 240:16, 241:14, addresses 88:20, agencies 259:8
20. 237:17, 248:3 249:14, 277:5 270:11, 271:18 30. 290:21 292:14, 298:9 246:23 103:9 agency 203:16,
200 4:40 2009 15:4, 39:15 25. 270:10 300 5:19, 110:7 accounts 112:9, Activities 190:22, administer 236:24, 203:21, 204:3
200. 195:21 2009. 226:19 254 5:8 30290 5:16 183:21, 193:3, 191:3, 214:14, 242:20, 243:6, agree 92:15, 101:2,
2000 21:1, 26:12, 2010 20:20, 20:23, 26 5:12, 274:3, 304 4:11 213:9, 213:14, 232:5 244:10, 244:15 113:18, 115:6
72:22, 72:23, 21:8, 23:10, 274:7, 274:8 305 4:14 242:20, 243:6 actual 36:16, 76:12, administration agreement 13:1,
207:10 23:23, 25:2, 26. 276:9 30th 314:6 accurate 8:20, 8:24, 77:10, 77:15, 201:6, 201:9, 13:21, 13:23
2001 72:24 25:18, 26:3, 26:14 260 5:9 31 5:17, 296:21, 90:15, 94:16, 186:14, 203:23, 247:24 Ah 281:21
2002 152:5, 152:7 2010. 20:19, 26:1 264 5:10 297:9, 297:18, 97:14, 109:20, 283:1 administrator 52:6, ahead 124:3, 180:16,
2004. 297:15 2014 280:9, 282:6 27 110:15, 276:5, 299:4 112:14, 112:18, actually 28:2, 28:24, 200:13, 201:1, 191:18, 216:14,
2005. 52:19, 190:7 2016 46:24, 47:7, 276:10, 276:13 31. 297:1, 299:3 113:18, 114:2, 39:1, 51:18, 62:7, 201:2, 201:7, 246:6, 279:4,
2006 54:14, 54:17, 48:10 27. 276:12 310 4:17 114:6, 114:16, 63:19, 71:6, 201:12, 201:16, 284:6, 297:7
64:9, 64:15, 87:1, 2018. 314:6 270 5:11 312 135:15, 135:21 115:15, 115:21, 137:4, 173:5, 237:3, 240:10, aid 22:4, 302:9,
117:16, 119:17, 2064 243:23 27276 5:13 312.263.3700 2:8 125:20, 130:10, 183:5, 183:23, 240:15, 241:10, 302:18
119:21, 120:9, 2066. 245:2, 245:6 274 5:12 312.603.1902 2:21 154:17, 159:18, 192:10, 193:4, 242:3, 246:14 aired 292:21,
124:4, 127:10, 2068 246:6 276 5:13 312.621.0000 3:19 191:6, 199:4, 196:15, 207:15, administrator@salf. 293:13, 294:16,
128:15, 129:22, 20:28:24-0500 181:1 279 5:14 312.726.0531 2:31 217:21, 236:3, 261:15, 306:14, dot.org 200:18 294:18
142:23, 143:6, 20m34:7 28 5:14, 111:20, 312.814.5581 3:10 255:4, 260:23, 309:11 administrator@salf. airplane 45:13,
144:8, 152:24, 21 5:7, 242:9, 114:3, 279:17, 312.814.8283. 136:2 261:7, 265:5, add 190:16 org 201:8 45:14, 210:1
156:22, 157:7, 242:12, 243:23, 279:22 32 5:18, 299:8, 266:1, 270:11, added 223:9 advice 44:19, 48:1, airport 33:1
158:1, 171:24, 244:16 28. 279:21 299:17, 303:11 274:8, 288:10, additional 12:21, 106:2 al 1:11, 148:11,
176:13, 201:21, 21. 242:6, 242:17, 286 195:14 32. 299:12, 299:22, 291:4, 299:18, 13:11, 137:11, advise 164:9 313:12
202:20, 207:23, 243:14 286,154.13. 194:7 301:19, 301:21 301:3, 301:7 137:20, 224:11 advised 26:19, alcohol 8:22
209:18, 210:19, 2108 2:29 288 5:15 33 5:19, 300:20, accurate. 94:5 Additionally 256:9 26:24, 27:1, alerted 132:22
210:20, 212:2, 211 4:41 29 5:15, 288:5, 301:2, 301:3, accusation 266:12 address 76:9, 76:19, 95:20, 96:14 allegation 213:6,
213:1, 215:7, 212. 164:18 288:24, 289:6 301:13 accusations 152:19, 76:20, 76:21, affairs 67:12 214:13, 296:2
215:11, 234:2, 217 4:42 29. 288:9, 289:12 3415. 172:13 267:22, 272:13, 77:10, 77:15, affect 8:24, 95:9, allegations 211:20,
275:13, 292:20, 2170. 301:2 290 5:16 3600 1:22, 2:6, 285:4 77:19, 77:22, 95:13, 114:11, 213:18, 214:17,
293:20, 293:24, 2196. 159:13, 159:17 296 5:17 148:18 accuse 170:22, 84:5, 88:13, 152:17, 183:22, 219:13, 221:3,
295:16, 299:19 2197 159:16 299 5:18 3rd 195:23 278:8, 292:9, 92:17, 99:23, 193:3 222:1, 249:18,
2006. 53:2, 64:4, 22 5:8, 254:22, 2:00 64:22, 64:24, 292:13 100:3, 100:7, affected 41:3, 93:10, 295:11, 295:15,
176:7, 176:14, 255:3, 255:4, 65:2, 65:6 accused 202:4, 101:3, 101:11, 112:6, 112:8, 296:3, 296:5
176:20, 209:20 256:9, 260:12 <4 > 266:9, 266:15, 102:15, 102:18, 112:17, 178:12, allege 294:22,
2007 210:17, 233:11, 222 4:43 4 99:15, 125:9, 273:5, 273:9, 102:23, 103:6, 256:1 295:19, 295:23
233:15, 248:19, 2227. 195:11 <3 > 125:13, 125:16, 278:13, 295:3, 103:7, 103:11, affects 306:13 alleged 44:10, 64:6,
264:12, 299:19 224 5:5 3 4:28, 71:15, 126:12, 126:20, 295:6 104:1, 104:13, affiliated 292:3 69:10, 73:12,
2007. 35:8, 35:9, 23 5:9, 260:17, 107:23, 108:3, 129:4 accusing 187:20, 104:18, 105:11, aforementioned 78:3, 78:13,
195:5, 248:21, 260:21, 260:22, 108:4, 108:7, 4. 125:10 230:23, 247:4, 112:3, 112:24, 313:25 80:11, 80:24, 81:4,
248:22, 249:7, 261:23 108:11, 108:14, 400 3:17 277:6 171:15, 171:16, aforesaid 313:18 81:21, 86:24,
249:14 23. 136:18 108:19, 109:3, 4125 4:29 achieved 102:20 180:8, 180:11, afraid 273:2 87:21, 88:2,
2008 42:10, 158:21, 235 5:6 109:13, 109:19, 45 281:4 Acquaintance 125:3, 185:11, 186:16, Africa 142:15, 145:7 89:11, 93:10,
163:3, 163:8, 24 5:10, 8:23, 110:14, 111:20, 45. 211:12 125:5 186:20, 188:22, afternoon 141:9, 94:9, 97:6, 103:2,
163:14, 164:3, 264:22, 265:3, 113:17, 115:12, 4th 289:11 actions 25:11, 91:10, 189:4, 192:13, 141:17, 141:20 103:13, 104:4,
201:2, 240:24, 265:5, 266:22, 115:22, 120:2, 92:10, 93:22, 192:17, 200:18, afterthought 221:7 106:21, 107:11,
248:19, 249:12, 269:14 129:24, 306:18 134:9, 139:13, 211:19, 215:23 afterwards 103:14, 107:17, 108:16,
249:22, 252:14, 24/7 66:22 3. 110:5, 140:6, <5 > 140:21, 169:17, address. 112:4 109:22, 109:24, 110:11, 117:21,
317 319

5 4:5, 4:30, 130:4, 155:13, 156:3, ABC-7 11:9 accessed 82:10, 142:8, 150:11, 254:12 279:7, 295:9 179:20, 181:23,
130:10, 130:24, 186:5 ability 8:24, 205:22 277:7 157:6, 167:20, amounts 226:5 answers 7:11, 7:20 186:5, 190:8,
131:10, 131:13, 7. 195:4 able 28:6, 28:17, accessing 87:10, 180:12, 187:21, analysis 204:5 Anthony 1:19, 313:5, 199:7, 199:11,
132:16, 132:21, 70 72:15 28:21, 29:19, 87:14, 87:18 220:17, 233:11, analyzed 204:11 314:12 223:21, 223:23,
134:7, 138:2, 74. 199:3 69:2, 70:9, 78:19, accident 302:3 233:15, 234:2, Andrea 213:24, Antonio 49:15, 237:20, 243:23,
138:22, 139:4, 7:30 65:16 78:22, 78:23, accompany 78:24, 275:9, 292:18, 214:2 49:17 255:6, 261:3,
139:12, 140:22, 7:31 165:14 91:6, 103:15, 79:3 295:13 Angelini 3:15, Anybody 31:15, 299:20
142:13, 144:1, 113:2, 134:8, According 85:17, allegedly 72:7, 83:6, 149:12, 161:15, 33:13, 55:9, 56:8, application 297:9,
144:18, 145:2, 139:18, 152:8, 110:12, 111:9, 83:19, 84:16, 161:18 95:24, 96:3, 297:12
153:2, 307:16 <8 > 161:16, 183:5, 111:11, 139:16, 115:2, 287:4 angry 177:8, 177:20 126:16, 178:11, appraised 68:20
5. 130:8, 141:4, 8 4:33, 137:10, 194:12, 219:17, 142:4, 180:19, alleging 271:14 Annabel 1:5, 3:26, 203:20, 204:2, appreciate 48:16,
184:19, 306:19 159:9, 159:13, 219:22, 220:3, 214:18, 236:22, Allen 160:7 6:15, 52:1, 59:2, 280:12, 304:3 291:18
50 2:18, 21:12 159:18, 160:16, 246:13, 246:21, 277:8, 277:10, allow161:9, 240:16, 73:22, 110:18, anyhow44:21, appropriate 63:11,
500 2:19 161:5, 245:9, 247:13, 262:18, 290:23, 291:1, 241:15, 246:23 133:12, 133:21, 67:12, 230:2 63:12
547. 108:3 264:13 263:21, 303:19 303:19 allowed 237:5 133:22, 145:20, Apart 10:12, 10:19, appropriately 93:22
5th 132:21 8. 159:23, 162:20 above-listed 110:17 Account 30:5, 82:10, allowing 277:4 148:5, 149:20, 10:20, 15:15, approval 129:19
80 19:2 above-referenced 82:12, 82:20, Almost 70:6 161:8, 166:15, 20:9, 30:21, approve 258:20
8054. 299:12 225:13 83:7, 83:10, alone 215:20 167:24, 170:17, 31:15, 33:8, 33:11, approximately 176:2
<6 > 80s 22:15 Absolutely 114:1, 83:11, 83:15, already 87:6, 87:19, 175:16, 181:24, 40:8, 48:20, April 52:24, 64:4,
6 4:31, 134:17, 8:51. 245:12 177:6, 306:11 83:16, 83:20, 88:1, 88:10, 190:23, 193:13, 63:20, 78:9, 64:9, 64:15, 81:3,
134:20, 134:24, 8th 308:1 absorb 71:16 83:24, 84:1, 105:8, 152:14, 194:9, 195:13, 86:14, 89:12, 127:10, 156:22,
135:18, 136:13, abuser 266:17, 84:19, 84:23, 162:16, 193:7, 199:12, 214:14, 105:8, 132:15, 176:8, 176:11,
139:2, 139:22, 266:19, 273:6, 84:24, 85:13, 220:13, 256:12, 225:14, 232:6, 138:4, 156:24, 201:13, 201:16,
140:1, 141:15, <9 > 273:9 86:17, 87:1, 87:11, 291:14 234:13, 236:16, 157:1, 182:11, 232:12, 232:14,
166:22, 173:17, 9 4:34, 164:14, academy 22:5 111:24, 112:2, altered 92:12 238:4, 238:18, 224:11, 226:2, 233:11, 233:15,
173:18, 174:3, 164:18, 164:19, accent 53:18 112:16, 112:23, Although 268:15 243:9, 243:15, 233:13, 261:1, 248:20
174:17, 179:10, 165:19, 168:16, accept 56:11, 169:6 114:23, 134:12, Amazon 212:13 251:12, 253:16, 281:11, 299:18 Argumentative
181:22, 182:14, 169:9, 172:15 access 86:24, 88:16, 178:2, 178:3, American 45:17, 266:6, 267:7, apologize 18:19 278:16, 302:4,
185:22, 192:6, 9. 165:3, 166:11, 89:11, 103:8, 178:23, 178:24, 194:14, 194:20, 267:12, 268:19, Apparently 53:10, 303:4
193:10, 308:22 171:2 183:14, 192:21, 179:8, 186:6, 195:24, 209:21, 297:5, 313:11 54:22, 91:13, arising 222:22
6. 137:24, 153:3, 90 4:26, 69:17, 194:23, 194:24, 189:14, 196:1, 210:5, 210:9, Annabel-blackberry 93:23, 103:7, Around 18:20, 25:2,
166:6, 167:4, 115:14, 115:18, 201:7, 201:13, 206:11, 207:16, 210:23, 211:2, 261:23 105:14, 114:12, 52:20, 53:12,
186:4, 308:16 152:3 201:16, 206:14, 208:21, 213:3, 212:20, 219:19, Annabel. 255:8 138:10, 141:11, 58:9, 65:15,
60601 2:7, 2:20, 97 4:27, 71:15 210:13, 232:18, 213:18, 233:9, 219:23, 220:2, annual 299:18 143:11, 143:13, 97:15, 113:9,
2:30, 3:9, 3:18, 9950 110:6, 211:18 233:2, 233:5, 234:12, 234:13, 220:4, 220:6, Answer 8:6, 8:12, 180:18, 266:3, 118:7, 119:16,
149:13 9:00 1:24 233:11, 233:15, 236:15, 238:4, 220:9, 224:20, 12:24, 13:5, 289:10, 307:24 120:9, 129:22,
6067. 297:2 @salf.org 215:23 233:24, 234:13, 242:24, 277:3 233:18, 233:19, 13:24, 14:16, appear 138:5, 138:6, 151:16, 157:18,
66 245:19 237:5, 237:9, account. 234:15, 237:6, 237:7, 14:17, 14:18, 159:13, 165:17, 158:1, 163:2,
66. 90:6, 245:20 237:11, 238:17, 236:18 247:5, 247:15, 18:6, 40:5, 48:17, 172:18 163:8, 163:14,
68 242:6 < A> 240:17, 240:20, accountant 45:16, 248:7, 286:17 51:11, 56:1, 68:7, APPEARANCES 2:1, 175:7, 190:15,
69. 255:3 a.m. 1:24 240:23, 241:4, 196:14, 197:4, AMEX 210:22, 253:8 71:11, 77:13, 3:1, 148:23, 149:1 195:3, 212:1,
6:38 290:23 ABC 12:10, 13:15, 241:6, 241:15, 197:7, 197:16, amongst 36:9 81:18, 96:8, appeared 313:7 221:1, 233:1,
6th 307:24 14:20, 15:16, 244:4, 246:24, 209:22, 210:2, amount 94:2, 100:11, 136:21, appears 125:19, 233:15, 262:6,
24:11, 47:17, 247:24, 248:5, 210:3, 210:8, 194:11, 194:15, 211:3, 234:6, 125:22, 135:8, 270:17, 293:12
160:24, 162:7, 248:14, 256:13, 212:6, 212:19, 223:5, 224:7, 295:17 136:7, 137:19, arrest 117:1, 119:24,
<7 > 216:1, 228:11, 270:1, 277:4 212:21, 225:18, 224:11, 224:14, answered 129:10, 154:11, 154:21, 124:9, 124:16,
7 4:32, 154:6, 257:8, 292:21, access. 232:22, 252:7, 253:7, 225:23, 254:1, 133:9, 224:17, 155:17, 159:21, 276:24, 277:2
154:10, 154:11, 293:17, 293:24 247:3 254:4, 287:12, 254:3, 254:4, 249:23, 277:18, 165:14, 172:16, arrested 116:16,
318 320
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 82 of 93 PageID #:2070
2018
117:17, 124:18, 171:17, 183:19, 127:24, 128:1, Attorneys 17:12, 66:14, 83:2, 98:4 83:2, 84:3, 85:5, 310:20, 312:8 50:22, 58:21,
142:20, 142:22, 188:15, 188:21, 128:6, 128:9, 124:7, 161:16, Boston 145:14 85:12, 91:1, 91:7, BS 297:23 61:22, 61:23,
142:24, 147:9, 192:24, 193:13, 128:11, 128:12, 252:18 bottom102:2, 140:9, 97:7, 97:11, 98:9, building 39:3, 39:13, 66:8, 66:10, 81:9,
213:12, 233:10, 194:10, 198:15, 128:15, 128:17, Atty 126:1 160:6, 161:4, 98:10, 105:7, 39:21, 40:2, 86:4, 98:4,
249:17 198:17, 204:12, 128:18, 128:23, Attyg 126:1, 126:20 195:14, 196:10, 105:18, 105:19, 40:10, 200:23 130:20, 138:18,
arrival 109:15 262:21, 262:22, 129:3, 130:8, auditor 291:9, 197:22, 211:21, 106:3, 113:13, bunch 80:24, 150:2, 151:13,
arrive 70:18 262:23, 296:14, 134:17, 136:7, 291:20 214:7, 218:10, 125:17, 125:24, 174:14, 257:9 156:6, 156:11,
arrived 302:8 298:7 137:6, 140:12, authority 205:24, 232:10, 236:6, 133:1, 165:15, Bureau 287:7, 289:4 162:23, 166:16,
arrow135:21 At&t/yahoo 232:21 140:13, 141:15, 260:4 240:1, 243:23, 166:12, 167:9, Burns 242:13, 243:4, 167:24, 168:12,
article 230:21, attached 141:21, 148:31, 148:34, authorization 82:11 244:22, 245:1, 173:12, 187:7, 243:24, 244:5, 170:2, 170:17,
266:20, 271:2, 194:6, 196:10, 149:3, 149:6, authorized 238:14 246:7, 253:24, 189:16, 193:18, 245:23 200:18, 214:11,
271:3, 278:5, 289:3, 289:24 149:7, 153:17, automatic 213:1 291:16, 297:17, 207:19, 234:18, business 9:15, 9:19, 228:4, 228:7,
279:10 attachment 134:14, 155:20, 156:1, available 127:19, 297:22, 299:2, 234:19 9:20, 9:21, 18:11, 231:2, 242:21,
articles 296:13 134:15, 232:21 156:15, 156:17, 208:10, 270:2 299:3, 307:18 brief 101:21, 101:23, 27:21, 39:9, 258:10, 258:14,
ASA1:11, 148:11, attachments 139:17, 160:23, 162:15, Avenue 3:16, 110:6, bought 52:14, 193:21, 193:22 125:2, 125:5, 259:10, 272:16,
313:12 288:15 167:6, 174:3, 211:18 230:14, 230:16 briefly 311:17 126:14, 129:16, 286:21
ashamed 208:24 attack 52:7 174:17, 179:13, aware 29:17, 31:7, box 207:7 bring 91:2, 130:24, 181:17, 181:18 calling 177:21,
Aside 87:2, 87:5 attacked 160:15 180:3, 181:8, 31:18, 32:4, boxes 201:10 146:23, 150:17, buying 210:1 258:9, 266:16,
assessments attain 19:21 181:22, 182:14, 32:14, 47:17, boyfriend 61:9 151:11, 206:15 bye 281:16 272:15, 292:2
305:10 attempted 62:5, 183:10, 185:20, 59:17, 83:5, Brack 11:10 Bringing 39:7, Calloway 3:5, 6:23,
assigned 219:7, 93:20 197:12, 203:15, 104:23, 120:18, brain 281:22 67:23, 123:7, 94:23, 99:17,
237:3, 240:14, attend 279:14 207:4, 207:5, 146:15, 156:6, braking 27:24 146:16 < C> 149:5, 274:18,
242:3, 244:10, attended 19:16, 216:22, 218:13, 175:16, 200:12, brand 121:24, broadcast 162:9 Cal 122:14 280:6
244:15 40:19, 41:11, 219:6, 221:15, 200:17, 202:23, 122:13, 127:13, broadcasted 162:10 calculate 194:13, calls 37:22, 45:17,
assist 90:23, 98:11 144:5 226:16, 226:17, 202:24, 206:2, 218:19, 218:23 broke 88:19, 264:8, 254:3, 254:4 46:12, 168:3,
assistance 123:5, attention 93:14, 230:1, 230:18, 206:7, 212:23, breadcrumb 192:14 268:17 calculating 194:8, 175:2, 259:12
297:10 102:1, 125:23, 231:14, 250:4, 213:16, 213:19, break 8:10, 8:13, broken 26:21, 27:13, 252:2 Cameroon 116:9,
Assistant 2:16, 3:6, 131:1, 133:11, 250:8, 250:15, 226:4, 284:2, 8:17, 27:24, 41:6, 27:16, 27:17, calculation 290:24 116:18, 142:15,
16:8, 16:9, 17:21, 144:7, 146:17, 250:19, 250:20, 284:9, 284:15, 48:17, 55:24, 27:19, 230:12, California 25:22, 144:3, 145:7
19:10, 20:1, 20:3, 160:16, 197:18, 250:23, 251:4, 285:8, 285:20 58:24, 59:4, 264:2, 267:1 25:24, 26:2, 26:5, cancel 232:21, 241:4
50:3, 52:5, 238:10, 286:1, 252:11, 252:12, awareness 123:7 73:16, 73:17, brought 32:13, 26:18, 230:14, Canceled 194:24,
138:17, 148:34, 296:24, 301:11, 253:16, 253:21, away 162:11, 273:1, 101:23, 144:12, 39:10, 42:10, 263:7, 270:4, 214:12, 232:20,
149:6, 155:20, 308:2, 310:1 256:22, 266:11, 285:6, 294:19, 147:12, 147:13, 44:24, 51:3, 271:14 232:21, 241:7,
207:4, 250:4, attitude 110:19, 270:16, 270:24, 302:2, 303:8 152:23, 191:9, 55:12, 66:17, call 48:20, 48:22, 241:9, 283:13,
250:8, 281:2, 111:3, 111:7, 271:9, 271:11, AX 214:10, 237:6, 191:12, 231:21, 69:18, 122:2, 54:19, 55:4, 56:5, 283:18
281:12, 288:21, 111:14 271:13, 272:19, 240:17, 240:18, 231:22, 231:23 133:11, 144:7, 56:11, 62:5, capability 98:18
304:7, 304:8, Attorney 2:13, 2:16, 280:14, 280:16, 246:24, 247:2 break-in 267:24 152:7, 163:21, 69:19, 71:9, Capital 37:17
304:10 3:3, 3:6, 3:7, 10:9, 280:18, 281:2, break-ins 267:2 164:6, 256:10, 76:19, 113:6, car 302:2, 303:3,
Associate 43:21 13:5, 27:1, 27:2, 281:3, 281:12, breaking 30:5, 284:10, 286:1, 114:4, 126:11, 303:8, 303:20
Associated 136:9, 29:6, 30:22, 282:11, 286:2, < B> 30:12, 30:15, 301:10, 308:1 138:11, 157:18, Card 45:15, 45:17,
146:22, 189:4, 31:15, 48:2, 50:3, 286:19, 287:7, B.S.N301:9 145:1, 145:3, BROWN2:15, 4:17, 157:24, 158:6, 45:22, 46:4,
195:13, 252:2, 90:6, 96:22, 287:15, 287:16, Bachelor 300:7, 146:13, 268:11 6:21, 62:11, 65:4, 158:10, 158:16, 46:17, 70:9, 71:3,
253:15 102:3, 121:7, 287:20, 288:16, 300:10 breaks 8:15 125:4, 145:14, 196:18, 210:9, 71:14, 72:3,
associates 227:4 121:20, 124:7, 288:21, 289:4, back 18:22, 32:22, breath 51:10, 56:2, 148:33, 151:13, 228:1, 230:24, 117:6, 144:15,
Association 32:3 126:21, 126:23, 289:19, 292:5, 34:6, 35:8, 55:12, 273:11 152:1, 152:11, 287:17 194:11, 194:20,
assume 8:7, 33:17, 127:3, 127:9, 308:19, 310:22, 63:6, 64:21, 69:3, Brian 66:8, 66:14, 176:8, 176:11, called 1:15, 6:3, 209:14, 209:18,
168:21, 219:8 127:12, 127:16, 311:5, 311:7, 69:18, 84:8, 66:16, 67:22, 176:15, 215:9, 16:5, 42:12, 43:8, 210:19, 210:20,
assumed 28:3, 127:21, 127:22, 311:8, 311:15 85:19, 86:5, 91:7, 68:21, 81:24, 223:2, 310:18, 44:16, 44:23, 211:19, 211:20,
321 323

95:2, 95:11, 95:16, basement 27:18 156:23, 160:24, 279:13, 280:1 212:4, 213:18, 202:10, 216:12, 262:15 249:17, 252:17,
96:7, 98:2, basic 155:10 165:21, 168:13, Blackberry 28:5, 214:10, 214:12, 229:10, 250:5, certainty 94:3, 255:22, 310:23
102:15, 103:12, basically 95:4, 183:12, 184:3, 28:7, 28:24, 29:4, 214:16, 219:19, 271:19, 271:21, 94:15, 236:20 charges 32:13,
105:13, 105:15, 122:12, 192:4, 187:3, 189:10, 29:8, 29:11, 219:23, 232:19, 282:13, 282:18, certificate 302:6, 194:14, 209:14,
107:5, 115:7, 285:15, 301:6 190:6, 192:19, 29:23, 30:2, 232:21, 237:6, 283:2, 283:15, 303:7, 303:10 209:18, 209:23,
127:5, 128:15, basis 13:17, 13:20, 202:11, 216:6, 30:14, 261:11, 240:17, 247:1, 285:14, 286:3, certification 19:6, 209:24, 210:21,
134:12, 138:22, 80:18, 106:24, 216:24, 217:24, 261:14, 261:16, 248:8, 248:10, 286:4, 286:12, 19:7, 19:8 211:2, 212:4,
141:4, 141:15, 130:19 224:9, 232:23, 261:21, 262:2, 253:8 286:13, 297:6, certifications 304:12 214:10, 219:18,
144:8, 146:20, basket 283:15 233:16, 241:8, 262:17, 263:4, card/number 237:8, 312:6, 313:14 Certified 16:8, 219:24, 220:2,
160:1, 162:17, Bates 90:5, 130:8, 251:15, 253:23, 263:7, 263:9, 240:19, 247:2 cases 10:24, 11:5, 17:20, 19:10, 220:4, 220:7,
166:5, 169:23, 265:2 254:15, 268:14, 263:18, 263:21, cards 72:2, 213:9, 15:6, 15:7, 15:9, 19:23, 19:24, 220:9, 221:18,
179:10, 185:19, bearing 147:11 273:3, 274:23, 263:24, 277:14, 213:13, 215:20, 15:15, 35:11 20:2, 304:6, 304:9 233:19, 240:17,
191:17, 198:3, became 20:2, 33:24, 276:22, 293:18, 277:15, 277:17, 248:9, 249:5 Casualty 225:11 certify 313:7, 247:1, 247:6,
204:7, 204:13, 83:5, 220:12 307:1, 307:2 277:20, 278:2, care 139:8, 259:3, Casulaty 225:17, 313:15, 313:24, 247:15, 248:8,
206:15, 206:17, Becker 302:12 believes 115:23, 278:9, 278:14, 273:8, 286:9 225:20 314:1 256:9, 256:12,
207:17, 214:6, become 41:8, 270:17 278:21 career 231:19 caught 144:11 cetera 256:18, 302:7 257:18, 257:22,
214:21, 232:5, 285:20 bell 109:4 blame 239:14 Careers 52:13 cause 284:23, chance 122:5, 284:10, 285:1,
251:21, 254:9, becomes 150:21, belong 31:23 blanks 295:5, 295:10 careful 40:4 302:20, 313:8, 255:18 297:6
263:9, 266:13, 150:24 belonged 201:24 bled 301:23, 302:8, CAROL 1:15, 3:21, 313:18 change 59:4, 59:8, Charitable 250:16,
266:14, 272:21, Beem2:4, 148:26 belongings 57:8, 302:18 4:3, 6:2, 6:9, 6:18, caused 99:1, 105:15, 88:22, 89:1, 250:18, 250:20,
275:16, 275:17, begin 173:13, 57:9, 57:22, blew65:8, 69:24, 91:8, 109:16, 131:3, 222:20 126:9, 183:15, 251:1, 287:7,
301:18 175:19 59:24, 60:7 96:1 148:21, 149:15, CC133:5 234:15, 236:18, 289:4, 291:12,
background 15:21, beginning 52:24, below165:11, 173:9, blog 228:17, 228:18, 150:1, 172:20, cc'd 133:17 238:1, 239:2, 291:14, 292:8
116:12, 117:11, 221:14 238:16 256:11, 274:22, 182:3, 186:15, CCSA154:10 242:24 Chase 213:2, 213:3,
201:23, 302:11, begins 91:8 bench 282:16 275:1, 285:23 186:19, 238:13, CCSA0 290:21 changed 57:12, 213:24
304:13, 308:6, behalf 2:10, 2:23, Besides 285:5 blogs 152:15, 300:2, 301:13, CCSAO108:3, 58:14, 58:18, check 107:3, 107:4,
308:7, 308:8 2:33, 3:12, 3:21, best 123:24, 184:2, 277:12 313:7, 313:15 159:13, 164:18, 89:5, 94:8, 107:5, 107:8,
backup 65:5 148:28, 148:36, 191:24 Board 31:7, 31:22, carried 93:23 172:13, 184:19, 131:16, 132:10, 117:12, 201:23,
bad 151:24, 152:16 148:42, 149:9, bet 23:7 31:23, 32:11, Cary 266:9, 266:20, 189:23, 195:11, 132:11, 183:21, 224:19, 308:8
ballpark 18:21, 149:15 better 102:7, 158:19, 32:15, 82:5, 292:1 199:3, 200:9, 193:2, 201:4, checks 93:7
19:13 behind 38:4, 55:14, 208:16 131:6, 131:7, Case 1:8, 12:12, 211:12, 222:10, 234:1, 234:11, Chester 265:14,
Bank 17:4, 17:5, 194:1, 254:6 Bianca 2:15, 6:21, 146:12, 259:21, 13:6, 13:14, 225:3, 232:11, 236:10, 236:20, 266:11, 266:18
17:15, 17:16, believe 15:4, 17:22, 148:33 269:7, 311:18, 14:20, 32:10, 235:19, 237:15, 237:1, 240:9, Chicago 1:23, 2:7,
213:3, 213:9, 18:16, 20:13, bianca.brown@coo 311:19 34:20, 35:1, 242:6, 243:23, 243:3, 243:7, 2:20, 2:30, 3:9,
213:14, 213:18 30:1, 30:11, kcountyil.gov Bob 27:4, 27:6, 29:6, 35:21, 36:16, 244:23, 260:21, 244:2, 244:6, 3:18, 70:14,
banking 17:7, 17:8, 33:15, 39:16, 2:22, 148:35 29:13, 29:16, 36:17, 37:2, 37:4, 265:3, 270:11, 246:2, 246:18 148:19, 149:13,
286:16, 286:21 42:16, 52:19, Bill 161:5 36:14, 38:18, 37:6, 40:12, 276:9, 276:12, changed. 246:10 263:8, 276:14,
banks 17:15, 17:17 73:21, 74:2, bills 25:20 128:23, 153:11, 42:22, 46:18, 279:21, 288:9, changes 237:12 277:21, 278:19,
Baratz 24:17, 25:14 74:20, 78:11, bimbo 34:6, 34:13 153:15, 153:19, 47:23, 64:5, 299:12 changing 99:2, 99:4, 278:23, 279:6,
Barbara 1:19, 313:5, 80:18, 82:18, biography 301:4, 197:12, 216:15, 122:1, 122:11, cease 24:2 183:14, 192:21, 279:13, 292:21,
314:12 85:11, 86:4, 87:9, 301:8 229:5, 229:9, 122:13, 123:5, cell 166:17, 168:1, 246:14 302:13
Barnes 125:18, 87:19, 90:19, bit 11:2, 15:21, 229:18, 251:6, 123:6, 124:13, 168:13, 168:16 charge 45:15, 45:22, Chicken 145:15,
203:1, 203:6, 95:24, 96:3, 23:16, 71:1, 261:16, 270:16, 148:8, 153:12, Center 2:17, 302:13, 210:10, 215:20, 151:13, 152:1,
212:23 104:10, 107:10, 135:6, 181:22, 274:20, 275:19, 153:16, 153:19, 302:15 237:6, 248:9, 152:11
Barrington 38:21 109:3, 110:22, 232:6, 240:11 275:24, 280:21 155:6, 158:16, certain 15:4, 110:23, 248:10, 249:4 Chico 273:21
base 122:16 117:23, 124:17, Black 28:19, 151:19, book 289:22 158:22, 161:14, 113:18, 206:20, charged 117:17, child 70:8, 144:16,
based 41:14, 246:12, 129:11, 130:13, 276:14, 276:20, books 312:1 162:16, 163:11, 294:23 213:13, 233:10, 266:16, 266:19,
305:20 141:21, 153:10, 279:5, 279:11, boss 66:8, 66:9, 164:2, 199:23, certainly 147:6, 233:18, 248:10, 273:6, 273:9
322 324
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 83 of 93 PageID #:2071
2018
children 70:15, 71:5, citizen 116:10, 181:23, 201:4, companies 43:22 136:8, 204:15 191:6, 199:4, 233:21, 236:11, 21:14, 21:17,
71:19, 72:3 116:19, 116:21, 308:19, 309:9 Company 11:18, context 35:14, 217:21, 236:3, 238:1, 242:14, 21:22, 22:14,
Chris 6:19, 83:1, 116:22, 117:15, codes 182:18 11:19, 66:11, 40:11, 51:6, 51:14, 251:8, 255:4, 244:6, 244:18, 26:8, 26:9, 26:11,
97:23, 304:21 142:14, 143:21, coffee 38:23, 39:19, 66:17, 66:23, 54:5 260:23, 261:8, 246:3, 246:10, 26:16, 39:6, 41:1,
Christian 66:13, 144:2, 145:6, 39:22, 40:9, 42:24 67:23, 94:9, continue 99:10, 265:5, 266:1, 246:16, 249:3, 41:2, 41:3,
83:18, 84:13, 146:8, 307:10 coincided 247:18, 117:4, 126:6, 142:7, 283:17 270:12, 274:8, 251:19, 252:19, 145:23, 148:32,
85:17, 85:21, citizen. 116:1 247:22 161:3, 170:14, Continued 3:1, 4:7, 288:10, 289:14, 252:22, 277:17, 148:36, 251:3,
85:24, 86:6, 86:9, citizens 40:23 collaboration 178:7, 189:16, 216:2, 149:1, 150:5 291:5, 299:18, 285:10, 289:6, 253:21, 268:7,
86:14, 86:21, Citizenship 142:19, 178:13 225:12, 225:17, contracted 59:2 301:3 289:9, 292:23, 268:9, 284:16,
87:9, 87:17, 143:10, 143:12 colleagues 271:19 226:9, 256:1, contractors 45:10 copying 245:23 294:16, 294:24, 310:22, 311:6,
87:24, 89:13, city 272:15 collect 21:10, 256:4, 263:6 contributing 277:13 corner 140:10, 295:1, 296:9, 311:8, 313:3,
98:6, 102:6, Civil 1:17, 10:16, 106:20, 107:3, compare 71:12 control 296:11 299:3, 299:4 299:5, 300:3, 313:6
102:9, 102:22, 15:18, 31:9 107:12 compensation conversation 37:19, coroner 302:10 300:8, 301:14, couple 39:3, 69:18,
103:7, 104:10, civilian 37:15 collected 57:22, 221:23, 222:17 48:8, 78:9, 80:13, Corporation 228:10 304:7, 304:11, 69:20, 254:17,
104:23, 105:3, claim225:16 59:24, 60:7 complainant/victim/ 85:20, 86:11, Correct 13:19, 14:1, 304:13, 304:14, 269:9, 303:23,
105:7, 131:15, claimed 64:8, 82:9, College 16:9, 19:16, company 109:16 91:11, 91:18, 51:16, 51:17, 306:1, 306:6, 306:24, 310:18
131:20, 133:13, 183:15, 223:5, 19:22, 20:4, complaint 32:7, 118:18, 119:4, 56:6, 60:10, 68:1, 306:10, 307:5, course 16:4, 17:6,
140:18, 164:22, 223:7, 231:5, 144:5, 202:13, 50:22, 50:23, 160:18, 233:14, 80:15, 80:16, 308:14, 308:23, 17:7
165:23, 166:2, 292:1 202:15, 202:16 50:24, 79:2, 79:7, 274:21, 274:24, 80:20, 80:21, 309:19, 310:7, courses 16:18, 20:3,
166:7, 173:22, Clarify 77:12, 305:6, Colorado 134:8, 79:12, 120:7, 275:4 81:11, 81:12, 313:23 20:10
174:19, 174:23, 306:24, 310:10, 139:5 120:8, 120:10 conversations 82:13, 92:14, correctly 295:9 Court 1:1, 7:8, 11:24,
178:7, 179:14, 310:11 combination 254:16 Complaints 120:4 96:19, 105:6, 97:6, 97:9, 99:24, correspond 14:9, 12:2, 12:3, 12:6,
182:20, 184:3, clarity 250:12 comes 55:9, 102:16, complete 94:3, 133:17, 133:24, 104:19, 108:9, 42:17, 237:20 12:13, 15:2, 17:9,
184:5, 184:10, cleaned 27:21 306:9 94:15, 237:5, 310:21 108:17, 108:24, corresponded 29:5 79:1, 79:6, 79:14,
185:19, 186:3, clear 13:17 coming 9:8, 32:18, 240:16, 241:15, convicted 251:16, 109:20, 112:10, Correspondence 79:17, 148:1,
187:11, 188:13, cleared 273:19 84:8, 145:23, 246:24 284:24 112:18, 113:19, 9:18, 14:9, 80:12, 229:15, 255:12,
188:19, 189:7, clearinghouse 213:2 146:3, 178:23, completed 16:4, CONWAY310:16 113:20, 114:17, 84:3, 154:19, 255:19, 257:3,
189:13, 192:5, clerk 21:18, 47:10, 179:7, 187:6, 17:6, 40:15, 41:8 Cook 2:14, 2:23, 121:8, 121:13, 155:19, 157:21, 257:12, 257:13,
193:17, 197:24, 47:15, 47:22 187:7, 216:2, completely 37:1, 6:21, 12:3, 39:6, 124:16, 135:9, 165:15, 174:20, 258:19, 260:5,
198:9, 198:17, client 12:23 261:17, 269:5 69:19, 69:21, 41:1, 41:3, 135:16, 136:10, 236:4, 246:12, 260:7, 267:18,
201:12 close 23:24, 32:24, comings 55:4 115:17, 147:7, 148:32, 148:36, 136:11, 137:8, 246:18 275:15, 282:23,
Christina 301:23 67:20, 126:2, commencing 1:24 274:16, 275:3, 251:3, 253:21, 137:12, 138:5, corresponding 84:8 313:10
Christopher 2:26, 127:2, 127:4, committed 219:18, 297:5 268:7, 268:9, 151:17, 152:3, corrupted 166:18, courthouse 143:2,
66:1, 148:39, 127:18, 129:4, 251:13 compromised 284:16, 310:22, 156:19, 157:12, 169:10, 170:9, 275:16, 275:18,
173:13 129:9, 129:12, committee 36:22, 237:9, 240:19, 311:6, 311:8 165:16, 170:24, 170:10, 170:19 276:1, 276:2
Chuck 11:9, 12:10, 287:10 36:23 247:2, 247:18, cooking 34:6 174:15, 174:16, Corruption 226:21, courtroom283:12
13:15, 14:20, closed 24:1, 287:11 communicated 277:17, 278:14 copied 89:21, 134:1, 177:24, 179:18, 227:10, 227:13, Courts 1:18
15:17, 24:11, closely 129:18 30:20, 31:14, compromised. 174:15 182:6, 182:7, 228:6 cover 107:17,
24:23, 25:14, closing 24:21 33:12, 209:13 277:14 copies 119:14, 182:9, 182:10, cost 223:17, 223:20 134:24, 135:3,
162:9, 228:11, clue 30:3, 41:12, communication Computer 27:20, 161:9, 161:12, 184:22, 188:24, Counsel 9:3, 9:7, 137:5, 137:14,
257:8, 292:22, 59:9, 59:16, 68:8, 36:4, 43:15, 37:4, 37:8, 42:4, 204:15 195:19, 196:1, 12:18, 101:24, 138:4, 138:7,
293:1, 293:6, 100:12, 116:10, 80:14, 123:17, 42:10, 43:22, copy 64:23, 83:14, 199:13, 209:15, 313:26, 314:1 144:19, 154:14
293:9, 293:11, 117:11, 188:7, 123:19, 138:19, 46:17, 51:1, 90:15, 97:14, 210:22, 213:6, Count 51:10, 290:22 covered 144:17
293:17, 294:12, 188:9, 188:12, 158:12 51:15, 57:13, 115:7, 125:20, 213:11, 213:14, country 16:17, Cpanel 192:14,
294:13, 294:22, 248:9 Communications 63:10, 63:22, 130:10, 137:24, 216:5, 218:3, 256:20 236:24, 240:9,
295:14, 295:19, CNA16:8, 19:6 39:5, 90:3, 64:3, 66:3, 66:22, 154:17, 159:19, 221:3, 227:10, County 1:21, 2:14, 242:20, 247:10
295:22, 296:2 CNN16:7 215:18, 291:20 68:1, 68:5, 68:17, 165:11, 178:1, 227:13, 227:16, 2:23, 6:21, 12:3, CPR 22:4
Circuit 12:2, 12:3 code 180:5, 180:18, community 146:6 70:1, 74:3, 74:18, 179:7, 179:23, 227:17, 228:12, 15:10, 21:12, crap 271:17
325 327

89:5, 90:23, 66:20, 68:12, conglomerate 39:23 121:18, 121:20, crash 99:1, 105:16, 92:10, 103:16, 195:13, 195:19, 302:1, 302:6,
95:14, 102:16, 69:3, 69:17, 98:1, connected 104:13, 121:22, 122:20, 302:2, 303:3, 103:24, 106:2, 195:20, 196:10, 303:3, 303:8
103:5, 105:10, 98:20, 101:14, 105:12, 112:11, 123:3, 123:14, 303:9 113:14, 114:19, 197:5, 197:10, daughters 228:7
105:12, 105:16, 106:17, 112:12, 112:12, 133:6, 124:3, 127:8, crashed 65:22, 66:3, 118:15, 120:13, 220:16, 223:16, Dave 166:5, 235:24,
107:2, 107:11, 119:1, 169:22, 151:6, 151:8, 127:22, 139:4, 98:2, 98:15 228:14 224:2, 252:2, 236:4, 237:22,
107:17, 111:22, 203:17, 204:4, 160:13, 181:16, 139:18, 142:7, created 161:7, cross 40:24, 41:3, 252:17, 253:15 241:18, 245:23
114:5, 118:14, 204:10, 204:16, 181:20, 183:12, 153:23, 154:3, 190:7, 215:24, 145:19 Dane 254:8 David 173:22,
119:18, 121:23, 216:17 192:20, 205:8, 157:1, 157:2, 253:4, 256:2 csass@salf.org dark 280:23 235:24
122:12, 123:9, concept 40:22, 41:7 259:8, 290:10, 157:5, 188:14, creating 97:24, 180:24 Dasgupta 280:22 Davis 43:21, 44:2,
124:15, 128:5, concepts 39:10 309:23 257:6, 263:5, 169:1 cspizzirri@salf.dot. data 68:11, 69:7, 44:15, 45:4, 55:3,
151:1, 156:18, concern 146:10, connection 152:9 266:11, 275:6 credentials 37:15, org 165:12 69:13, 69:15, 55:6, 56:23,
158:22, 168:10, 151:15, 152:10 consent 45:18 Contacted 29:5, 144:9, 200:13, CSR 1:19, 314:12, 69:16, 70:6, 72:1, 58:17, 66:19,
168:20, 169:1, concerned 41:12, consider 124:24, 31:20, 44:2, 294:23, 295:7, 314:13 72:7, 84:4, 84:9, 67:4, 67:15,
169:7, 171:14, 123:21, 146:9, 208:14 48:21, 52:5, 295:20, 296:6 Cunningham274:10 84:10, 92:12, 68:21, 81:24,
173:1, 173:3, 146:14, 152:18 considered 126:9, 84:11, 87:3, Credit 46:4, 46:17, currently 20:16, 93:19, 98:12, 105:23, 106:6,
173:4, 196:17, concerns 142:16, 126:17, 208:18 105:23, 113:11, 194:11, 194:20, 25:21 98:15, 219:21, 120:14, 125:17,
200:22, 200:24, 145:8, 145:9, constant 257:14 116:12, 121:3, 209:14, 209:18, curriculums 70:12 225:15, 309:11, 153:23, 203:1,
201:3, 201:24, 154:24, 155:2, constantly 257:11, 121:6, 121:7, 210:19, 210:20, cutoff 72:17 310:6 203:7, 254:8,
204:23, 205:4, 155:10 292:2 121:12, 121:13, 211:19, 211:20, CV 313:14 date 14:12, 18:18, 257:9, 259:21,
205:5, 205:7, CONCLUDED 29:7, constituents 36:20, 123:20, 124:14, 212:3, 213:9, cwunder@kpglaw.c 18:19, 42:3, 260:1
205:16, 205:18, 29:8, 29:10, 37:23, 38:5 127:24, 134:7, 213:13, 213:18, om2:32, 148:41 57:16, 57:21, Day 8:16, 58:11,
206:3, 206:13, 302:8, 312:13 consulate 116:18 151:16, 156:16, 214:10, 214:16, Cyber 36:6, 36:11, 58:2, 76:15, 77:7, 58:16, 60:12,
206:17, 209:3, conclusion 220:8, consult 139:1 166:4, 188:19, 218:12, 219:19, 36:12, 37:11, 85:10, 125:21, 60:16, 60:20,
209:8, 211:24, 287:21, 302:17 Consultant 103:16 201:3, 209:12, 232:19, 253:8 37:21, 38:14, 159:1, 190:16, 84:20, 118:5,
212:3, 216:9, conclusive 10:10 Consultants 52:14, 209:21, 210:2, crime 36:6, 36:11, 38:19, 40:15, 202:16, 235:10, 118:22, 147:18,
217:5, 218:8, condition 94:7, 198:1, 200:21, 210:3, 210:4, 36:12, 37:11, 40:17, 41:9, 44:8, 244:16, 246:1, 168:8, 170:2,
219:5, 219:12, 169:23 234:9, 234:16, 212:24, 237:1, 38:14, 40:15, 117:24, 121:23, 252:10, 265:10, 238:11, 257:15,
221:2, 222:21, conditions 169:20 235:1, 235:4, 240:13, 244:14, 40:17, 41:9, 190:22, 191:3, 283:23, 284:7, 267:19, 297:15,
222:22, 225:15, conduct 170:2 236:24, 241:2, 256:18, 256:21, 218:14, 219:18, 214:14, 232:5 297:16 301:24, 314:6
232:19, 234:17, confer 101:24 277:10 258:5, 259:19, 255:13 Cyberstalking Dated 92:7, 108:7, Days 60:24, 61:21,
237:6, 240:17, conference 72:13, Consulting 97:5, 266:8, 277:24, crimes 38:19 256:10, 257:17, 125:18, 134:4, 62:4, 68:14, 81:8,
240:23, 241:7, 129:17 97:9, 97:12, 279:1, 279:8 criminal 35:11, 37:3, 257:22, 257:23, 135:4, 152:23, 81:15, 89:10,
241:15, 246:24, confession. 171:9 97:16, 97:21, contacting 36:20, 40:12, 42:1, 260:10 154:14, 155:13, 121:3, 121:5,
247:13, 247:21, confidentiality 97:23, 98:5, 98:7, 212:20, 243:4, 42:21, 164:2, 165:13, 171:8, 121:11, 121:17,
248:13, 251:13, 12:16, 12:19, 98:10, 98:11, 259:6, 259:7, 280:8, 280:12, 179:14, 184:21, 121:19, 124:10,
251:16, 252:8, 13:1, 13:21 98:14, 98:19, 278:23, 279:5 281:13, 284:9, < D> 190:15, 211:16, 289:5, 308:1
254:7, 254:9, confirm13:22, 100:2, 103:24, contacts 34:24, 285:9, 285:18, D. 222:11 234:8, 235:24, deaf 294:8
263:2, 263:18, 188:24 105:18, 113:14, 185:23 285:22, 297:6 D1 207:14 241:4, 245:8, deal 95:4, 95:5,
281:18, 282:5, confirmed 201:3 114:19, 118:15, containing 154:19 Critical 75:3, 75:6, D123 207:13 290:4, 291:6 129:17, 162:15,
284:20, 286:9, confiscate 147:8 120:12, 133:2, contains 172:14 75:11, 75:15, D124 207:13 dates 94:4, 143:17, 271:16, 286:4
286:13, 310:24, confiscated 147:9 235:24, 241:18, content 110:2, 75:18, 76:13, dah 192:10, 192:11, 203:4, 211:6, dealing 37:19
311:22, 311:23 confronted 202:6 245:24 172:15, 174:13, 76:22, 77:14, 264:12, 264:13 249:16 dealt 36:12, 55:3,
computer-related confused 177:2, contact 45:3, 47:4, 179:24, 181:8, 78:6, 78:10, Daley 2:17 daughter 21:6, 117:7, 296:13
127:10 177:19, 289:21 47:6, 48:2, 49:2, 182:14, 182:16, 80:13, 81:24, damage 131:3, 30:23, 32:3, Dean 202:6
computers 43:23, confusing 162:17, 50:12, 61:19, 186:11, 190:11, 88:6, 88:8, 88:10, 222:20, 222:23, 227:22, 228:2, Dear 33:22, 125:24,
58:12, 59:5, 257:12 66:24, 67:3, 237:12, 238:23, 90:3, 90:11, 223:6, 223:7 231:4, 231:19, 130:14, 165:5
64:13, 65:7, confusion 151:2, 85:22, 106:5, 273:16 90:22, 91:3, Damages 194:6, 270:21, 272:24, death 21:6, 227:23,
65:14, 65:17, 151:22 114:14, 116:17, contents 135:9, 91:10, 91:24, 194:8, 194:9, 295:4, 301:22, 231:7, 295:4,
326 328
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 84 of 93 PageID #:2072
2018
301:23, 302:6, 264:17, 264:19, 301:19, 301:21, 46:20, 47:1, 47:3, 296:15, 300:6 drawed 310:1 209:12, 216:4, 61:19, 63:1,
302:21, 303:7, 298:10 312:13, 313:19, 47:6, 47:14, doing 34:14, 36:2, dried 25:8, 25:10 232:7, 240:11, 119:21, 119:23,
303:10 departure 59:18, 313:25 47:24, 48:5, 48:8, 37:14, 66:5, drinks 43:2 241:3, 248:20, 264:6
debit 34:7 61:1 deposition. 223:2 48:21, 78:16, 73:10, 123:22, drive 105:13, 105:15 251:22, 253:11, elected 152:13,
debits 213:2 depended 302:11, depositions 1:18 78:18, 80:15, 123:24, 177:13, drives 205:9 267:3, 277:15, 286:11, 302:10
Debjani 280:22 303:5, 303:15 Depot 253:8 82:1, 85:23, 86:4, 202:20, 204:6, driving 32:22 289:5, 305:5, election 152:17
December 52:19 dependent 304:17 describe 12:9, 53:7, 86:5, 87:3, 89:13, 204:13, 238:19, dropped 220:2, 307:1, 307:14, electronic 203:23,
decision 55:1, depending 305:9 53:24, 64:7, 269:8 103:15, 103:18, 257:11, 260:6 284:13 309:10 208:15, 298:15
55:16, 55:20 deposed 7:3 describes 93:1, 103:20, 103:23, Domainkey 181:5 drugs 8:22 early 19:2, 19:14, email 29:12, 41:21,
Defendant 2:33, DEPOSITION 1:15, 108:20 116:17, 117:1, Don 90:12, 90:16, drying 24:9 19:19, 20:7, 42:18, 48:23,
3:12, 3:21, 7:5, 7:7, 9:8, 9:11, describing 74:4 118:1, 118:4, 91:11, 91:18, DSL 131:18, 132:11, 33:23, 65:10, 50:18, 56:7, 56:9,
148:42, 149:9, 9:17, 9:24, 10:6, description 108:14 118:7, 118:12, 94:12, 94:14, 132:17, 234:10, 73:10, 119:17, 58:14, 61:6, 61:7,
149:15 32:19, 33:3, 90:5, descriptions 227:15 118:20, 119:6, 95:7, 95:20, 236:9, 236:21, 119:21, 124:3, 61:8, 61:11, 61:15,
Defendants 1:13, 90:8, 94:22, deserve 228:3 119:12, 119:22, 96:13, 125:17, 237:1, 238:1, 152:2, 152:12, 61:17, 61:20,
2:23, 6:22, 35:1, 96:21, 97:2, Designer 131:15 120:15, 120:16, 125:24, 161:15 238:16, 239:3, 201:13, 201:16 75:16, 76:1, 76:3,
49:24, 148:13, 99:16, 107:23, desire 170:13 120:20, 122:3, done 68:4, 96:3, 239:15, 240:9, earned 297:23, 76:4, 76:12,
148:36, 313:14 108:2, 125:7, desk 45:13, 45:14, 122:9, 122:19, 96:16, 137:15, 247:9 298:5 76:15, 76:16,
defended 53:9 125:13, 130:4, 45:20, 57:7, 127:15, 128:3, 188:10, 196:14, DU313:3 Eastern 1:3, 148:3, 76:18, 76:19,
deferring 306:8, 130:7, 134:17, 84:12, 114:7, 128:8, 128:16, 199:17, 201:20, due 26:20, 99:2, 313:11 76:21, 77:6, 77:8,
306:14 134:20, 148:21, 137:14, 138:17, 129:2, 145:18, 228:11, 244:3, 111:6, 115:24, Eavesdropping 77:10, 77:15,
Definitely 91:15, 154:6, 154:9, 194:13, 194:24, 150:9, 154:15, 257:5, 268:18, 221:2, 221:4, 284:21, 285:10, 77:16, 77:19,
119:10, 227:1 157:15, 159:9, 205:10, 210:12, 154:18, 154:23, 286:23, 312:3, 312:6 285:13, 285:18, 77:22, 82:10,
degree 16:7, 17:21, 159:12, 164:14, 210:13, 232:18, 156:7, 156:12, 312:7 duly 6:1, 6:3, 150:3, 285:22, 286:5, 82:16, 82:19,
18:17, 19:3, 19:5, 164:18, 172:9, 232:24, 233:9, 160:19, 160:21, door 27:17, 27:19, 313:16 286:8, 286:12 82:22, 83:3, 83:6,
19:21, 19:23, 172:13, 173:18, 233:24, 237:5, 161:6, 166:7, 105:16, 258:17, Dupage 1:21, 41:1, Ebay 210:1, 212:14, 83:10, 83:14,
19:24, 68:23, 174:3, 184:15, 240:17, 240:23, 178:1, 178:15, 268:17 41:2, 313:6 212:17 83:19, 83:23,
92:5, 297:22, 184:18, 189:19, 241:7, 241:8, 178:21, 179:2, doubt 203:3, 261:5 duplicated 291:14 Education 15:21, 84:2, 84:6, 84:16,
298:5 189:22, 195:7, 241:15, 246:24, 189:2, 189:5, down 22:10, 27:19, duplicates 245:12 15:22, 16:1, 84:18, 84:19,
delayed 255:17 195:10, 198:22, 247:16, 247:17, 194:22, 195:1, 33:23, 37:17, During 9:19, 9:24, 18:14, 20:11, 84:22, 85:1, 85:5,
deleted 72:7, 111:23, 199:2, 200:5, 247:19, 248:13 200:2, 201:22, 41:6, 84:9, 94:24, 22:20, 23:10, 116:20, 144:5, 85:11, 85:12,
112:6 200:8, 211:8, desperate 270:18, 202:8, 202:10, 99:10, 113:9, 47:17, 51:3, 202:12, 264:14, 85:18, 85:21,
deletion 150:11 211:11, 217:16, 270:19 202:18, 202:24, 115:11, 135:10, 80:23, 86:11, 264:16, 264:18, 86:17, 87:1,
Dell 93:1, 93:6, 93:7, 222:6, 222:9, destroy 269:8 203:6, 203:14, 135:19, 136:19, 100:19, 104:11, 264:19, 308:4 87:11, 87:14,
93:9, 93:21 224:23, 225:2, destroyed 92:12, 204:21, 205:2, 141:4, 166:12, 157:14, 163:13, educational 295:7, 87:18, 87:24,
demonstrated 235:15, 235:19, 292:17 205:15, 207:3, 181:9, 181:21, 164:3, 286:17 295:20 88:15, 88:17,
277:11 242:6, 242:9, destroying 292:10, 209:2, 210:7, 190:3, 194:5, Dynamic 234:11, effects 305:4 88:19, 88:22,
Department 28:22, 254:22, 255:2, 292:14 210:11, 214:12, 196:7, 198:12, 234:12, 236:10, effort 93:24 89:11, 89:14,
36:19, 39:5, 260:17, 260:21, Det 125:24, 199:23 214:19, 215:12, 229:19, 229:21, 238:15 efforts 68:10, 73:4, 89:21, 90:1,
108:9, 108:16, 260:22, 264:22, detail 22:9, 23:16 216:16, 217:1, 247:7, 247:11, 90:24, 92:1, 95:8, 102:15, 102:18,
110:11, 120:21, 265:3, 270:7, details 13:6, 243:2 218:3, 218:12, 252:8, 270:15, 95:9, 95:13, 102:21, 102:24,
121:6, 123:22, 274:3, 274:6, detained 268:7, 231:8, 231:12, 271:21, 271:24, <E> 95:18, 95:22, 103:8, 103:9,
124:5, 145:21, 276:5, 276:8, 268:9 233:2, 233:4, 272:3, 272:5, ear 294:8 96:15, 98:12, 104:2, 104:13,
146:2, 151:21, 279:17, 279:20, detect 183:5 233:14, 247:18, 291:2, 312:4 earlier 35:3, 42:6, 100:17, 150:10, 104:14, 105:11,
165:20, 172:22, 288:5, 288:9, Detective 6:19, 248:12, 281:14, downed 166:14 63:16, 80:22, 206:22 106:21, 111:12,
187:9, 187:14, 290:17, 290:20, 33:15, 43:17, 281:15 dozen 258:22 81:8, 105:22, eight 18:2 112:1, 112:3,
201:21, 212:24, 296:21, 297:1, 43:19, 44:6, 45:5, determine 27:23, draft 190:11 114:21, 142:18, Eighties 19:14, 112:23, 112:24,
220:11, 225:5, 299:8, 299:11, 45:8, 46:3, 46:9, 29:19, 263:21, drafted 190:15, 156:14, 161:6, 19:19, 20:7, 21:15 114:23, 115:7,
264:13, 264:16, 300:20, 301:1, 46:13, 46:15, 277:16 198:10 174:19, 179:18, either 41:21, 48:22, 125:16, 125:21,
329 331

determined 30:16 Diego 230:21, 22:8, 23:16, 32:9, 251:1, 313:11 126:20, 132:23, 206:10, 206:11, 179:24, 183:22, 177:16, 182:9,
determining 180:12 270:22 33:2, 33:7, 38:23, divorce 15:7, 15:15 132:24, 133:4, 207:6, 207:7, 193:3, 198:2, 200:14, 203:9,
Devine 121:8, different 9:19, 35:23, 39:3, 42:12, 46:4, divorces 11:6, 15:12 133:6, 133:8, 207:18, 208:6, 200:14, 200:15, 254:5, 254:13,
121:13, 121:21, 36:1, 96:11, 151:20, 174:22, Dixon 160:7 133:12, 133:13, 208:15, 208:20, 201:11, 202:6, 254:14, 256:17,
122:6, 122:17, 132:12, 145:24, 296:5 DLS 238:14 133:18, 133:20, 215:22, 215:23, 203:18, 203:21, 307:4
122:20, 123:4, 146:20, 146:21, discussed 36:13, DNA152:6, 152:7 134:2, 134:7, 226:15, 231:2, 203:23, 206:16, employer 56:9
123:21, 124:3, 147:7, 230:8, 150:8, 157:2, dnifro@amwolawil. 134:10, 134:12, 236:3, 236:7, 207:11, 207:12, employment 20:21,
124:14, 124:19, 259:8 161:20, 163:13, com3:20, 149:14 138:5, 138:6, 236:14, 236:19, 207:16, 208:8, 21:23, 22:12,
124:24, 126:1, difficult 72:16, 123:8 164:22, 166:6, doctor 11:14, 266:15 139:19, 139:21, 237:22, 239:21, 208:20, 215:21, 22:20, 23:4,
126:4, 126:11, difficulty 124:6, 172:15, 179:24, doctors 302:6 140:1, 140:16, 242:17, 242:20, 235:23, 237:13, 56:12, 57:4, 57:6,
127:4, 127:17, 155:4, 312:5 186:7, 199:10, Document 79:16, 141:10, 141:13, 242:23, 243:6, 237:19, 242:12, 150:15, 175:23,
128:20, 129:5, Dillon 38:24, 39:24, 241:3, 251:22, 90:7, 91:23, 97:1, 142:1, 142:9, 243:24, 244:16, 256:11, 261:11, 211:24, 223:17,
129:14, 129:21, 49:9, 49:11, 49:13 291:13 107:22, 109:14, 143:6, 159:19, 245:10, 245:16, 261:17, 262:7, 223:20
130:11, 130:14, Dina 3:14, 6:18, discussing 101:17, 125:12, 130:3, 165:12, 165:14, 245:18, 245:21, 262:10, 262:12 EMS 70:12, 70:13,
130:19, 135:4, 149:11 138:2, 138:23, 134:19, 136:13, 165:19, 166:5, 246:2, 246:12, emails. 256:13 302:8
135:14, 136:5, direct 136:5, 137:3, 152:22, 186:4 154:5, 159:8, 166:10, 166:11, 246:15, 255:4, embarrassing 63:14 enclosure 141:22
136:10, 137:8, 296:24 discussion 39:11, 164:13, 172:8, 167:9, 168:15, 256:8, 260:23, embarrassment enclosures 136:13,
137:18, 137:21, Directing 166:10 91:9, 92:9, 164:1, 184:14, 189:18, 171:7, 171:16, 261:10, 261:22, 231:3 137:17, 139:2,
138:1, 138:11, directions 269:17 175:11, 175:14 190:21, 191:7, 171:19, 172:16, 263:4, 265:2, emergency 23:21, 140:2
138:16, 143:9, directions. 269:16 discussions 96:19, 195:6, 195:12, 172:17, 174:13, 265:6, 265:22, 302:15 encompassed 24:20
144:1, 147:1, directly 189:12 279:11 198:21, 200:4, 174:15, 174:18, 266:2, 268:10, employ 144:21, encourage 147:1
151:16, 152:23, director 67:13 disengaged 263:19 211:7, 217:15, 174:19, 174:22, 270:12, 270:20, 175:20 end 58:16, 175:4,
153:4, 153:8, disagree 157:23 disgruntled 61:7, 222:5, 224:22, 175:1, 177:8, 274:9, 274:12, employed 20:16, 199:22, 219:15,
153:15, 153:22, disappeared 261:11 61:15, 142:5 232:6, 235:14, 177:16, 177:21, 274:13, 274:14, 54:20 221:17, 260:13,
154:16, 154:17, disappearing 261:18 dismiss 282:18 239:5, 242:8, 178:2, 178:17, 280:1, 288:11, employee 47:21, 269:14, 272:8,
154:20, 155:14, disappointed dismissal 56:12 250:3, 253:4, 178:23, 178:24, 288:14, 288:19, 52:9, 53:4, 53:6, 290:12
155:15, 156:2, 282:12, 282:17 Dismissed 282:9, 253:15, 253:20, 179:1, 179:4, 289:2, 289:3, 53:8, 55:10, ended 40:16, 264:5
156:6, 156:11, disconnected 282:13, 284:12 254:21, 260:16, 179:6, 179:7, 290:4, 291:5, 62:14, 62:19, enforce 122:15,
157:2, 157:22, 193:20, 233:5, dispatched 211:18 264:4, 264:5, 179:8, 179:14, 292:6, 305:5 62:22, 81:14, 219:1
158:21, 159:6, 248:17 disposed 13:7, 264:9, 264:11, 180:3, 180:4, emailed 43:7, 89:18, 82:24, 83:1, enforcement 73:5,
162:23, 163:2, discover 65:13, 284:13 264:21, 270:6, 180:6, 180:10, 133:1, 173:2, 113:10, 113:11, 119:19, 129:18,
163:7, 163:14, 138:14, 152:5 disposition 13:14 274:2, 276:4, 181:24, 182:8, 188:10, 231:18, 113:13, 114:14, 144:19, 146:23,
217:22, 219:7, discovered 45:11, dispute 158:15, 276:17, 279:16, 183:2, 183:5, 259:13, 263:9, 114:16, 190:22, 157:3, 157:6,
307:17, 311:10, 47:8, 65:20, 84:5, 158:20, 225:23, 288:4, 288:22, 183:7, 184:5, 267:19 225:14, 253:24 178:22, 203:12,
311:15, 311:17 166:8, 232:17, 279:24 290:16, 296:20, 184:20, 184:24, Emails 9:14, 9:16, employee. 99:3 203:15, 204:2,
Dicianni 160:23, 232:18, 234:10, disregard 24:6 298:3, 299:7, 185:2, 185:16, 28:7, 46:12, employee/suspect 204:9, 204:14,
161:21, 161:22, 236:24, 237:2, dissolve 25:3 300:19 185:24, 186:2, 72:22, 72:23, 110:18 204:22, 205:3,
162:16, 221:16, 239:19, 240:14, dissolved 25:18 document. 126:22, 186:6, 186:9, 72:24, 81:1, employees 46:6, 205:15, 206:10,
222:12 241:24, 242:2, distracted 265:20 127:7, 210:17 186:12, 186:15, 82:12, 83:21, 47:9, 47:15, 55:2, 207:1, 207:3,
Dick 121:21, 122:6, 242:19, 244:14, District 1:1, 1:2, documentation 186:16, 186:20, 83:23, 84:18, 62:24, 63:1, 207:6, 208:4,
122:17, 123:3, 308:11 1:17, 12:6, 21:11, 236:15 187:17, 188:2, 86:3, 86:16, 65:18, 73:5, 208:17, 209:5,
126:1, 126:4, discovering 47:14 21:12, 21:14, documents 9:10, 189:4, 189:7, 86:21, 86:24, 82:21, 85:6, 113:8, 209:9
126:11, 127:3, discovery 12:21, 21:17, 21:21, 9:13, 120:14, 189:9, 189:14, 103:9, 103:12, 113:15, 113:23, engage 98:1, 234:24
130:15, 136:5, 14:2, 93:19, 22:15, 148:1, 120:15, 120:19, 192:8, 192:13, 112:2, 112:22, 132:22, 133:3, engaged 28:7, 28:8,
152:23, 153:15, 180:11 148:2, 313:10 120:23, 121:1, 198:1, 198:3, 114:24, 115:1, 133:7, 133:17, 28:12, 52:15,
162:23, 307:16, discretions 53:10 disturbing 132:23, 127:19, 137:21, 198:10, 199:5, 134:12, 139:8, 134:13, 172:19, 65:7, 99:14,
311:10, 311:15 discuss 10:23, 133:4 162:10, 202:3, 199:15, 200:1, 139:11, 164:23, 173:10, 174:14, 100:22, 241:10
died 52:6, 303:3 18:14, 20:14, Division 1:3, 148:3, 229:15, 229:23, 200:17, 201:8, 172:21, 179:17, 177:9, 177:10, enough 123:22,
330 332
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 85 of 93 PageID #:2073
2018
262:14, 262:17 269:22, 272:1, Excuse 36:14, 164:14, 164:18, 249:2, 249:9, 118:2, 143:14, 192:23, 218:24, 221:19, 222:3,
enroll 16:23, 17:19 272:7, 272:11, 57:13, 78:4, 164:19, 165:3, 249:13, 268:14, 158:7, 172:1, 219:15, 221:5, 222:16, 223:11,
entered 112:1, 272:22, 273:6, 89:16, 93:16, 165:19, 166:6, 289:13 188:4 222:19, 226:13, 259:15, 263:8,
114:22, 249:14 285:5, 287:11, 157:4, 174:7, 166:10, 166:11, Files 27:21, 69:7, finished 94:10 242:17, 248:7, 272:23, 290:12
entire 180:4 287:17, 289:22, 195:15, 276:12 166:22, 167:4, 69:8, 69:15, 70:4, fire 54:13, 54:16, 257:4, 281:23, following 60:24,
entirety 175:23 302:17 Executive 50:3, 168:16, 169:9, 81:1, 92:12, 55:1, 55:17, 62:16 286:10, 288:17, 62:4, 81:9, 81:15,
entitled 253:15 Everywhere 266:20, 155:19 171:2, 172:9, 111:23, 112:6, fired 52:23, 54:3, 288:24, 289:11, 93:19, 109:17,
entries 190:15 272:22, 285:24 Exhibit 90:5, 90:8, 172:12, 172:13, 162:6, 162:7, 54:18, 54:19, 293:11, 293:23, 131:2, 180:4,
entry 131:17, 134:9, evidence 95:10, 90:11, 92:14, 172:14, 172:15, 206:20, 211:24, 56:21, 56:24, 296:6, 297:18, 258:3, 272:18,
190:8, 195:23, 95:14, 95:22, 92:24, 93:15, 172:21, 173:18, 243:17, 264:3 61:2, 61:21, 298:22, 302:9, 301:23
197:19, 214:8, 96:15, 113:12, 94:7, 96:22, 97:2, 174:3, 174:12, files. 115:14 62:14, 63:1, 302:18, 307:8, follows 6:4, 150:4
232:7, 234:8, 114:15, 119:8, 97:8, 98:23, 174:17, 174:24, fill 70:8, 298:11 110:17, 110:20 311:20, 311:22, foot 67:8
237:21, 240:8, 119:18, 120:16, 99:11, 99:22, 178:18, 179:4, filled 72:4, 295:4, firefighters 22:4, 313:16 footprint 78:20,
241:3, 242:2, 187:20, 188:6, 101:16, 102:2, 179:10, 180:1, 298:6, 298:9 70:12 five-minute 73:16, 78:22, 78:24,
244:9, 244:13, 199:13, 199:23, 102:20, 104:15, 181:22, 182:14, finalized 14:24, 15:1, firing 55:7, 62:23 73:17, 191:11 134:9, 140:17,
246:23, 249:8, 208:15, 209:4, 107:23, 108:3, 184:15, 184:19, 15:3, 102:20 firm160:8, 200:22 fix 66:10, 66:22, 199:13
251:11 209:8 108:4, 108:7, 184:20, 185:21, finally 272:3 First 6:3, 7:5, 7:8, 166:17, 168:1, footprinted 139:13,
equipment 92:12 ex 268:3, 269:8, 108:11, 108:14, 185:22, 186:2, finances 112:11, 12:1, 16:16, 22:4, 168:9, 168:17, 139:14
Ernesto 302:14 271:2 108:19, 109:3, 186:4, 186:5, 287:8 31:3, 36:17, 37:2, 168:19, 168:23, footprinting 140:21
escalated 291:17 ex-employee 211:23 109:13, 109:19, 186:13, 187:8, financial 81:2, 81:6, 37:6, 42:11, 44:8, 169:7, 169:22, footprints 85:18,
Especially 146:21 ex-husband 30:9, 110:5, 110:14, 187:13, 189:8, 111:24, 112:9, 45:3, 52:3, 52:16, 170:18, 188:9 198:2, 263:20
essentially 297:12 227:2, 227:6, 111:20, 113:17, 189:19, 189:23, 112:16, 113:5, 62:13, 62:18, fixed 66:7 force 36:11
establish 102:7, 250:11, 267:12, 115:12, 115:22, 189:24, 190:2, 170:6, 289:24, 72:23, 74:8, flags 146:24 foregoing 313:22
171:14 267:15, 267:21, 120:2, 125:8, 190:12, 190:21, 292:8, 292:10, 74:19, 78:1, flight 45:15, 115:24, foreign 307:22
established 276:24, 268:14, 278:11, 125:13, 125:16, 191:20, 192:4, 292:17 105:23, 108:11, 116:3, 147:2, forensic 43:21, 51:4,
277:3 282:22 126:12, 126:20, 192:6, 193:8, find 12:20, 28:17, 110:6, 110:9, 147:8, 307:11 64:19, 66:11,
establishing 104:16 exact 291:2 129:4, 130:4, 193:10, 193:24, 43:22, 45:19, 110:15, 116:18, flip 134:23, 135:10, 66:17, 66:24,
et 1:11, 148:11, exactly 91:3, 305:6 130:8, 130:10, 194:2, 194:5, 45:21, 52:8, 59:4, 116:22, 116:24, 136:12 67:23, 74:16,
256:18, 302:7, EXAMINATION4:4, 130:24, 131:10, 195:7, 195:11, 91:6, 122:3, 117:18, 118:10, flipped 159:16 74:24, 88:4, 92:1,
313:12 4:7, 4:10, 4:13, 131:13, 132:16, 195:12, 195:19, 122:7, 122:10, 118:11, 118:13, folder 201:24, 207:8, 127:13, 128:13,
etc. 94:4 4:16, 6:5, 94:2, 132:21, 134:7, 195:23, 196:6, 138:18, 152:8, 119:10, 119:22, 208:19 216:17, 234:17,
eventually 253:1, 150:5, 218:11, 134:17, 134:20, 196:22, 197:3, 155:5, 161:2, 121:3, 121:6, Follow12:20, 12:21, 247:13
284:11 218:15, 304:1, 134:24, 135:18, 197:19, 197:22, 162:24, 166:4, 121:12, 121:18, 14:6, 119:9, forensics 91:6
Everybody 126:7, 305:1, 310:19 136:13, 137:24, 198:6, 198:7, 183:22, 188:14, 122:13, 123:14, 139:20, 146:21, forever 60:22, 67:18
126:10, 126:17, examine 203:17, 138:2, 138:22, 198:8, 198:10, 192:7, 193:4, 123:17, 123:19, 150:7, 164:21, forged 107:3, 107:4
130:20, 133:5, 204:3, 204:22, 139:2, 139:4, 198:11, 198:18, 200:23, 246:1, 123:20, 124:15, 218:7, 219:8, forget 207:13,
146:14, 173:14, 205:16 139:12, 139:22, 198:22, 199:3, 259:15, 261:20, 124:21, 124:22, 221:8, 233:13, 274:11, 275:3
178:9, 226:17, examined 6:4, 150:3 140:1, 140:22, 199:4, 199:10, 269:5, 271:11, 124:23, 129:14, 240:4, 260:14, forgot 158:3, 274:15,
229:5, 230:5, examiner 51:4 141:4, 141:15, 200:5, 200:9, 271:13, 294:9, 130:18, 130:20, 262:7, 263:4, 284:1
257:7, 273:23 Examining 126:22, 142:13, 144:1, 211:8, 211:12, 303:19 130:23, 136:18, 263:11, 263:13, form60:2, 60:17,
everyone 6:13 127:7, 210:17 144:18, 145:2, 211:13, 211:16, finding 312:5 142:23, 145:21, 263:19, 267:7, 72:10, 83:12,
Everything 22:1, examples 39:8 153:2, 153:3, 211:22, 212:14, fine 10:4, 191:13, 145:23, 153:15, 268:20, 268:21, 93:3, 101:5,
64:23, 67:8, Except 153:11, 154:6, 154:10, 214:6, 217:16, 220:13, 287:11, 155:12, 156:3, 268:23, 288:18, 104:7, 104:20,
67:14, 143:18, 216:23, 269:24, 154:11, 155:13, 217:19, 217:21, 293:5 162:19, 165:6, 288:19, 290:13 115:4, 121:22,
204:17, 206:14, 311:10 156:3, 159:9, 218:1, 218:6, finish 7:11, 7:12, 166:12, 172:24, followed 26:21, 178:4, 188:5,
206:16, 206:18, exchange 46:12, 159:13, 159:18, 222:6, 222:10, 8:12, 18:3, 40:4, 174:12, 174:23, 26:22, 28:16, 203:19, 238:2,
207:10, 207:11, 159:19, 207:19 159:23, 160:16, 222:11, 222:14, 48:12, 48:15, 183:17, 186:5, 155:9, 155:22, 285:2, 303:14,
229:8, 230:13, exclamation 267:8 161:5, 162:20, 224:23, 225:3, 51:9, 84:9, 92:22, 186:12, 187:6, 202:8, 213:5, 304:17
333 335

225:4, 225:8, 174:11 <F> 154:18, 258:12 Formally 25:5, 49:4, Foundation 9:22, 80:6, 110:16, 247:16, 247:17,
226:4, 232:5, exist 13:2, 24:3 Fabricated 226:23 fax'd 197:16, 259:13, 50:2 10:1, 11:19, 21:2, 299:14 247:19, 248:13,
235:15, 235:19, existed 216:3 face 109:7 259:14 formed 21:1 21:4, 21:7, 21:24, four 10:21, 72:12, 261:15, 306:21
235:20, 236:7, existing 223:9 Facebook 34:4, faxes 258:12 former 47:8, 47:15, 22:9, 22:18, 23:3, 129:24, 170:2, ftpsalf 243:1
236:22, 237:15, exit 55:11, 55:14, 34:8, 34:15, 34:18 FCC 39:4 47:21, 166:18, 23:12, 23:17, 237:9, 237:10, full 20:20, 21:19,
237:17, 237:21, 57:2, 57:3, 57:14 fact 47:18, 108:12, Federal 12:1, 12:2, 169:10, 169:11, 23:18, 23:22, 240:20, 290:9, 21:22, 23:8, 53:4,
237:23, 240:3, expect 282:20 113:4, 115:24, 12:6, 22:6, 39:5, 170:8, 225:13 23:23, 23:24, 292:7 55:10, 170:14,
240:11, 242:1, expecting 257:15, 146:7, 146:9, 67:9, 144:13, forms 298:8 24:2, 25:18, four-hour 104:12 170:15, 204:18,
242:6, 242:9, 257:16 164:7, 210:7, 259:9, 297:9, forth 32:22, 84:8 32:16, 44:10, four. 10:7, 11:15 219:15
242:12, 242:17, experienced 151:7, 217:6, 267:18, 298:4 forward 95:17, 52:22, 53:24, Foxx 2:13, 148:31 full-time 23:3, 53:6,
243:14, 243:22, 194:19, 262:19 272:16, 287:14, feel 8:16, 72:17, 133:2, 134:11, 54:13, 54:16, frame 30:24 58:20, 62:22, 63:1
244:8, 244:13, expert 216:17, 304:17, 307:9, 177:7, 177:12, 165:14 58:9, 59:19, 60:1, Fran 39:9 Fuller 63:9, 64:20
244:16, 246:22, 247:13 312:6 177:15, 227:18, forwarded 82:12, 60:13, 61:1, 61:2, Frank 63:9, 64:20 functional 72:16
248:3, 250:3, experts 188:8 factor 277:13 255:16, 256:3 82:19, 83:6, 63:18, 63:24, fraud 211:19, 211:20, funding 22:6, 24:8,
250:22, 251:3, Expires 314:14 failed 131:18 fees 252:18, 252:21 83:10, 83:15, 64:3, 64:6, 64:9, 222:22, 253:9 25:7, 25:10, 25:20
251:11, 251:21, explain 31:6, 31:21, fair 7:12, 8:1, 8:13, felt 84:5, 103:8, 83:17, 83:20, 67:7, 67:16, fraudulent 107:3, fundraiser 272:17
251:24, 252:15, 31:22, 53:20, 305:9 131:2, 175:18, 83:24, 84:16, 68:12, 80:2, 80:6, 107:8, 294:10 funds 219:22
254:22, 255:3, 69:1, 101:15, Fairly 273:2 229:22, 257:18, 84:18, 84:22, 97:22, 98:12, free 8:16, 277:4, funeral 130:2
255:4, 256:9, 182:20, 256:14 faith 93:24 286:8 85:1, 85:6, 86:16, 98:20, 106:12, 287:1 future 175:8
260:12, 260:17, explained 58:22, fall 120:8 FEMA67:10 115:2, 133:14, 108:17, 110:17, freeze 281:22 FYI 162:22
260:21, 260:22, 101:12, 237:7, false 112:13, 152:19, few14:14, 34:23, 174:13, 178:2, 117:21, 120:20, French 3:12, 6:24,
261:23, 264:22, 240:18, 247:1 258:19, 266:13, 62:5, 64:21, 178:18, 183:23, 121:5, 121:11, 50:15, 50:17,
265:3, 265:5, explanation 238:24, 266:14, 267:21, 121:17, 150:7, 186:1, 193:5, 127:9, 135:11, 51:5, 51:13, <G>
266:22, 269:14, 239:7, 239:24 273:18, 285:4 174:24, 194:15, 208:21 135:14, 135:19, 149:9, 216:5, garage. 267:2
270:7, 270:10, expose 85:7, 175:5, familiar 49:22, 213:16, 245:12, forwarding 106:22, 150:11, 150:16, 216:9, 216:17 Garcia 49:4
270:11, 271:18, 177:3 213:21 296:4, 302:5, 142:9, 155:18, 150:18, 156:18, Friday 1:23, 99:14, Garrels 291:9,
274:3, 274:7, Express 45:17, family 126:6, 126:7, 304:22, 309:1 183:2 158:23, 165:19, 111:20, 114:3, 291:19
274:8, 276:5, 194:14, 194:20, 126:10, 126:14, field 185:13 found 43:23, 44:22, 172:23, 187:13, 114:22 Gary 274:9, 274:20
276:9, 276:13, 196:1, 209:21, 126:17, 178:11 figure 28:22, 128:4, 61:9, 63:10, 189:3, 200:13, friend 30:10, 32:23, gathering 262:10,
279:17, 279:21, 210:6, 210:9, far 105:9, 132:9, 160:22, 162:14, 86:15, 86:23, 203:2, 203:17, 33:22, 125:1, 262:12
279:22, 288:5, 210:23, 211:2, 132:11, 132:14, 196:13, 196:19, 88:12, 91:21, 204:4, 204:10, 125:2, 126:2, gave 58:20, 71:13,
288:9, 288:24, 212:20, 218:2, 147:7, 156:20, 243:6, 254:19, 91:23, 103:6, 204:16, 216:9, 126:4, 126:12, 100:13, 187:19,
289:6, 289:12, 219:19, 219:23, 161:23, 172:19, 305:13 103:7, 104:1, 219:5, 219:12, 126:18, 127:18, 204:17, 205:24,
290:17, 290:21, 220:2, 220:4, 182:2, 201:11, file 72:11, 79:1, 79:7, 104:11, 105:10, 219:21, 223:7, 226:15 230:18, 267:20,
291:4, 291:24, 220:6, 220:9, 292:8 94:4, 94:16, 105:11, 119:14, 224:5, 224:10, friends 32:24, 33:24, 286:14, 294:7,
296:21, 297:1, 224:20, 233:18, farther 115:11 143:5, 146:16, 161:14, 166:3, 225:6, 225:12, 66:12, 267:17 305:3, 307:15,
297:9, 297:18, 233:19, 237:6, father 18:11, 18:12, 207:15, 211:1, 166:15, 167:12, 225:21, 228:15, front 45:12, 45:14, 308:18, 309:10,
299:3, 299:4, 237:8, 247:5, 269:6, 269:7 237:11, 243:19, 167:19, 171:15, 253:1, 289:16, 45:20, 58:17, 310:5
299:8, 299:12, 247:15, 248:8, favorable 227:16 249:11, 260:9, 191:18, 192:3, 290:1, 292:11, 84:12, 114:7, geek 181:2
299:17, 299:22, 286:18 Fax 134:24, 135:3, 260:13, 260:14, 200:24, 201:24, 292:15, 292:23, 115:8, 137:13, geeks 309:22
300:20, 301:2, extension 297:14 135:9, 135:13, 268:3, 268:16, 202:11, 210:12, 296:8, 299:24, 138:17, 194:13, General 3:3, 3:6, 3:7,
301:3, 301:13, extent 286:3 135:14, 136:5, 291:15, 298:18 212:21, 230:20, 300:1, 300:14, 194:24, 210:12, 7:6, 22:12, 57:13,
301:21, 303:11, external 99:13, 136:8, 136:9, filed 11:23, 31:4, 231:6, 233:2, 301:4, 301:21, 210:13, 232:18, 84:15, 90:6,
306:18, 306:19, 99:23, 100:3, 137:5, 137:6, 31:11, 31:16, 239:11, 239:24, 304:16 232:24, 233:9, 96:22, 102:3,
307:11, 307:16, 101:3 137:7, 137:17, 32:6, 32:7, 33:13, 247:19, 251:12, founded 21:8, 22:17, 233:24, 237:5, 126:21, 126:23,
308:16, 308:22, eye 267:7, 268:20 138:4, 138:7, 43:11, 46:21, 267:1, 270:16, 22:23, 300:1, 240:17, 240:23, 127:3, 127:9,
310:2 138:12, 138:18, 50:23, 50:24, 270:22, 274:21, 301:22 241:6, 241:8, 127:16, 127:22,
EXHIBITS 4:21, 5:1, 138:20, 154:11, 143:3, 240:21, 308:4, 308:9 Founder 80:1, 80:5, 241:15, 246:24, 127:23, 128:1,
334 336
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 86 of 93 PageID #:2074
2018
128:6, 128:9, 209:7, 238:24, 298:4 193:22, 232:2 299:9, 300:21 in-house 132:13 24:5, 25:12, 30:6, 106:15, 106:16,
128:11, 128:12, 271:8, 281:5, granted 260:6 hair 280:23 identified 210:21 in. 39:11, 44:20, 30:7, 33:11, 106:20, 107:12,
128:18, 129:3, 281:21, 284:5 grants 304:15 Half 27:17, 52:4, identify 92:11, 98:15, 91:2, 151:11, 40:10, 63:23, 107:16, 224:15,
130:8, 134:17, given 71:5, 119:16, gratitude 218:2 52:5, 52:11, 102:7, 219:17, 207:17, 243:19, 119:23, 120:13, 225:5, 225:17,
136:7, 137:6, 138:10, 162:6, great 73:15, 147:12 52:13, 52:14, 244:17, 246:21 253:19, 268:8 120:19, 134:1, 226:3
140:12, 140:13, 178:8, 180:19, green 117:6, 144:14 52:23, 54:3, identifying 113:17, inaccuracies 308:13 182:1, 214:20, insured 225:6,
141:16, 149:3, 217:6, 218:8, grievance 111:17 54:10, 54:18, 134:16 Inaccurate 294:24, 295:24 225:12, 225:14
149:6, 149:7, 234:1, 253:16, ground 7:6 54:20, 55:17, ignorant 101:13 299:5, 299:6, inform102:19 intelligent 262:14,
167:6, 174:4, 313:19 group 43:21, 113:1, 55:20, 56:4, IL 34:7 300:2, 300:15, information 12:22, 262:17, 263:1
174:18, 179:13, giving 109:10, 307:4 56:10, 56:15, ill 18:12 300:16, 301:14, 13:12, 14:3, 70:4, Intent 99:11
180:3, 181:8, 208:16, 309:17 guess 10:5, 44:23, 57:5, 58:14, illegal 162:8 301:15, 301:16, 70:20, 70:22, interact 42:20
181:22, 182:14, glanced 110:3 46:10, 67:19, 58:21, 58:23, Illinois 1:2, 1:21, 303:12, 307:8 71:23, 71:24, interacted 35:19
183:10, 185:20, Gmail 181:5, 185:7, 215:15, 221:14, 59:11, 63:19, 1:23, 2:7, 2:14, inaccurately 295:23 80:10, 80:18, interaction 110:9
203:16, 207:5, 185:9, 185:12, 263:20 111:8, 116:9, 2:20, 2:30, 3:4, inappropriate 63:22 80:23, 81:3, 81:6, interest 123:4
216:22, 226:16, 188:17, 188:21 guessing 142:3 116:12, 117:3, 3:9, 3:18, 12:4, inbox 206:12, 207:7, 93:6, 94:4, 94:16, interested 36:16,
250:2, 250:19, God 285:5 guidance 100:23, 117:11, 120:23, 12:7, 21:12, 208:7 100:3, 162:2, 121:24, 122:7,
250:20, 250:23, goings 55:4 203:11 144:22, 162:3, 21:14, 26:6, 26:8, Inc. 92:11 177:4, 181:23, 314:3
287:7, 287:16, Gordon 227:8 guidance. 291:18 162:5, 162:13, 26:13, 26:19, incident 37:8, 94:17, 183:17, 192:22, interesting 192:14
287:20, 288:16, gotten 210:8, 263:18 guilty 175:18 166:11, 172:16, 26:24, 33:23, 301:24, 303:12, 231:1, 234:15, interests 184:2
288:21, 289:4, Goudie 11:9, 12:10, Gunnigle 29:13, 175:5, 175:6, 36:11, 36:17, 308:10 236:17, 246:13, interface 183:13,
289:20, 292:5, 13:15, 14:20, 42:7, 42:9, 42:15, 175:9, 175:10, 37:3, 37:7, include 10:16, 247:14, 260:2, 192:15, 192:20,
308:19, 311:5 15:17, 24:12, 42:17, 42:20, 175:15, 175:22, 122:14, 127:8, 92:19, 92:21, 289:15, 290:1, 206:10, 207:6,
generally 137:16, 24:23, 25:15, 43:4, 43:8, 43:14, 175:24, 176:17, 128:18, 148:2, 143:24, 186:2, 291:13 208:7
142:2 162:10, 228:11, 231:15, 251:7, 176:24, 186:5, 148:19, 148:32, 238:12, 239:10, informed 59:22, interfered 29:22
Generals 156:15, 257:9, 292:22, 256:24, 258:21, 186:13, 190:21, 149:4, 149:13, 252:18, 252:21, 219:16 interject 12:17
156:17, 287:15 293:1, 293:7, 260:24, 263:3, 194:5, 220:16, 156:15, 156:16, 253:6 initial 106:5, 108:15, International 162:4,
generate 189:7 293:9, 293:11, 265:6, 266:6, 221:2, 221:9, 157:4, 216:22, included 132:6, 192:12 190:21, 220:17,
generated 180:23 293:18, 294:12, 269:18, 270:3, 221:16, 221:24, 218:12, 226:21, 136:14, 182:5, initially 118:22 221:24, 252:22
generic 185:10, 294:14, 294:22, 270:12, 271:23, 226:3, 236:6, 227:9, 227:13, 192:10, 214:13, initiated 31:3 Internet 229:16,
185:12 295:14, 295:19, 272:5, 288:11, 240:1, 252:22, 228:6, 228:10, 215:4, 239:9, initiative 37:11, 41:9 267:13
gentleman 44:3, 295:22, 296:2 288:15, 288:20, 268:17, 270:15, 250:19, 289:3, 253:7, 254:18, injure 256:4 interpreted 111:13
52:10, 67:8, Gournis 2:27, 289:18, 291:5 308:7 292:5, 311:24, 266:21 inquiry 185:3, 185:4, interpreting 170:1,
169:12 148:40 guy 59:9, 59:10, hallway 38:1 313:1, 313:6, includes 10:8, 243:24 308:18
gentlemen 64:19 Government 39:8, 88:17, 273:4 hand 140:9, 162:11, 313:10 179:23 inside 247:10, interruption 101:21,
Gery 273:21 41:4, 67:10, 117:7, 164:17, 235:18, immediately 16:23, including 111:23, 265:16, 265:19 171:3, 193:22
getting 28:19, 37:21, 259:9 314:6 58:21, 74:12, 250:10, 256:18 instance 77:20 interview57:2,
37:22, 38:7, GPS 28:7, 28:8 < H> handful 215:14 97:5, 131:16 income 18:11 Institute 16:5, 16:13 108:15, 233:17
124:6, 152:14, grade 70:16 hacked 44:23, Handing 90:4, 96:21, immigration 116:15, incorrect 295:2 institutions 20:11 interviewed 38:3,
160:14, 248:9, graduate 15:23 111:22, 261:19, 108:2, 130:7, 147:3 independent 290:10, instruct 12:23 38:6, 294:13
250:10, 259:11, graduated 16:3 261:20, 262:16, 154:9, 159:12, Impact 255:8, 255:9, 309:24 instructed 14:18 introduce 6:13
278:11 graduating 16:2, 263:10, 263:12, 172:12, 184:18, 255:13, 255:24, indicated 132:24 instructing 13:5, introduced 35:7,
girl 138:17, 160:11 16:15, 16:22 263:24, 264:1, 189:22, 195:10, 256:6 indict 251:18 13:24 44:7, 118:13,
Give 7:19, 8:19, grand 251:12, 278:3 200:8, 211:11, impede 73:5 indicted 222:21 instruction 13:20, 311:18
8:24, 55:12, 60:7, 251:18 hacking 121:23, 217:19, 255:2, important 93:18, indictment 251:19 100:16, 100:24, intruder 193:16
100:16, 100:23, Grant 165:2, 165:3, 123:9, 262:2, 260:20, 265:2, 125:11, 182:21 individual 76:13, 203:11, 209:8 intrudes 311:23
140:11, 169:22, 165:4, 165:5, 263:4, 278:21 270:10, 274:6, impossible 94:15 214:22, 216:16 instructions 119:16, intrusion 44:10,
187:8, 187:13, 165:9, 264:14, had. 73:19, 101:21, 276:8, 279:20, impression 190:4, individually 206:19 209:3 64:6, 64:7, 69:10,
203:9, 209:2, 297:13, 297:14, 171:3, 191:15, 288:8, 290:20, 226:20, 255:11 individuals 15:13, Insurance 106:13, 73:6, 73:12,
337 339

299:11, 301:1 head 7:22, 136:22, 240:14, 242:3, 188:16, 237:2, 73:23, 74:15, 67:23, 71:7, 71:8, issues 38:6, 38:14, 261:16, 263:3,
handle 38:8, 289:22 151:20 244:10, 244:15, 240:14, 244:14 78:3, 78:13, 80:11, 75:24, 78:12, 46:4, 46:17, 265:6, 265:15,
handled 55:3 head. 7:13, 86:13, 276:24, 277:3 hosting 139:7, 139:9 80:20, 80:24, 87:14, 87:18, 51:15, 64:3, 64:5, 270:3, 270:12,
handling 161:19 283:20 hide 270:23, 294:4 hotel 32:23 81:4, 81:21, 87:20, 88:2, 94:1, 68:1, 68:5, 68:17, 288:11, 288:14,
hands 95:4, 156:4 headed 44:7, 118:1 high 15:23, 16:2, hounding 287:14 81:23, 82:7, 103:15, 123:9, 74:4, 124:16, 288:20, 289:18,
handwriting 130:15, headers 180:4, 16:3, 16:15, 16:22 hour 1:24, 281:4 87:21, 88:3, 140:20, 145:13, 127:10, 156:18, 291:5
130:16, 243:10, 181:23 highest 297:22, hourly 254:13, 93:11, 94:9, 97:6, 150:10, 151:23, 158:18, 158:22, July 39:15, 215:11,
243:11, 243:18 hear 17:13, 89:18, 298:5 254:17 103:2, 103:13, 153:11, 160:14, 168:20, 219:5 240:23, 249:11,
handwritten 264:5, 124:12, 203:5 highlighting 147:3 hours 8:23, 10:5, 104:4, 106:17, 167:20, 168:24, item155:6, 223:21, 280:9, 282:6
264:9, 264:10, heard 36:7, 114:5, highly 183:23, 193:4 39:3, 65:11, 106:21, 108:16, 170:22, 171:22, 253:14 June 213:1, 214:9
264:18 156:9, 165:8, hire 90:22, 169:24, 66:21, 73:11, 110:11, 117:22, 202:9, 219:4, items 57:10, 57:11, jurisdiction 145:24
Hannan 159:20, 282:12, 287:12 234:24, 235:4, 111:21, 218:20 142:8, 157:6, 219:11, 247:5, 191:2 jurors 251:12
159:24, 160:2, hearing 47:22, 270:24 hours. 99:15 167:21, 170:23, 254:9, 258:3, jury 251:18, 282:15
160:4, 160:7, 282:1, 283:2, hired 43:22, 59:8, House 79:1, 79:6, 172:4, 188:2, 262:24, 266:12,
160:9, 160:17, 283:13, 283:18, 64:20, 73:4, 91:4, 79:15, 79:17, 210:5, 220:17, 268:3, 268:11, <J >
160:18, 160:20 286:22 97:5, 97:21, 230:12, 230:14, 226:6, 234:2, 277:16, 278:2, J. 2:17, 109:16, < K>
happen 41:1, 175:8, hearings 229:24 98:11, 98:14, 230:16, 230:22, 275:9, 292:18, 278:8, 278:14, 300:2, 301:13 K. 1:5, 2:3, 148:5,
275:3 hearsay 113:4 117:3, 117:5, 231:7, 264:2, 306:9, 306:14, 278:20, 303:21, jail 268:7, 268:10, 148:25, 190:23,
happened 41:2, heart 52:7 266:17, 306:4 264:8, 268:17, 311:23 306:1, 312:4 284:16 214:14, 251:13,
42:13, 43:23, Heimlich 11:9, history 20:15, 22:13 269:19, 275:15 intrusions 305:4, involvement 156:1, James 49:9, 49:11, 313:11
45:19, 45:21, 24:12, 24:17, hit 191:22, 301:24, HSP 181:3, 181:19 305:11, 305:15, 180:13, 214:16, 49:13 Kansas 202:2
59:21, 59:23, 25:14, 30:10, 302:2, 303:12 hurt 177:23 305:22, 306:13 220:9, 285:16, Jean 301:23 Kaplan 2:27, 148:40,
60:15, 61:4, 31:19, 152:15, Hobbs 235:24, husband 273:2, investigate 203:21 287:3 Jinx 138:7, 138:8 222:12
64:14, 79:16, 160:15, 160:24, 236:4, 236:7, 281:24, 282:22, investigated 285:21, involving 161:8 job 20:24, 21:16, kar 216:3
98:13, 106:5, 217:12, 227:3, 236:19, 237:22, 283:11 287:8 IP76:5, 76:6, 76:7, 23:8, 58:20, Kate 49:4, 49:7
117:19, 155:24, 228:17, 228:18, 238:22, 241:18, investigating 29:6, 76:9, 76:19, 84:5, 119:2, 170:5 Keep 17:9, 55:13,
162:14, 175:12, 250:11, 264:7, 245:23 183:24, 193:5 88:13, 91:22, Joel 222:12 105:16, 127:19,
190:4, 190:19, 266:8, 267:11, Hold 136:19, 188:3, <I > investigation 51:6, 91:24, 92:17, John 242:13, 243:4, 129:11, 190:14,
230:13, 256:14, 267:15, 288:1, 284:1, 286:13 I. 6:11, 119:1 51:14, 73:6, 99:12, 99:13, 243:24, 245:23 191:21, 191:23,
272:19, 278:12, 292:3 holding 193:19 idea 283:14 100:19, 117:21, 99:23, 100:3, Join 99:7, 131:23 194:2
281:19, 305:15, hell 285:4 Home 17:5, 17:16, IDENTIFICATION 123:23, 124:2, 100:7, 101:3, jschwartz@millersh Keeping 126:2,
305:21, 306:14, Hello 281:16 26:20, 27:12, 4:23, 5:3 158:17, 161:11, 101:11, 102:7, akman.com2:9, 127:2, 127:4,
311:11 help 98:15, 122:18, 27:15, 27:20, identification. 90:9, 201:19, 202:19, 102:12, 102:19, 148:27 127:18, 129:4,
happening 40:16, 127:13, 129:3, 28:1, 30:12, 97:3, 107:24, 209:10, 213:17, 102:23, 103:6, Judge 47:10, 47:15, 129:6, 129:8
161:1, 191:21, 161:18, 161:24, 30:15, 32:21, 125:14, 130:5, 216:10, 217:5, 103:7, 103:11, 47:22, 79:15, Kenosha 15:10
259:1, 262:21 162:1, 168:9, 65:2, 68:14, 134:21, 154:7, 219:4, 219:11, 104:1, 104:16, 79:19, 79:24, kept 57:8, 68:20,
happy 142:5 168:23, 169:7, 267:1, 268:12 159:10, 164:15, 285:17, 287:4, 104:17, 105:7, 80:4, 229:9, 93:4, 93:5
harassed 24:7, 194:2, 256:23, homicide 152:2 172:10, 184:16, 288:16, 308:6, 105:11, 133:14, 229:18, 271:20, keypunching 16:20,
24:14, 24:21 258:22, 270:18, honest 110:3, 158:2 189:20, 195:8, 312:3 171:15, 180:8, 282:15, 282:17 16:21
harassing 30:7, 307:20 Honorable 130:14 198:23, 200:6, investigative 180:11, 186:17 Julia 2:3, 6:14, 29:6, kharma 215:23
257:16, 257:19 help. 114:6 hope 175:4 211:9, 217:17, 292:21, 293:12, irrelevant 297:5 47:11, 136:16, kharma@salf 216:3
harassment 26:20, helped 100:21 Hoping 34:6, 161:15 222:7, 224:24, 293:17 irreversible 131:3 148:25 Kids 71:16, 228:24,
291:17, 291:21, helping 216:18 horrendous 262:20 235:16, 242:10, investigators 305:24 IRS 289:14 Julie 29:13, 29:16, 273:8
291:23 her. 133:2 horrible 151:18, 254:23, 260:18, invitation 39:23 issue 44:9, 48:1, 42:7, 42:9, 42:15, killing 152:6
hard 205:8, 218:22 hereby 313:7 228:2, 271:7, 264:23, 270:8, invite 40:3 65:14, 89:14, 42:17, 231:15, Kimberlly 2:13,
Harrold 160:7 herein 6:3, 150:2 272:13 274:4, 276:6, invited 39:1 152:11, 162:3, 251:7, 256:22, 148:31
harsh 53:19 hereunto 314:5 hospital 302:7 279:18, 288:6, involved 15:18, 24:8, 183:2, 210:20, 258:10, 258:21, Kind 37:6, 37:8,
hated 269:6 herself 39:9, 237:3, Host 185:11, 188:14, 290:18, 296:22, 30:8, 38:10, 239:15 259:11, 260:24, 47:19, 121:19,
338 340
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 87 of 93 PageID #:2075
2018
151:5, 178:9, 296:5 Lawrence 110:6, 62:11, 94:23, 202:9, 206:2, 136:9 307:3 231:12, 233:2,
255:18, 263:15, Laketek 32:24, 39:9 211:18 100:5, 100:15, 241:23, 270:17, Madigan 3:3, 149:3 married 273:2 233:4, 233:14,
263:16, 306:19 Lance 302:12 laws 122:15, 126:9, 114:10, 117:23, 270:24 mail 134:10, 171:9, Martin 2:33, 6:19, 247:18, 248:12,
Kindergarten 70:16 language 239:9 218:24, 311:24 165:3, 165:6, looks 86:2, 90:17, 208:8, 272:23 38:3, 43:17, 281:14, 281:15
knowledge 34:3, laptop 150:17 lawsuit 10:12, 11:8, 165:7, 166:16, 97:17, 261:19, mails 28:19 43:19, 44:6, 45:5, Maryland 225:11,
41:14, 55:6, 55:8,larger 38:7 11:17, 11:23, 168:1, 168:8, 291:7 main 112:12, 204:24, 45:8, 46:3, 46:9, 225:16, 225:17,
56:23, 60:14, Lasalle 1:22, 2:5, 12:10, 24:5, 168:13, 168:16, loose 219:21 205:8, 205:13 46:13, 46:15, 225:20
62:24, 64:14, 2:28, 148:17 24:10, 30:21, 170:13, 170:18, loss 93:19, 194:19, Mainly 70:6 46:20, 47:1, 47:3, mass 152:2
68:3, 68:10, last 8:23, 11:10, 31:3, 31:5, 31:8, 215:9, 269:21, 225:13, 252:8 maintain 70:17 47:6, 47:14, Massacre 145:15,
81:13, 88:14, 11:14, 27:5, 31:9, 41:18, 270:4, 274:18, losses 224:15 Malcolm265:14, 47:24, 48:5, 48:8, 151:13, 152:1,
100:6, 102:10, 36:15, 41:20, 41:23, 43:5, 43:8, 297:18 lost 69:8, 69:15, 266:11, 266:18 48:21, 78:16, 152:11
107:20, 107:21, 60:12, 60:16, 43:10, 46:21, left-hand 67:11 69:16, 69:18, man 63:3, 63:20, 78:18, 80:15, matched 93:22
120:11, 120:24, 102:5, 115:12, 50:21, 50:22, leg 72:17 69:20, 70:5, 65:23, 67:5, 82:1, 85:23, 86:4, material 300:18
128:21, 131:14, 120:2, 120:4, 160:24, 161:19 legal 257:11 70:20, 71:23, 67:11, 160:2, 86:5, 87:3, 89:13, materials 63:22,
143:23, 150:9, 134:24, 137:23, lawsuits 10:14, legality 47:21 72:1, 72:19, 160:11, 181:19 103:15, 103:18, 296:7, 300:13
150:19, 152:10, 141:6, 154:13, 15:18 legislation 22:3, 72:24, 80:23, managed 18:11 103:20, 103:23, Mathew51:20,
153:22, 179:9, 190:8, 216:21, lawyer 33:9, 160:4, 36:3, 37:11, 37:13, 81:3, 81:6, 92:11, manager 55:4 116:17, 117:1, 51:21, 51:23
187:12, 189:15, 267:6, 281:20, 160:9 37:14, 37:18, 115:17, 197:15, mandate 22:5 118:1, 118:4, matter 12:9, 35:24,
201:15, 201:18, 291:13 leads 183:12, 192:19 37:20, 38:2, 38:9, 197:17, 199:24, Manpower 162:5, 118:7, 118:12, 36:1, 131:1,
204:12, 216:6, Late 21:15, 22:15, learn 45:10, 70:9, 38:10, 129:20 207:10, 220:14, 162:6, 162:12, 118:20, 119:6, 161:8, 289:13
226:7, 238:17, 44:13, 64:9, 65:1, 73:3, 101:3, legislators 36:5 228:3, 244:24 162:13 119:12, 119:22, matters 11:4
279:15, 305:14, 143:5, 201:13, 116:14, 143:20, legislatures 36:21, lot 26:20, 36:2, Marcos 31:20, 32:2 120:15, 120:16, Mayor 31:20, 39:7,
305:20 201:16, 263:11, 200:20, 209:17, 37:22, 39:6 36:18, 36:19, mark 151:19, 267:8 120:20, 122:3, 131:1, 131:5,
known 47:9, 98:17, 263:13 226:13, 293:6, length 121:20 66:21, 72:22, MARKED 4:22, 5:2, 122:9, 122:19, 142:16, 145:8,
99:21, 116:7, later 14:12, 16:6, 293:9, 293:23, lengthy 61:6, 61:8, 252:17, 287:2 90:7, 97:1, 102:2, 127:15, 128:3, 145:9, 145:11,
132:4, 218:9, 21:1, 71:13, 72:8, 294:19 61:11, 141:10 lunch 147:13, 107:22, 125:12, 128:8, 128:16, 146:9, 146:10,
262:7, 262:15, 73:5, 108:13, learned 71:11, Lesiak 49:19, 49:21 147:17, 148:22 130:3, 134:19, 129:2, 145:18, 151:15, 151:21,
308:3 181:17, 200:19, 116:21, 139:15, less 306:8, 309:18 136:7, 154:5, 148:42, 150:9, 151:23, 159:1,
Kotowski 138:8, 228:16, 257:7, 177:7 letter 54:3, 54:5, 159:8, 164:13, 154:15, 154:18, 159:6, 163:12,
138:14, 138:15 269:6 least 109:21 54:21, 54:22, < M> 172:8, 179:13, 154:23, 156:7, 163:23, 230:23,
KR215:22 Law 3:15, 47:10, leave 41:13, 56:14, 56:6, 56:13, M. 2:13, 3:14, 184:14, 189:18, 156:12, 160:19, 231:2, 311:19
Kyle 3:12, 6:23, 47:15, 47:22, 175:17, 269:15 56:15, 90:16, 148:31, 149:11 195:6, 198:21, 160:21, 161:6, Meadows 79:1, 79:4,
50:15, 50:17, 73:5, 119:19, leaves 192:13 90:20, 91:8, ma'am102:11, 200:4, 211:7, 166:7, 178:1, 79:6, 79:14, 79:17
51:5, 51:13, 122:8, 129:18, leaving 151:5, 91:12, 91:20, 108:10, 109:1, 217:15, 222:5, 178:15, 178:21, mean 28:10, 32:15,
149:9, 216:5, 144:12, 144:19, 175:17, 237:3, 91:24, 92:7, 112:20, 121:2, 224:22, 232:10, 189:2, 189:5, 47:20, 63:13,
216:8 145:1, 145:4, 240:15, 242:4, 92:14, 92:19, 138:3, 138:21, 235:14, 242:8, 194:22, 195:1, 68:16, 69:21,
146:13, 146:23, 244:10 92:21, 92:24, 140:19, 141:3, 244:23, 246:6, 199:23, 200:2, 76:10, 76:18,
149:12, 157:3, led 24:21, 180:7, 94:19, 111:11, 155:23, 169:16, 254:21, 260:16, 201:22, 202:8, 78:21, 82:15,
<L> 157:5, 160:8, 180:10 122:6, 130:11, 175:11, 180:9, 260:20, 264:21, 202:10, 202:18, 85:3, 94:7, 101:9,
LA231:4 178:22, 203:11, Lee 47:10, 47:15, 131:10, 132:6, 181:13, 184:23, 270:6, 274:2, 202:24, 203:6, 107:1, 129:8,
Labor 301:24 203:14, 204:2, 266:9, 266:20, 136:14, 137:24, 186:24, 188:20, 276:4, 279:16, 203:14, 204:21, 139:10, 139:14,
lack 141:12 204:9, 204:14, 292:1 138:1, 138:16, 189:1, 189:6, 288:4, 290:16, 205:2, 205:15, 144:15, 150:23,
ladies 73:14, 191:10 204:22, 205:3, left 22:5, 23:2, 138:20, 143:8, 190:1, 215:6, 296:20, 299:7, 207:3, 209:2, 151:3, 153:11,
lady 45:20 205:15, 206:9, 23:22, 54:23, 143:24, 147:3, 224:13, 290:15, 299:16, 300:19 210:7, 210:11, 155:3, 161:21,
Lake 21:12, 21:14, 207:1, 207:3, 55:9, 55:14, 152:23, 153:5, 291:10, 291:22, Markos 51:20, 214:12, 214:19, 167:13, 171:10,
21:17, 21:22, 207:6, 208:3, 57:23, 58:2, 58:9, 153:9, 153:14, 292:12, 292:16, 51:21, 51:23 215:12, 216:16, 171:12, 176:24,
22:14, 26:9, 208:16, 209:4, 59:24, 60:8, 153:24, 155:13, 292:19, 292:24 Marrazzo 109:4, 217:1, 218:3, 205:17, 205:18,
26:10, 26:16, 209:9 60:15, 60:22, 155:14, 155:16, machine 135:14, 109:5, 307:2, 218:12, 231:8, 212:7, 216:1,
341 343

156:2, 217:22, 104:18, 106:8, 299:18, 299:24, litigation 10:12, 218:8, 226:24, 40:8 102:17, 103:8, 202:6, 210:13,
218:1, 218:5, 106:12, 107:13, 300:14, 301:4, 10:17, 14:15, 231:3, 235:12, meets 267:7, 268:20 104:24, 105:4, 211:23, 212:2,
219:7, 220:7, 107:16, 108:17, 301:9, 301:21, 15:16, 15:17, 255:9, 263:14, megabytes 92:6 105:11, 107:9, 213:10, 213:12,
222:11, 225:4, 108:22, 110:7, 302:9, 302:19, 24:11, 31:9, 31:16, 267:10, 268:21, Melongo 1:5, 3:26, 110:18, 110:21, 214:15, 214:21,
276:13, 276:20, 110:17, 113:23, 304:15 32:6, 33:13, 34:2, 272:6, 272:9, 6:15, 30:1, 30:11, 111:2, 111:6, 214:24, 216:12,
291:11, 307:16 117:21, 118:4, life-saving 23:20 43:11, 48:22, 273:23, 298:8, 31:11, 31:16, 114:4, 115:23, 217:10, 219:4,
Letters 9:14, 9:20, 118:21, 120:19, light 151:24 49:24, 157:17 311:3 32:6, 33:14, 116:3, 116:14, 220:8, 221:7,
154:16, 154:22, 121:5, 121:11, likely 165:21 little 71:1, 151:9, Meaning 28:12, 34:13, 34:20, 117:1, 117:15, 221:13, 222:1,
155:8, 250:10, 124:15, 126:10, limited 285:12 181:21, 194:5, 28:15 35:12, 35:22, 119:24, 124:17, 222:20, 223:8,
289:23 126:15, 126:16, limping 72:18 206:16, 309:3 means 50:18, 99:20, 37:4, 40:12, 42:2, 131:14, 131:21, 224:7, 224:15,
letting 48:15 126:18, 127:9, line 6:16, 22:10, live 25:21, 26:6, 186:12, 309:12, 42:21, 43:11, 132:23, 133:4, 225:14, 226:16,
level 71:15 129:24, 131:7, 40:24, 41:4, 41:6, 26:10, 272:24 309:19, 310:8 46:18, 46:21, 133:18, 134:2, 226:21, 227:18,
liar 175:3, 177:22 134:1, 135:10, 131:18, 132:11, lived 26:16, 38:20, meant 76:2, 76:18, 47:9, 50:23, 52:1, 134:9, 139:13, 228:5, 228:9,
License 1:20 135:13, 135:15, 132:17, 136:5, 38:22, 271:3 94:12, 99:21, 52:3, 52:17, 140:21, 141:11, 229:2, 231:9,
Life 9:22, 10:1, 135:19, 136:9, 163:23, 166:14, lives 142:15, 145:7 104:16, 126:24, 52:21, 53:3, 53:7, 141:13, 142:2, 232:6, 232:18,
11:19, 21:2, 21:3, 146:4, 150:11, 182:2, 193:20, livid 257:2 127:14, 127:15, 53:15, 53:18, 142:7, 142:12, 232:22, 232:23,
21:7, 21:24, 22:8, 150:16, 150:18, 199:12, 210:2, living 26:5, 230:22, 141:19, 167:16, 53:23, 54:14, 142:14, 142:19, 233:10, 233:20,
22:18, 22:24, 152:11, 156:17, 215:4, 217:9, 231:1 170:22, 258:24 54:17, 55:1, 55:7, 143:10, 143:20, 233:23, 234:14,
23:3, 23:6, 23:9, 158:17, 158:23, 217:10, 223:20, LLP 2:4, 148:26, media 34:19 55:17, 55:21, 144:1, 144:24, 236:16, 236:20,
23:11, 23:17, 161:3, 165:18, 237:1, 240:9, 160:8 medial 304:13 56:5, 56:20, 145:6, 146:8, 237:2, 237:4,
23:20, 23:22, 168:9, 168:20, 247:9, 261:22, local 293:17 medic 37:14 56:24, 57:4, 57:6, 147:2, 148:5, 237:9, 237:11,
23:23, 23:24, 170:23, 172:18, 287:16, 297:3 log 99:12, 186:17, Medical 16:9, 20:1, 57:21, 58:2, 58:8, 149:20, 150:15, 237:24, 238:4,
24:2, 24:22, 25:2, 172:23, 175:10, link 78:1, 192:12, 200:13, 235:3 20:2, 38:10, 59:2, 59:14, 150:17, 153:16, 239:2, 239:15,
25:17, 32:16, 176:5, 182:1, 194:23, 228:18, logged 99:13, 99:23, 269:7, 296:13, 59:18, 59:21, 158:22, 161:14, 240:14, 240:16,
37:1, 37:15, 182:9, 187:13, 266:21 100:4, 100:7, 302:11, 302:13, 59:23, 60:6, 163:9, 163:19, 240:20, 240:22,
44:10, 46:16, 189:3, 191:22, linked 92:17, 103:12, 101:3, 102:8, 302:14, 302:20, 60:15, 60:24, 164:2, 164:3, 241:4, 241:6,
51:15, 52:22, 193:1, 200:13, 104:2, 204:24, 104:18, 232:24 304:8 61:4, 61:12, 168:5, 168:8, 241:14, 242:2,
53:23, 54:13, 203:1, 203:9, 205:6, 205:20, logs 183:14, 192:21 meet 9:7, 37:10, 61:21, 62:5, 168:23, 169:6, 243:13, 244:9,
54:16, 55:18, 203:10, 203:17, 213:9, 228:11, long 20:18, 52:21, 38:18, 40:11, 62:13, 62:18, 169:17, 170:1, 244:14, 244:17,
56:14, 57:4, 57:6, 204:4, 204:9, 230:6, 253:12, 69:5, 95:1, 42:14, 52:3, 73:22, 74:3, 170:10, 170:22, 246:23, 247:3,
58:3, 58:9, 59:15, 204:16, 205:11, 267:21, 269:11 153:18, 167:1, 124:21, 129:14, 74:14, 74:17, 171:16, 171:21, 247:4, 247:20,
59:19, 60:1, 209:14, 209:18, links 192:14, 230:8, 176:4, 223:11, 158:21, 258:17, 75:8, 75:19, 172:17, 173:9, 248:1, 248:5,
60:10, 60:12, 210:22, 211:19, 271:3 281:1 269:15, 269:24, 75:23, 77:23, 174:14, 175:1, 248:14, 249:17,
61:1, 61:2, 62:13, 213:2, 216:9, Lisa 3:3, 149:3, longer 144:5, 270:3, 281:1 78:2, 78:12, 79:7, 175:23, 176:4, 251:13, 251:15,
62:18, 62:20, 219:5, 219:12, 276:14, 276:20, 236:24, 240:10, meeting 36:11, 80:10, 80:18, 176:18, 176:23, 252:3, 253:12,
63:2, 63:18, 223:7, 224:5, 279:11, 280:1 242:21, 242:22 38:13, 39:2, 81:9, 81:14, 177:4, 177:8, 253:16, 257:18,
63:24, 64:3, 64:6, 224:10, 225:6, list 214:14, 249:19, look 102:5, 109:2, 39:12, 39:15, 82:20, 83:7, 83:11, 177:13, 177:15, 260:3, 260:10,
64:8, 67:6, 67:16, 225:12, 225:21, 253:6, 253:7 140:5, 140:9, 39:19, 39:20, 83:16, 83:24, 177:20, 178:3, 262:1, 262:12,
67:24, 68:12, 226:5, 228:1, listed 109:15, 133:5, 145:20, 174:9, 39:21, 40:1, 40:9, 84:6, 84:11, 178:24, 179:8, 262:16, 262:24,
69:14, 70:16, 228:15, 232:24, 136:4, 138:8, 181:21, 208:19, 40:20, 41:11, 84:19, 84:23, 180:12, 181:24, 264:7, 266:7,
70:17, 71:7, 233:24, 246:15, 234:12, 243:14, 216:2, 245:1, 118:12, 118:13, 84:24, 85:4, 182:1, 182:8, 267:14, 267:18,
71:17, 71:21, 252:1, 253:1, 253:14, 254:1 306:17, 307:15 159:2, 159:5, 85:11, 86:2, 87:10, 183:7, 184:8, 267:23, 268:6,
73:23, 74:15, 272:24, 277:9, Listen 96:8, 124:6, looked 66:2, 123:16, 163:6, 163:7, 87:14, 87:18, 184:9, 184:12, 271:4, 271:24,
80:2, 80:6, 81:14, 287:1, 287:8, 166:20, 196:4, 153:2, 309:15 163:13, 163:21, 87:20, 88:1, 187:20, 190:23, 273:15, 274:23,
81:22, 82:10, 289:16, 290:1, 211:3, 302:22 looking 47:20, 163:23, 164:3, 88:14, 88:16, 191:4, 194:9, 275:6, 276:24,
82:19, 89:4, 291:9, 292:10, listening 6:16 76:16, 114:10, 203:5, 212:9, 88:21, 89:2, 89:5, 194:23, 195:13, 277:2, 277:6,
97:22, 98:12, 292:14, 292:22, listing 191:2, 225:6 120:3, 135:18, 212:11, 311:20 89:22, 92:14, 198:2, 201:1, 278:1, 278:8,
98:20, 100:18, 295:23, 296:7, literally 27:17 137:3, 137:5, meetings 39:18, 92:17, 99:5, 202:1, 202:4, 278:12, 278:13,
342 344
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 88 of 93 PageID #:2076
2018
278:20, 279:11, 234:24, 235:4, minutes 281:4 289:15, 289:23, 280:19, 281:3, name 6:8, 6:14, 131:2 nice 273:10
279:14, 280:8, 235:24, 236:23, missing 92:11, 290:14, 291:12, 281:13, 281:17, 11:10, 11:15, need 8:10, 12:23, Nifro 4:11
280:11, 280:19, 237:1, 237:4, 141:18, 141:20 291:20, 292:5 282:5, 283:2, 24:18, 27:5, 35:3, 13:22, 14:3, night 73:11, 74:18
281:3, 281:13, 240:13, 241:1, mission 23:18, Mount 16:9, 19:16, 283:5, 283:10, 36:15, 44:21, 70:17, 78:24, nine 137:7
281:17, 282:5, 241:18, 244:11, 126:8, 126:15 19:22, 20:3, 20:10 284:2, 284:10, 45:21, 47:16, 86:3, 130:24, nine. 137:9
283:2, 284:2, 244:13, 245:24, Missouri 202:1, move 25:24, 26:18, 284:15, 284:24, 50:5, 50:16, 139:1, 162:15, nineteen 17:24
284:10, 284:15, 247:8, 277:10 202:2 26:19, 26:24, 285:7, 285:9, 50:20, 51:3, 51:5, 177:18, 228:19, NINFO3:14, 6:18,
284:24, 285:9, message 34:4, 34:8, misstated 295:20 27:11, 95:17, 285:17, 285:21, 51:13, 63:5, 63:6, 228:22, 228:23, 7:15, 7:17, 9:5,
285:17, 285:21, 34:16, 114:11, misstating 295:6 228:24, 230:13, 287:4, 288:7, 66:1, 77:21, 272:8, 272:9, 12:14, 12:17,
287:4, 292:9, 134:13, 166:16, misunderstand 231:24 290:19, 290:22, 77:23, 102:17, 289:12 13:19, 14:1, 14:7,
292:13, 297:5, 168:1, 168:7, 311:13 moved 26:12, 33:23, 291:3, 292:9, 105:12, 106:11, needed 8:16, 41:5, 14:10, 14:11,
310:23, 313:11 168:13, 168:16, misunderstood 43:13, 43:14, 292:13, 295:18, 107:4, 109:6, 52:5, 52:7, 72:15, 14:17, 18:3, 18:6,
Melongo_002169 170:18, 186:19 53:21, 77:13, 202:15 296:23, 297:8, 130:18, 130:20, 79:13, 95:16, 30:24, 40:4,
301:2 messaged 43:7 112:13, 208:12 movement 238:14 297:10, 298:1, 138:10, 141:2, 98:3, 127:12, 48:12, 48:17,
Melongo_004398 messages 34:19, MIT 16:4, 16:5, moving 27:9 298:21, 299:1, 163:20, 165:2, 146:19, 161:13, 51:9, 55:23,
217:20 168:7, 206:12 16:12, 20:9 MS 2:3, 2:13, 2:15, 299:10, 299:15, 165:8, 169:13, 206:1, 269:21, 56:17, 60:2,
Melongo_006060 messed 161:22 Mobilehome 32:2 3:3, 3:5, 3:14, 299:17, 300:24, 173:10, 173:11, 270:1 60:17, 60:20,
297:1 met 35:14, 35:17, moment 22:9, 60:21, 3:21, 3:26, 4:5, 303:1, 303:6, 185:11, 197:12, needs 34:7 62:15, 68:6, 77:1,
Melongo_006063 35:23, 38:16, 172:7, 174:23, 4:8, 4:11, 4:17, 303:17, 303:22, 212:7, 216:21, negative 177:12, 77:3, 77:9, 81:17,
299:16 38:20, 38:22, 193:20, 228:20, 6:6, 6:15, 6:21, 304:2, 305:3, 221:5, 221:15, 178:11 83:12, 87:2,
Melongo_annabel@ 39:2, 42:11, 42:24, 228:22, 228:23, 6:23, 7:1, 7:2, 310:16, 310:18, 224:20, 227:7, negatively 54:8 92:22, 93:3,
yahoo.com 43:2, 45:5, 45:8, 284:5, 288:8 7:18, 9:5, 13:3, 310:20, 310:23, 227:9, 227:12, neighbor 230:14 94:11, 96:8, 99:7,
82:13, 165:13 46:9, 46:15, 49:7, money 22:1, 220:14, 13:4, 13:19, 312:8, 312:11 233:8, 243:13, Network 36:8, 39:11, 100:10, 101:5,
member 311:19 49:11, 50:7, 50:16, 223:13, 223:14, 13:23, 13:24, mtg 162:23 247:20, 248:1, 99:12, 236:14, 101:19, 104:7,
members 89:21, 51:18, 124:22, 267:8, 268:20, 14:5, 14:8, 14:10, Mullins 32:8, 32:9, 248:5, 248:14, 277:3 104:20, 106:14,
259:21, 311:18 124:23, 129:17, 268:21, 268:23, 14:12, 14:13, 32:18, 32:21, 248:16, 263:6, new66:19, 88:19, 106:23, 107:1,
memory 190:14 163:2, 202:24, 269:1, 272:12, 14:17, 15:20, 33:5, 39:6, 131:2, 265:11, 265:13, 113:10, 114:13, 115:4, 121:14,
men 63:15, 144:15 216:4, 217:3 272:21, 297:13 17:12, 17:14, 131:4, 131:9, 265:19, 266:4, 114:16, 121:24, 122:24, 125:9,
mental 266:10 metadata 308:19, Monge 216:21 18:6, 18:7, 25:21, 145:8, 145:9, 280:20, 280:21, 122:13, 127:13, 129:10, 131:23,
mention 220:6, 309:10 monitoring 150:14, 30:1, 30:11, 31:2, 146:9, 146:10, 280:24, 289:8, 155:6, 186:6, 133:9, 135:23,
292:4 Michelle 33:18, 231:11, 231:13 31:11, 31:16, 151:15, 152:10, 301:9 218:20, 218:24, 140:7, 140:11,
mentioned 12:11, 33:21, 34:1 months 71:13, 32:6, 32:9, 32:18, 159:1, 159:6, named 11:11, 33:18, 237:8, 240:19, 140:23, 142:10,
15:7, 15:16, Michigan 3:16 71:15, 72:12, 32:21, 33:5, 163:5, 163:12, 214:4, 214:20, 247:2, 248:9 143:14, 149:11,
27:12, 33:12, middle 181:19 143:6, 153:14, 33:14, 34:5, 163:23, 259:22, 266:10, 274:9, newly 273:2 158:7, 164:5,
33:15, 35:2, miles 273:1 194:15, 230:20 34:13, 34:18, 260:2, 311:19 280:1, 291:8 News 12:10, 13:15, 164:9, 164:12,
81:23, 84:10, military 67:9, 67:12 morning 6:7, 64:24, 34:20, 34:22, Mullins. 142:16 names 213:16, 14:21, 15:16, 166:20, 169:3,
88:12, 89:19, Miller 2:4, 148:26 65:6, 65:10, 35:12, 35:22, municipal 39:8, 213:20, 213:21, 24:11, 228:11, 172:1, 173:24,
102:17, 111:16, Mills 3:15, 149:12 65:16, 73:10, 37:4, 39:6, 40:6, 41:4, 163:16, 213:22, 266:10 292:21, 293:16, 174:5, 178:4,
129:15, 133:10, Milwaukee 15:11, 98:2, 150:8, 40:7, 40:12, 42:2, 163:17 naming 49:23 293:17, 293:24 183:9, 187:23,
163:6, 169:12, 16:5, 16:10, 151:12, 156:14, 42:20, 42:21, Munya 33:19, 33:21, Nancy 280:22 newspaper 230:9, 188:3, 193:7,
227:9, 227:12 16:12, 17:4, 17:6, 157:10, 164:24, 43:4, 43:8, 43:11, 34:1, 34:5 nasty 152:21, 228:1 271:3 196:4, 196:7,
mentions 104:12, 17:15 168:4, 207:18 43:14, 46:18, murders 152:8 national 307:23 next 7:19, 21:22, 203:19, 208:1,
112:9 mind 11:3, 48:15, mother 18:1, 18:10, 46:21, 47:9, myself 72:11, 84:3, nationally 37:16 111:19, 114:13, 211:3, 224:17,
merchandise 193:19, 306:18 273:7 48:14, 48:18, 256:18, 258:12, Neal 254:8 115:22, 134:6, 231:21, 231:23,
212:15, 212:16, minds 36:12 Motion 29:2, 29:10 48:19, 50:23, 270:17, 273:9 near 38:21 142:13, 243:22, 234:4, 234:21,
215:3 mine 32:24, 33:22, motions 229:15, 51:12, 52:3, nearly 256:16, 251:11, 267:5, 238:2, 239:4,
Mercury 200:21, 205:21 229:23 52:17, 52:21, 284:16 271:18 242:7, 245:4,
234:9, 234:16, minute 51:10, 291:2 Motyka 289:9, 53:3, 53:7, 53:15, <N> necessary 14:8, Nic 234:12 245:10, 245:14,
345 347

53:18, 53:23, 104:24, 105:4, 168:23, 169:5, 228:5, 228:9, 245:17, 249:20, 97:2, 98:22, 279:17, 281:7, 192:9
54:14, 54:17, 106:19, 106:24, 169:6, 169:17, 228:19, 229:2, 249:23, 265:9, 101:18, 105:5, 285:19, 288:5, notified 31:24, 82:5,
55:1, 55:7, 55:17, 107:7, 107:9, 170:1, 170:10, 231:9, 231:22, 265:15, 265:20, 107:14, 107:18, 288:9, 288:21, 145:21, 146:5,
55:21, 56:3, 56:5, 108:1, 108:4, 170:22, 171:4, 231:24, 232:3, 273:11, 273:22, 107:23, 110:3, 290:8, 290:17, 153:19, 165:24,
56:19, 56:20, 110:21, 111:2, 171:16, 171:21, 232:4, 232:23, 273:24, 277:18, 115:9, 115:16, 290:21, 293:14, 166:2, 212:19,
56:24, 57:4, 57:6, 111:6, 114:4, 172:3, 172:11, 233:10, 233:20, 278:16, 279:7, 118:19, 119:20, 295:1, 296:17, 212:22, 260:7,
57:21, 58:2, 58:8, 115:10, 116:3, 172:17, 174:1, 233:23, 234:5, 283:4, 283:8, 120:1, 122:21, 296:21, 299:8, 272:18, 286:19
59:14, 59:18, 116:14, 117:1, 174:2, 174:6, 234:23, 235:17, 285:2, 288:3, 123:24, 125:2, 299:12, 300:12, notify 86:3, 145:24
59:21, 59:23, 117:15, 119:24, 174:14, 175:1, 235:21, 236:20, 290:22, 291:1, 125:13, 128:22, 300:20, 301:2, November 292:20,
60:5, 60:6, 60:15, 121:16, 123:2, 175:23, 176:4, 237:24, 238:7, 295:17, 297:3, 129:7, 130:4, 301:19, 308:15, 295:15
60:18, 60:23, 124:17, 125:4, 176:8, 176:9, 239:2, 239:8, 298:17, 298:19, 130:8, 134:3, 309:13, 309:15, null 124:11
60:24, 61:4, 125:6, 125:10, 176:11, 176:12, 239:15, 240:22, 298:23, 302:4, 134:20, 140:7, 311:6, 311:8, number 46:8, 46:10,
61:12, 61:21, 125:15, 125:16, 176:15, 176:16, 241:6, 242:2, 302:22, 303:4, 145:3, 148:8, 313:14, 314:13 69:13, 81:10,
62:5, 62:11, 129:13, 130:6, 176:18, 176:23, 242:11, 243:13, 303:14, 303:23, 154:1, 154:6, Nobody 36:17, 83:21, 94:1,
62:12, 62:13, 131:9, 131:14, 177:4, 177:8, 244:17, 245:5, 304:2, 304:20, 154:10, 156:10, 121:24, 122:15, 135:17, 135:21,
62:17, 62:18, 131:21, 132:1, 177:13, 177:15, 245:11, 245:15, 309:3, 312:12 156:13, 156:23, 124:12, 216:3, 136:2, 136:3,
65:4, 65:9, 68:9, 132:23, 133:4, 177:20, 178:3, 245:20, 245:22, No. 1:8, 1:20, 4:26, 159:9, 163:11, 230:17, 269:23, 136:9, 172:18,
73:15, 73:20, 133:15, 133:18, 178:16, 178:24, 247:4, 248:1, 4:27, 4:28, 4:29, 164:14, 165:7, 271:16 175:2, 177:8,
73:21, 74:3, 134:2, 134:9, 179:8, 180:12, 248:5, 248:14, 4:30, 4:31, 4:32, 165:10, 167:18, nods 7:22 182:1, 195:18,
74:14, 74:17, 134:22, 134:23, 180:21, 181:24, 249:17, 249:21, 4:33, 4:34, 4:35, 170:12, 172:9, None 65:18, 161:16 227:12, 230:19,
75:8, 75:19, 136:1, 136:6, 182:8, 183:1, 250:1, 251:15, 4:36, 4:37, 4:38, 173:18, 174:5, nonprofit 250:21 245:17, 309:3
75:23, 77:5, 136:20, 137:1, 183:7, 184:8, 252:3, 253:12, 4:39, 4:40, 4:41, 184:15, 187:18, nor 314:2, 314:3 numbered 130:8
77:23, 78:2, 137:3, 138:14, 184:9, 184:12, 255:1, 257:18, 4:42, 4:43, 5:5, 189:19, 195:7, North 1:22, 2:5, numbers 72:10,
78:12, 79:7, 139:13, 140:8, 184:17, 187:20, 260:3, 260:10, 5:6, 5:7, 5:8, 5:9, 195:11, 195:20, 2:28, 3:16, 148:17 111:24, 112:17,
80:10, 80:18, 140:15, 140:21, 188:1, 189:21, 260:19, 262:1, 5:10, 5:11, 5:12, 198:22, 200:5, Northern 1:2, 12:6, 206:16, 206:18,
81:9, 81:14, 141:1, 141:11, 191:4, 191:11, 262:12, 262:16, 5:13, 5:14, 5:15, 200:19, 202:21, 148:2, 313:10 207:13
81:20, 82:20, 141:13, 142:2, 191:14, 191:16, 262:24, 264:7, 5:16, 5:17, 5:18, 203:13, 205:8, not-for-profit 300:1 numerous 277:12
83:7, 83:11, 142:7, 142:12, 193:9, 193:19, 265:1, 265:12, 5:19, 8:21, 14:23, 208:12, 209:11, notary 1:20, 313:5 nurse 296:9, 296:16,
83:13, 83:16, 142:14, 142:19, 193:23, 195:9, 265:17, 265:21, 15:1, 17:2, 23:5, 211:8, 213:15, Note 93:18, 186:17, 296:18, 298:5,
83:24, 84:6, 143:10, 143:19, 196:5, 196:9, 266:6, 266:7, 29:24, 30:19, 214:3, 214:5, 236:22, 241:4, 304:4, 304:18
84:11, 84:19, 143:20, 144:1, 199:1, 200:7, 267:14, 267:23, 33:4, 33:6, 33:10, 217:16, 217:19, 264:18 Nursing 16:7, 16:8,
84:23, 84:24, 144:24, 145:6, 201:1, 202:1, 268:6, 269:18, 34:3, 34:14, 219:14, 221:18, notes 234:11, 237:4 17:1, 17:20,
85:4, 85:11, 86:2, 146:8, 147:2, 202:4, 202:6, 270:9, 271:23, 34:17, 35:18, 222:6, 223:22, Nothing 36:23, 19:10, 300:7,
87:10, 87:14, 147:12, 147:15, 203:22, 208:2, 271:24, 272:5, 43:1, 43:3, 43:6, 224:23, 225:3, 40:18, 41:15, 300:11, 304:6,
87:18, 87:20, 148:25, 148:31, 210:13, 211:10, 273:12, 273:15, 43:9, 48:6, 49:8, 235:15, 240:6, 65:17, 65:21, 304:10
88:1, 88:14, 148:33, 149:3, 211:13, 212:2, 274:5, 274:18, 49:10, 49:16, 242:6, 242:9, 70:1, 122:16,
88:16, 88:21, 149:5, 149:11, 213:10, 213:12, 274:19, 274:23, 49:18, 49:20, 246:20, 247:16, 173:10, 205:21,
89:2, 89:5, 89:22, 149:15, 149:20, 214:21, 214:24, 275:6, 276:7, 50:4, 50:8, 50:11, 249:7, 249:24, 206:17, 207:17, <O>
90:4, 90:10, 150:6, 150:8, 215:9, 215:10, 276:11, 276:24, 50:14, 50:19, 254:20, 254:22, 221:22, 226:8, o'clock 64:22, 64:24,
92:14, 92:17, 150:15, 150:17, 216:12, 217:10, 277:2, 277:6, 51:19, 51:22, 255:3, 256:7, 281:16, 284:21, 65:2, 65:6
92:23, 93:8, 152:10, 153:16, 217:18, 219:4, 277:19, 278:1, 51:24, 54:18, 258:9, 260:11, 285:15, 287:18, O'hara 49:5, 49:7
94:23, 96:10, 154:8, 158:8, 220:8, 221:13, 278:8, 278:13, 56:22, 57:1, 58:7, 260:15, 260:17, 287:19, 294:3, O. 29:3
97:4, 99:5, 99:9, 158:22, 159:11, 222:1, 222:8, 278:18, 278:20, 59:20, 61:18, 264:1, 264:22, 304:20, 312:11, oath 79:21
99:17, 99:18, 163:5, 163:9, 222:20, 223:2, 279:5, 279:9, 62:3, 62:9, 64:1, 265:3, 270:5, 313:17 Object 93:3, 104:7,
100:14, 101:8, 163:19, 164:2, 223:3, 223:8, 279:11, 279:13, 66:14, 73:2, 73:7, 270:7, 271:10, notice 136:17, 104:20, 115:4,
101:20, 101:22, 164:3, 164:16, 224:7, 224:15, 279:14, 279:19, 73:9, 74:12, 78:8, 271:16, 274:3, 220:14 180:14, 188:5,
101:24, 103:8, 164:20, 166:23, 225:1, 226:16, 280:6, 280:7, 79:22, 81:5, 81:7, 275:11, 275:14, noticed 99:13, 297:3
104:8, 104:22, 168:5, 168:8, 226:21, 227:18, 280:8, 280:11, 90:5, 90:8, 96:20, 276:5, 276:9, 185:23, 188:16, Objection 55:23,
346 348
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 89 of 93 PageID #:2077
2018
56:17, 60:2, 84:12, 91:16, 106:8, 108:22, 57:11, 63:3, 63:4, 234:15, 237:4, 259:12, 259:19, 281:21, 298:6 28:9, 28:11,
60:17, 62:15, 103:17, 103:18, 110:7, 118:5, 64:5, 71:17, 72:11, 240:16, 242:20, 260:1, 266:11, personal 27:21, 37:22, 41:21,
68:6, 77:9, 81:17, 111:18, 118:9, 118:21 72:17, 73:8, 242:22, 242:24, 269:5, 285:14, 80:17, 103:9, 42:18, 45:16,
83:12, 94:11, 99:6, 122:1, 124:7, official 152:13, 82:21, 83:3, 243:2, 243:5, 305:15, 305:21, 112:1, 112:23, 46:12, 47:4, 47:5,
100:10, 101:5, 126:24, 127:23, 287:5, 302:10 83:19, 88:19, 243:7, 244:2, 305:24, 306:3 114:23, 120:24, 47:7, 48:5, 48:20,
106:14, 106:23, 128:1, 128:10, officials 31:22, 93:4, 106:4, 244:6, 244:18, peoples 305:10 124:24, 126:1, 48:22, 50:10,
121:14, 129:10, 128:13, 128:17, 157:3, 157:6 114:2, 115:18, 246:2, 246:14, per 91:8, 92:8 126:4, 126:11, 50:18, 54:19,
131:22, 133:9, 128:18, 129:3, often 53:12, 72:12, 122:14, 137:11, 246:19 percent 69:14, 126:18, 127:18, 56:5, 56:11,
140:23, 142:10, 138:11, 149:7, 129:21, 215:12 140:24, 141:18, passwords 57:12, 69:17, 71:15, 134:11, 134:13, 61:20, 61:22,
169:3, 178:4, 151:5, 153:8, Okay 8:8, 10:3, 11:1, 142:8, 164:23, 57:22, 58:15, 72:15, 72:19, 204:22, 205:4, 81:15, 94:21,
183:9, 187:23, 153:17, 153:23, 14:5, 15:12, 18:5, 165:23, 166:1, 58:18, 58:19, 115:14, 115:18 205:5, 205:16, 113:6, 114:4,
203:19, 224:17, 156:1, 156:15, 42:5, 74:9, 87:7, 166:21, 167:4, 58:24, 59:5, percentage 69:14, 205:18, 206:3, 123:15, 135:16,
234:4, 238:2, 156:17, 158:24, 96:12, 134:14, 171:14, 172:21, 59:15, 60:8, 72:6 207:15, 230:24, 136:3, 157:18,
239:4, 249:20, 162:23, 168:14, 136:23, 138:24, 173:24, 174:12, 88:17, 88:18, perform93:20 231:1, 236:17, 157:24, 162:23,
277:18, 278:16, 175:17, 178:9, 140:3, 140:11, 178:11, 179:17, 88:20, 89:4, 99:2, performance 110:18, 256:13, 256:15, 168:3, 168:14,
279:7, 285:2, 200:22, 203:15, 141:8, 147:14, 182:5, 193:19, 99:5, 131:15, 111:2, 111:6, 305:14 171:3, 193:20,
302:4, 303:4, 203:16, 207:5, 157:20, 159:15, 196:2, 206:19, 131:16, 131:21, 111:14 Personally 11:21, 210:8, 230:19,
303:14 210:8, 216:22, 164:11, 171:6, 207:14, 210:7, 132:9, 132:11, performed 140:18, 41:22, 109:6, 230:24, 241:19,
obliviate 117:2 231:2, 241:21, 174:10, 176:15, 211:15, 212:10, 132:13, 132:14, 232:20 226:8, 291:15, 241:22, 259:11
observation 192:12 247:10, 247:21, 193:12, 225:7, 221:5, 228:6, 132:17, 169:14, perhaps 113:23 304:3 phoned 168:14
obtain 161:9 250:15, 250:20, 228:21, 246:20, 230:6, 234:12, 169:23, 183:14, period 22:21, 23:10, personnel 93:20, phones 168:4
occur 285:13 250:23, 251:4, 249:1, 288:13, 238:13, 242:16, 183:16, 183:21, 248:6, 254:6 94:1 physicians 302:15
occurred 152:2, 253:8, 253:17, 288:23, 293:2, 245:3, 245:4, 192:21, 234:1, permanent 52:9 pertain 284:17, pick 24:24
178:10, 311:24 253:22, 281:2, 293:3, 293:4, 245:6, 246:6, 238:18, 277:4 permanently 72:21 284:18 picked 33:1, 153:19
occurrence 237:10 282:11, 286:2, 295:17, 304:6, 247:8, 261:1, past 155:1, 170:4, permission 82:11, pertaining 1:18, picture 248:15,
occurrences 240:20 286:20, 287:15, 305:18, 305:19, 262:13, 264:5, 311:18 145:19, 145:22, 163:10, 163:22 248:16
October 143:6, 287:20, 289:20, 306:12, 306:17, 267:2, 267:18, pathological 175:3, 257:13 Peter 6:10, 11:9, pictures 230:22
190:7 292:6, 293:15, 306:20, 307:14, 270:17, 272:17, 177:22 permitting 13:23 24:12, 24:17, piece 36:3, 229:8
odd 117:10, 142:6 294:2, 294:13, 309:4, 309:8, 281:4, 284:21, pause 193:21 perrymedic 183:20, 25:14, 30:10, pieces 80:9
offender 111:21, 298:10, 310:23, 309:17, 309:21, 288:8, 302:12, pay 22:7, 25:20 193:1 31:19, 152:15, pin 239:14, 239:17
112:1, 114:22, 311:5 310:2, 310:10, 311:18, 312:1, paycheck 21:11 perseverance 160:15, 160:24, Pitsburg 302:14
211:23, 212:3 Officer 44:3, 106:7, 311:2, 311:12, 312:7 PC 205:12, 205:16, 218:13 217:12, 227:3, place 57:14, 64:8,
offense 144:13, 106:10, 108:20, 311:14, 312:8, one-to-one 39:20 205:19, 206:6 person 39:4, 41:3, 228:17, 228:18, 65:10, 73:12,
251:13 109:3, 109:4, 312:10 one. 11:3, 16:11, penalized 230:1 41:21, 42:15, 250:11, 264:7, 230:6
offer 168:9 109:5, 109:8, old 301:22 212:6, 242:16, pending 8:12, 313:9 45:8, 46:9, 48:22, 266:8, 267:11, placed 52:10, 175:18
offered 168:22, 109:11, 110:20, oldest 228:1 245:6, 271:12, penetrated 86:3 58:22, 61:20, 267:15, 267:19, places 144:10
220:20, 221:19 111:1, 112:5, on-line 65:24, 97:24 309:3 people 9:19, 24:7, 62:1, 63:4, 75:14, 269:6, 271:4, Plaintiff 1:7, 1:16,
offering 166:17, 112:21, 113:1, Once 35:23, 46:22, ones 91:21, 261:18, 24:20, 31:19, 75:18, 76:22, 287:24, 292:3 2:10, 6:15, 11:16,
168:1, 168:17, 113:24, 116:2, 124:9, 130:2, 309:23 36:8, 37:19, 38:7, 78:6, 81:14, Peters 90:12, 90:16, 90:4, 90:7, 96:21,
168:19, 170:18 117:20, 119:7, 150:20, 151:7, ongoing 14:22, 39:1, 40:19, 123:15, 128:13, 91:11, 91:18, 97:1, 107:22,
offers 169:7 119:10, 119:22, 168:14, 275:15, 194:8 41:10, 58:23, 138:9, 138:15, 92:8, 92:24, 94:9, 108:2, 125:7,
Office 3:7, 42:12, 202:9, 211:17, 294:18 open 72:11, 105:16, 103:22, 111:18, 141:2, 162:11, 94:12, 94:14, 125:12, 130:3,
43:20, 44:7, 45:6, 212:1, 212:12, One 7:17, 7:19, 8:6, 207:14, 208:6 144:15, 146:22, 162:18, 178:12, 95:7, 95:21, 130:7, 134:17,
45:10, 46:2, 46:3, 307:3, 307:21 11:3, 11:8, 15:10, operational 23:23 151:11, 152:5, 219:17, 231:5, 96:13, 125:17, 134:19, 148:7,
52:10, 53:11, officers 22:3, 70:13, 16:11, 18:12, opinion 31:21, 153:11, 173:9, 234:14, 238:16, 126:3 148:28, 154:5,
54:21, 55:5, 55:9, 122:8 29:19, 45:14, 255:16 192:1, 233:17, 255:12, 256:18, phernon@tribune.c 154:9, 159:8,
58:16, 66:2, 66:4, offices 57:20, 58:2, 47:8, 47:14, oppose 129:20 258:13, 258:16, 262:11, 264:12, om280:2 159:12, 164:13,
72:13, 84:11, 60:1, 60:10, 48:20, 56:18, opted 95:17 259:7, 259:9, 264:17, 273:21, Phone 6:16, 6:17, 164:17, 172:8,
349 351

order 135:6, 154:12, 220:19, 239:12, 245:1, 251:11, 108:21, 110:10, 172:12, 184:14, 275:24, 288:11, 260:14, 268:4, 191:19, 194:1
154:13, 159:14, 243:17, 257:3, 270:15, 289:6, 120:21, 121:1, 184:18, 189:18, 288:15, 288:19, 268:14, 268:16, Pres 133:1
159:16, 161:3, 257:12, 260:6 289:12, 297:18, 121:6, 121:12, 189:22, 195:6, 289:19, 291:6, 308:6, 312:3 presence 283:11,
257:6, 268:4 owned 92:13, 98:10, 297:21, 298:20, 123:22, 124:2, 195:10, 198:21, 313:12 policies 106:18 313:20
ordered 271:20 263:7 298:22, 299:2, 124:5, 128:9, 199:2, 200:4, point 56:20, 62:10, policy 106:21, Present 3:24, 57:20,
orders 269:9 owner 80:1, 80:5 299:4, 299:16, 145:19, 146:3, 200:8, 211:7, 65:3, 88:11, 107:13 118:17, 149:19,
org 183:20, 193:1 299:21, 301:19, 148:43, 165:20, 211:11, 217:15, 92:16, 94:22, politician 272:17, 190:24, 229:10,
organization 22:2, 301:20, 313:3 172:22, 187:9, 222:5, 222:9, 99:16, 118:21, 272:19, 273:21 255:7, 282:23,
32:1, 181:2, 296:1 <P> Pages 135:6, 137:7, 187:14, 187:19, 224:22, 225:2, 183:6, 210:20, pornographic 202:5 313:24
Ori 3:15, 149:12 P-o-h-e 27:4 137:10, 154:12, 201:20, 202:19, 235:14, 235:18, 215:8, 223:1, portion 114:21, presented 178:14,
original 181:16, p.m. 147:18, 148:16, 154:15, 167:4, 209:13, 210:4, 242:5, 242:8, 274:17, 280:5, 198:9, 286:24 221:9
208:15, 285:14 165:14, 179:21, 243:14, 246:6, 212:24, 213:5, 254:21, 255:2, 301:8 position 170:14, preserve 119:17,
originally 181:16 236:8 276:20, 309:1 214:11, 217:4, 260:16, 260:21, point. 156:5 170:15 209:3, 209:8
originated 237:7, packed 269:22 paid 175:20, 224:7, 218:11, 225:5, 260:22, 264:21, pointing 136:6, positively 219:17 President 23:11,
240:18, 247:1 PAGE 4:2, 93:15, 225:20, 225:23, 312:3 265:3, 270:6, 139:22, 140:1, possibility 74:17, 80:6, 109:16,
Originator 234:13, 98:24, 99:10, 252:21 part 21:2, 39:17, 270:10, 274:2, 196:7, 298:19 75:7 110:16, 299:13
236:16, 238:4, 102:2, 102:6, Painful 227:20, 114:2, 115:5, 274:6, 276:4, points 150:8 possible 30:9, President/founder
238:6, 238:9, 108:19, 109:13, 227:21 126:10, 126:16, 276:8, 279:16, Police 22:3, 28:22, 74:21, 94:3, 21:5, 296:15,
277:4 110:15, 115:11, Palatine 131:5, 152:20, 157:17, 279:20, 288:4, 44:1, 44:2, 44:16, 185:7, 200:3, 297:20
others 12:11, 13:15, 115:12, 120:3, 142:16, 145:8, 159:3, 180:6, 288:8, 290:16, 44:24, 45:4, 67:1, 211:22, 212:2, press 145:15
14:21, 15:17, 121:10, 134:24, 145:16, 145:20, 180:10, 181:10, 290:20, 296:20, 67:3, 70:12, 225:18, 233:23, Preto 302:14
24:12, 24:21, 135:9, 135:19, 146:1, 151:19, 184:5, 186:4, 297:1, 299:7, 105:24, 106:6, 243:1, 251:9, pretty 118:24
24:24, 68:22, 136:6, 137:11, 151:24, 202:15 253:2 299:11, 300:19, 106:7, 106:10, 261:3, 271:21, previous 59:9, 59:10
152:15, 257:9, 137:23, 139:22, pants 130:21 partial 201:9 301:1, 301:18, 108:7, 108:8, 297:16 previously 150:2,
300:18 141:17, 154:13, Papadakis 2:27, partially 252:24 301:20, 313:12 108:15, 109:8, possibly 38:23, 161:20, 247:22
Otherwise 114:8, 155:12, 156:3, 148:40 participation 41:15, planning 255:19 110:10, 110:12, 212:5 primarily 9:14
124:11 159:17, 159:22, paper 36:23, 40:15, 41:16 play 124:2 120:21, 121:6, post 229:16 print 173:22
outcome 314:4 160:7, 160:17, 40:18, 40:21, particular 12:12, Please 6:7, 7:19, 121:12, 123:22, posted 152:20, Printed 154:12,
outside 28:17, 161:5, 162:19, 40:22, 41:7, 41:8, 119:8, 144:16, 17:10, 17:13, 124:5, 143:3, 152:21, 266:19, 173:1, 173:3,
35:20, 35:21, 165:6, 166:12, 76:18, 229:8 178:6, 179:1, 127:19, 204:1, 143:5, 145:21, 267:16, 272:1, 173:4, 198:1,
35:23, 40:11, 167:1, 167:5, paperwork 51:14, 179:3, 180:3, 228:20, 267:7, 146:2, 151:21, 272:11, 274:22, 248:15, 276:18
42:21, 43:24, 171:1, 172:16, 66:5, 250:17 180:7, 180:11 268:20, 284:6, 161:7, 165:20, 274:24, 287:15 printout 165:11,
44:19, 44:20, 173:20, 174:3, paragraph 99:1, particularly 205:24 305:8 172:22, 187:9, posting 202:4 172:17, 178:22,
44:21, 45:1, 174:17, 179:13, 110:15, 111:19, parties 34:24, 259:3, PODLASEK 1:11, 187:14, 187:20, postings 277:12 179:7, 210:16,
45:10, 46:16, 180:2, 180:22, 115:13, 131:12, 306:15, 314:2 27:6, 27:8, 29:14, 201:20, 202:3, postponed 255:20, 233:6, 233:7
126:19, 131:17, 181:7, 181:9, 132:21, 141:7, party 10:11, 28:20, 35:3, 35:6, 35:20, 202:9, 202:20, 255:22, 281:24, printouts 138:5,
173:7, 231:7, 181:21, 182:14, 219:16, 222:19, 203:10, 215:3, 37:10, 38:10, 209:13, 210:4, 286:4 138:6, 208:16
250:10 182:21, 183:7, 236:13, 266:24, 219:19 38:18, 39:12, 211:1, 211:16, potential 13:18 Prior 9:7, 9:10,
outsiders 302:11 186:5, 186:12, 267:5, 267:6, pass 57:21, 298:11 39:18, 40:11, 212:24, 213:5, potentially 12:24 20:23, 26:5, 52:6,
outskirts 38:21, 194:4, 194:5, 271:18, 277:1, Passed 37:15, 41:17, 41:21, 214:11, 214:18, Pratt 227:8 59:18, 67:10,
38:22 195:23, 197:21, 289:11 37:18, 37:20, 148:11, 153:15, 214:22, 215:2, prepare 56:15, 94:2, 105:13,
overview91:9, 92:9 211:22, 214:7, Pardon 77:2, 156:24, 63:10, 302:1, 197:13, 199:5, 216:24, 217:4, 253:18, 280:15 116:24, 138:11,
own 41:11, 41:12, 232:8, 232:9, 176:10, 195:17, 303:8, 303:12 199:16, 229:6, 217:8, 220:10, prepared 191:7, 138:20, 152:22,
45:24, 46:1, 66:5, 232:10, 232:12, 244:20 passing 22:2 229:20, 251:6, 225:5, 229:8, 197:3, 198:9, 177:17, 237:3,
119:2, 151:11, 237:15, 238:12, Park 2:34, 6:20, passport 147:9 255:5, 257:21, 237:10, 240:20, 251:24, 252:7, 238:17, 240:15,
185:9, 185:11, 242:17, 243:13, 44:2, 44:16, 45:4, password 88:15, 258:22, 260:24, 249:2, 249:9, 252:11, 252:15, 242:3, 244:10,
186:16, 188:13, 243:22, 243:23, 105:23, 106:6, 88:23, 89:1, 261:13, 263:3, 249:11, 249:13, 280:19 256:11, 276:23,
189:17, 205:3, 244:17, 244:22, 108:8, 108:15, 134:11, 193:2, 271:8, 274:10, 260:9, 260:13, preparing 10:6, 277:2, 281:3,
350 352
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 90 of 93 PageID #:2078
2018
294:13, 310:23 129:12, 162:7 266:19 258:23 218:16, 230:10, 132:17, 139:3, 73:13, 75:13, 297:15, 307:6,
Pro 229:11, 229:12, project 40:15, 40:17, public 1:20, 23:19, question 8:3, 8:7, 240:8, 248:4, 150:10, 150:15, 75:17, 75:21, 308:3
230:2, 234:12, 65:24, 71:1 47:19, 70:14, 8:12, 8:13, 18:3, 248:6, 260:12, 151:1, 153:16, 76:7, 77:18, 78:5, removed 41:16, 63:3
260:7 projects 58:8, 59:17 177:5, 220:12, 31:13, 48:12, 269:1, 282:6, 162:2, 164:2, 79:23, 80:3, 80:8, repairs 225:21,
Probably 10:15, prominent 302:5 287:5, 313:5 48:16, 74:8, 289:15, 291:19, 188:22, 195:24, 82:8, 83:22, 84:7, 238:19
67:20, 72:15, promotional 296:7, published 279:10 92:22, 96:5, 96:8, 293:15, 299:2, 196:16, 196:20, 86:10, 86:12, repeat 54:15, 60:3,
108:13, 215:16, 300:13, 300:17 pulled 36:22, 112:2, 96:11, 96:13, 299:16, 311:11 211:1, 220:17, 87:7, 89:15, 86:18, 203:24,
281:4, 286:6, pronounce 27:4, 112:22, 114:23 133:23, 137:4, refers 176:23 221:24, 224:15, 95:20, 96:18, 282:3
286:7, 298:7 36:14 purchased 212:15, 139:3, 139:5, refigure 59:14 226:5, 233:11, 102:21, 103:10, repercussions
problem39:4, 151:9, proof 28:4, 294:5 212:16 143:15, 146:3, reflect 54:8 243:10, 243:15, 103:11, 105:19, 144:23, 145:17
166:17, 168:2, property 18:11, purchases 219:20 178:19, 186:8, reflected 196:22 249:18, 253:8, 106:11, 107:6, replaced 52:9, 52:11
168:17, 168:19, 150:21, 150:24 purpose 46:7, 58:10, 188:6, 196:3, reflects 196:24 256:11, 260:10, 109:12, 118:6, Report 47:17, 90:11,
168:24, 169:1, prosecute 155:5 123:3, 191:19, 203:24, 205:14, refresh 160:8, 163:1, 266:7, 271:13, 127:5, 127:6, 97:8, 97:15,
170:19 prosecuted 285:9, 194:1, 194:7, 207:2, 208:3, 307:20 288:16, 314:2 127:20, 131:18, 97:18, 99:22,
problems 36:8, 285:21, 312:1 197:9, 215:17, 211:21, 237:17, refused 54:19 relates 211:21 132:8, 132:20, 108:7, 110:12,
36:20, 37:24, prosecuting 122:8, 250:7, 252:1 237:22, 250:2, regarding 108:16, relating 161:7, 133:23, 143:2, 115:13, 117:6,
39:10, 53:11, 123:5, 271:19 pursuant 1:16, 273:22, 273:24, 166:8, 278:11, 161:11 143:3, 143:7, 117:9, 143:4,
53:13, 53:14, prosecution 156:20, 148:22 274:1, 276:19, 305:11, 305:21, relation 61:4, 155:24 143:18, 153:21, 143:5, 144:14,
53:16, 105:15, 285:17, 286:11 pursuing 20:3, 278:7, 282:3, 306:12, 307:9 relationship 53:22, 157:8, 157:9, 144:16, 144:23,
111:3, 111:7, prosecutor 35:7, 286:12 282:4, 293:9, register 45:13 54:1, 105:3, 158:3, 158:4, 145:4, 183:17,
111:15, 111:17, 122:1, 122:3, put 12:18, 22:1, 293:16, 294:11, registered 54:21, 182:12, 256:21, 158:9, 158:20, 192:23, 202:3,
114:5, 145:10, 122:10, 124:8, 30:24, 36:10, 295:17, 298:1, 54:22, 296:9, 278:12 159:7, 160:3, 211:1, 211:16,
145:12, 146:6, 124:10, 128:23, 38:23, 46:8, 302:20, 302:22, 296:16, 296:18, released 40:19 160:10, 160:12, 214:18, 214:23,
155:1, 169:7, 153:20, 155:1, 64:20, 69:13, 303:2 298:5, 304:4, relentless 218:10, 160:15, 161:20, 215:2, 216:24,
200:21, 235:2, 155:5, 312:5 72:11, 113:9, questionable 95:22, 304:18 218:15 161:23, 162:17, 217:5, 217:8,
241:23, 272:2 prosecutors 123:8, 117:10, 130:21, 96:15 regret 284:23 relevance 292:4 163:15, 163:17, 228:11, 229:8,
problems. 110:19 129:1 151:24, 184:1, questioned 278:5 regular 229:24 relevant 14:3, 101:2, 163:18, 164:10, 237:10, 249:2,
Procedure 1:17, protect 40:23, 184:2 194:14, 197:7, questions 7:12, 8:6, regularly 150:17 180:12, 182:21 167:16, 167:23, 249:11, 250:21,
264:17 protection 230:16, 197:16, 198:12, 12:24, 14:6, regulations 117:5 relieved 202:7, 168:11, 169:13, 260:9, 260:13,
procedures 93:21 268:5, 269:9 198:19, 206:19, 14:14, 34:23, reimburse 176:17, 202:14 176:3, 179:9, 260:14, 264:15,
proceed 123:13 protested 229:9 207:14, 207:17, 64:2, 79:24, 219:18, 220:20, relinquish 58:19 187:11, 202:17, 268:4, 268:15,
proceeding 215:8 proud 71:16 218:21, 230:9, 84:13, 174:24, 220:21, 220:23, remainder 135:8 203:8, 211:15, 268:16, 289:14,
proceedings 62:10, prove 268:15, 294:8 230:21, 238:22, 192:2, 211:4, 221:18 remained 57:11 212:6, 212:9, 299:19, 307:21,
65:3, 223:1, proven 214:15 239:18, 243:19, 215:19, 270:1, reimbursed 107:5, remark 85:8 212:10, 212:11, 308:14
274:17, 280:5 provide 93:24, 247:7, 247:10, 303:22, 303:24, 175:19, 175:22, remarried 18:24, 212:13, 213:4, reported 220:10,
process 57:5, 57:14 100:3, 120:15, 248:8, 253:19, 310:16, 310:18, 223:18, 253:1, 19:1 214:19, 216:7, 292:7, 294:9
produced 34:21 161:8, 165:19, 257:6, 271:2, 312:9 253:3 remember 11:14, 220:22, 221:15, REPORTER 7:9,
professionals 23:19 178:6, 178:21, 285:5, 285:23, quick 101:19, reissued 237:8, 15:19, 18:19, 224:2, 224:4, 17:9, 38:2, 231:5,
professor 202:3, 179:1, 246:13 286:12, 286:20, 303:24, 306:18, 240:18, 247:2 19:2, 22:22, 224:21, 225:9, 277:21, 278:20,
202:5 provided 91:9, 92:9, 295:9 310:3 relate 34:20, 181:24, 26:22, 34:11, 235:11, 241:12, 278:24, 279:6,
program17:19, 120:14, 120:20, putting 197:9 quickly 308:16 196:13, 221:13, 34:14, 34:15, 241:13, 248:23, 292:1, 294:5
97:24, 263:15, 120:23, 121:1, quit 63:19 223:23 39:16, 41:19, 249:15, 259:22, reporting 144:18,
263:19 172:22, 178:1, quite 53:19, 64:21, Related 17:20, 44:21, 49:1, 263:6, 264:8, 146:13
programs 70:11 236:16 <Q> 293:8, 311:20 35:21, 38:13, 57:16, 57:24, 274:13, 276:3, reports 161:7,
progress 126:2, provider 134:8 quality 95:9, 95:13, Quote 236:9, 236:14, 40:15, 46:16, 58:1, 58:5, 58:10, 278:10, 278:22, 161:10, 229:15,
127:2, 127:4, providing 13:11 95:21, 96:14 238:12, 291:11, 51:8, 51:14, 57:3, 59:20, 61:8, 61:9, 279:23, 280:3, 240:21, 249:9,
127:18, 129:5, ps- 180:4 quarterly 264:20 301:22 90:23, 100:17, 63:5, 63:6, 67:17, 280:24, 281:8, 249:13, 264:20,
129:6, 129:9, psychopath 266:16, quashed 258:1, quoted 94:6, 238:20, 106:21, 120:19, 67:21, 68:24, 281:10, 282:24, 290:11, 292:21,
353 355

239:9 211:5, 269:4, 224:14, 226:5, 224:11 293:2, 293:7, 290:7 192:21 56:4, 56:10,
270:18, 270:19, 230:24, 233:17, recovered 70:2, 293:10, 293:12, responded 112:3, Richard 2:17, 49:19, 56:15, 57:5,
307:6, 310:7, 243:16, 256:10, 72:8, 72:9, 73:1, 293:17, 293:24, 246:5, 259:4 49:21, 121:7, 58:14, 58:21,
<R> 312:1 264:14, 291:11, 115:14, 115:19, 294:1, 294:14, responding 132:24, 121:13, 122:20, 58:23, 59:11,
R. 3:5, 149:5, 263:8 reason 8:19, 13:9, 304:16 207:12, 220:15, 294:18, 294:22, 192:7 123:4, 123:21, 63:19, 111:8,
R/O 109:15 14:19, 25:17, receiving 97:19, 224:3, 224:4, 295:15, 295:19, response 141:12, 124:3, 124:14, 116:9, 116:12,
ran 85:17 59:7, 61:13, 63:7, 113:6, 250:9 224:5 295:22 155:15, 171:7, 124:19, 128:20, 117:3, 117:11,
Randolph 3:8 78:11, 90:19, recess 73:19, recovery 73:3, 92:1, represent 6:14, 183:20, 185:2, 129:5, 129:21, 120:22, 125:18,
Randy 50:2, 50:3, 144:7, 159:5, 147:17, 148:22, 93:21, 93:24, 161:14, 300:9 185:17, 185:18, 130:11, 130:19, 144:21, 148:11,
50:7, 50:9, 50:12, 219:10, 261:5, 191:15, 232:2 95:8, 95:13, representation 193:1, 238:11, 135:4, 135:14, 162:3, 162:5,
155:19, 157:11, 279:24, 283:19, recipient 185:24, 95:18, 95:22, 162:2 243:24, 276:16, 136:10, 137:7, 162:13, 175:5,
157:14, 158:10, 285:6 192:10 96:15, 98:12, represented 9:3, 276:17 137:17, 137:21, 175:6, 175:9,
158:13, 218:2, reasons 87:13 recipients 182:6, 100:17, 150:10, 295:24, 296:8 responsible 27:24, 137:24, 138:16, 175:10, 175:14,
218:16, 219:8 reboot 66:3 258:4 206:21 reputable 302:12 30:18, 34:19, 143:9, 144:1, 175:22, 175:24,
rather 129:20 rebooted 98:3 recognize 136:3, rectify 59:8, 151:10 reputation 152:19 142:8, 295:3 151:16, 153:4, 176:17, 176:24,
raw180:5, 181:23 recall 48:7, 49:2, 136:4, 164:19, red 146:23 request 8:13, rest 138:4, 186:18, 153:7, 153:22, 190:21, 199:5,
RE 166:14 76:4, 76:8, 77:6, 189:23, 235:20, redaction 261:1, 155:10, 161:10, 223:18 154:16, 154:17, 203:1, 203:6,
re-entered 65:4 86:6, 91:14, 265:11, 265:13, 261:2 220:23, 222:17, restate 31:13 154:19, 155:14, 212:23, 220:16,
reach 47:1, 47:2, 91:15, 91:17, 265:16, 265:18, redid 88:18 242:23, 256:9, result 25:7, 25:11, 155:15, 156:2, 221:2, 221:9,
47:13, 129:2 105:6, 109:5, 265:22, 266:3, reduced 244:12, 257:22, 264:20, 69:10, 223:8, 156:6, 156:11, 221:16, 221:24,
reached 47:3, 128:5, 109:10, 109:18, 279:22, 309:22 313:21 289:15, 289:20 281:17, 282:4, 157:1, 157:21, 226:2, 252:21,
128:9, 128:12, 118:11, 119:3, recognized 209:22 reentered 99:17, requested 56:6, 282:7 158:21, 159:6, 255:5, 258:21,
128:17, 287:20, 131:11, 133:16, recollect 225:9 223:2, 280:6 199:17, 199:19, resulting 223:5 163:2, 163:7, 260:24, 274:10,
311:14, 311:21 138:19, 142:1, recollection 43:12, refer 9:21, 9:24, 199:21, 221:1 resumed 148:21 163:14, 217:22 288:11, 288:15,
Read 94:7, 104:21, 164:1, 199:19, 57:17, 160:9, 24:10, 34:12, requesting 255:7, retained 71:14, 72:2 Rickert 47:11 288:19, 289:19,
114:21, 145:6, 226:7, 243:21 163:1, 190:13, 99:4, 102:9, 289:24 retaliation 133:22 right- 67:11 291:6, 308:7,
161:4, 167:7, receipt 194:6 307:21 126:21, 198:5, require 308:8 retention 71:15 rights 14:6 313:12
183:10, 184:11, receipts 194:8 record 6:8, 12:18, 293:1, 300:6 rescheduled 282:1, retired 20:17, 20:18, ring 109:4 Roberts 50:2, 50:3,
193:10, 195:18, receive 134:15, 13:18, 18:4, reference 92:13, 282:22, 283:19 21:9 ringing. 182:24 50:7, 50:9, 50:13,
196:19, 198:4, 173:5 73:18, 113:16, 180:7, 198:7 Research 29:2, retirement 20:23 risk 115:24, 116:4, 155:19, 157:11,
198:9, 240:10, received 18:14, 147:15, 174:2, referenced 17:20, 29:10, 29:18 retrieve 134:11 147:2, 147:8, 157:14, 157:23,
271:19 20:11, 45:16, 186:15, 191:14, 37:12, 179:11 researching 29:7, retrieved 72:16, 307:11 158:10, 158:13,
Reader 230:21 54:22, 56:7, 191:17, 191:23, referencing 155:21 161:18 286:16, 286:21, Rita 32:8, 131:1, 158:15, 218:2,
reading 92:3, 56:14, 61:6, 191:24, 194:2, referral 270:16, reserve 14:5 301:5 131:4, 145:11, 218:11, 218:17,
113:17, 127:6, 82:14, 82:22, 220:12, 231:20, 271:9 reset 59:15, 237:4, reverse 85:2, 152:16, 259:21, 219:3, 219:8,
147:10, 166:19, 83:3, 85:1, 90:1, 290:22, 297:4, Referred 74:24, 240:15 109:15, 154:12, 260:2, 311:19 219:11
181:7, 195:22, 90:16, 97:15, 299:15 84:12, 184:11, resetting 243:5 159:14 RN297:23, 298:5, Rodriguez 59:12,
237:14, 249:8, 114:4, 132:23, recorded 313:20 197:6, 291:23 Residents 32:2 review9:10, 9:13, 299:4, 299:14, 63:17, 169:15,
277:1 133:4, 133:8, records 111:24, referring 9:22, 24:11, resolve 67:24, 68:4 9:16, 57:3, 97:18, 300:2 169:18, 170:3,
real 291:7, 306:18, 133:11, 133:20, 112:9, 112:16, 24:15, 34:12, respect 98:20, 110:2, 110:4, ROBERT 1:11, 6:11, 170:10, 221:6,
308:16, 310:2 141:10, 156:2, 113:5, 158:19, 37:3, 43:11, 44:9, 107:11, 117:20, 217:8, 253:20, 11:9, 11:11, 24:18, 221:11, 221:12,
really 18:19, 29:15, 173:15, 174:18, 286:17, 286:22, 76:4, 76:14, 123:23, 131:20, 298:12, 302:6, 35:3, 38:10, 52:4, 224:9
61:7, 68:23, 95:3, 181:3, 181:4, 292:10, 292:14, 82:16, 167:19, 218:16 302:16 52:5, 52:10, role 21:3, 52:8, 67:6
95:24, 117:2, 185:16, 186:3, 292:17 170:12, 173:16, respond 61:17, review. 155:20 52:11, 52:12, Rolling 79:1, 79:3,
117:10, 119:11, 186:9, 198:12, recover 68:11, 174:3, 179:3, 61:23, 61:24, reviewed 109:18, 52:14, 52:23, 79:6, 79:14, 79:16
122:21, 143:17, 200:15, 215:3, 70:22, 84:4, 179:6, 180:7, 168:12, 239:21, 217:4, 217:13 54:3, 54:10, Room2:19, 73:14,
156:4, 164:7, 215:21, 215:22, 84:10, 92:11, 184:8, 184:9, 257:21, 258:8, reviewing 109:19, 54:18, 54:20, 98:3, 103:21,
167:23, 168:11, 219:20, 223:13, 219:22, 220:3, 194:17, 195:24, 259:4, 290:4, 113:16, 183:13, 55:17, 55:20, 105:10, 118:14,
354 356
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 91 of 93 PageID #:2079
2018
118:16, 191:10, 226:2 104:23, 105:3, 98:12, 98:20, 222:2, 236:13, 86:16, 90:12, 139:4, 142:13, 221:17, 223:17
204:7, 204:13, salary 224:8, 252:24, 105:7, 131:15, 100:17, 104:18, 244:17, 267:5, 90:20, 91:12, 145:5, 170:16, several 24:4, 39:6,
302:15 253:2, 253:3, 131:20, 132:16, 106:8, 106:12, 277:1, 281:21, 102:22, 102:24, 198:4, 238:20 45:9, 45:12,
room. 62:11, 65:4, 254:17 133:13, 139:16, 107:13, 107:16, 282:2, 289:5, 104:2, 104:14, sentences 170:17 45:22, 61:23,
94:23, 99:17, Salerno 66:14, 140:18, 164:22, 108:16, 108:22, 297:15, 297:21, 112:2, 112:23, separate 15:13, 132:22, 134:13,
215:9, 274:18, 66:16, 67:22, 165:23, 166:2, 110:7, 110:16, 298:20, 299:2, 115:7, 125:17, 36:24, 37:13, 215:20, 216:16,
280:6 68:21, 81:24, 173:12, 173:13, 113:23, 117:21, 299:4, 299:21, 125:21, 130:11, 255:22 256:11
roommate 31:17 83:2, 84:3, 85:5, 173:23, 174:19, 118:4, 118:21, 301:19, 301:20 133:1, 133:13, separation 99:2 Shahna 216:21
Roosevelt 202:16 85:6, 85:12, 91:1, 174:23, 178:8, 120:19, 121:5, seconds 191:9 133:20, 133:21, series 235:23, Shaking 7:13, 86:13,
root 183:21, 193:2 97:11, 98:9, 98:10, 179:14, 181:4, 121:11, 124:15, secure 124:8, 135:4, 135:13, 237:19, 242:12 283:20
roped 205:13 105:7, 105:20, 182:20, 184:4, 126:16, 127:9, 131:17, 219:20 136:8, 137:7, serious 222:20 Shakman 2:4,
ROTC 67:13 106:3, 125:17, 184:6, 184:11, 129:24, 131:7, seeing 187:7, 283:15 137:17, 137:21, served 257:19 148:26
roughly 19:12, 126:3, 133:1, 185:19, 186:3, 134:1, 135:10, seek 221:23 139:19, 141:13, server 68:1, 93:1, shall 260:13
283:24 165:15, 166:12, 187:11, 188:13, 135:13, 135:15, seeking 162:1, 143:6, 143:8, 95:9, 95:14, shape 304:17
routine 257:14 167:10, 171:7, 188:19, 189:7, 135:19, 136:9, 269:17 153:5, 153:8, 99:15, 111:22, sharing 260:2
RPR 1:19, 314:12 171:10, 171:18, 189:13, 192:5, 146:4, 150:10, seem66:6 153:13, 153:14, 111:23, 112:7, sheet 55:15, 135:1,
Rubino 49:15, 49:17 207:19, 234:19 193:17, 197:24, 150:16, 152:11, seemed 43:24, 153:24, 154:18, 112:8, 113:11, 135:3, 137:5,
ruined 231:19 SALF 10:1, 73:4, 198:9, 198:17, 156:17, 158:17, 67:18, 194:12, 155:15, 166:5, 114:14, 151:9, 138:5, 138:7,
ruled 282:16, 282:18 99:3, 99:4, 99:14, 201:12 158:23, 165:18, 247:16, 294:8 173:6, 173:13, 181:4, 198:3, 154:14, 302:7,
Rules 1:16, 7:6, 99:23, 100:4, satisfied 54:7, 168:9, 170:23, seen 108:4, 108:6, 173:23, 174:14, 201:2, 204:24, 302:16
146:21 100:7, 101:4, 54:12, 141:11 172:18, 172:23, 150:19, 184:24, 175:1, 177:8, 205:1, 205:13 sheets 137:14
run 190:3, 301:24, 111:22, 115:13, Save 9:22, 10:1, 176:4, 182:1, 200:9, 205:22, 177:20, 179:20, server. 102:8 Sheriff 36:19, 39:5
302:3, 302:7, 134:10, 198:3, 11:19, 21:2, 21:3, 182:9, 187:12, 211:13, 222:14, 181:5, 182:8, Server2vipgeek.co Shirley 3:5, 6:23,
302:16, 303:12 222:20, 223:6, 21:7, 21:24, 22:8, 189:3, 192:24, 225:8, 226:10 184:6, 185:2, m181:11 149:5
running 69:3, 234:10, 236:14, 23:16, 23:17, 200:12, 203:1, sell 170:18 187:16, 199:5, servers 44:11, 64:7, shocked 117:3,
124:12, 190:14 237:2, 237:11, 23:20, 23:24, 203:9, 203:10, Senario 16:9, 19:16, 199:23, 200:14, 64:9, 64:21, 133:19
237:13, 240:13, 24:2, 25:2, 25:17, 203:17, 204:3, 19:22, 20:3, 20:10 206:11, 207:7, 64:24, 65:14, Shontay 165:2,
244:14, 253:24, 32:16, 36:24, 204:9, 204:16, Senator 38:4, 38:24, 208:7, 208:19, 69:22, 73:24, 165:3, 165:4,
<S > 277:3, 277:12, 44:10, 51:15, 205:11, 209:14, 39:24 220:14, 243:20, 74:15, 93:2, 93:9, 165:5, 165:8
S. 2:26, 148:39 289:13, 299:24, 52:21, 53:23, 209:18, 210:21, senators 130:21 250:12, 250:22, 94:8, 94:16, shop 39:19, 39:22,
Sabotage 190:22, 305:5, 305:16, 54:13, 54:16, 211:18, 213:2, send 56:13, 138:10, 252:12, 252:14, 98:15, 98:21, 40:9
191:3, 214:14, 307:4 55:17, 56:14, 216:9, 219:5, 138:16, 154:22, 253:21, 255:5, 99:14, 99:20, short 118:24
232:5 SALF. 92:13, 131:3 57:4, 57:6, 58:2, 219:12, 223:7, 161:11, 199:15, 258:13, 259:5, 99:23, 100:4, shortly 45:3, 153:13
Safe 22:17, 22:24, Salf.org 183:20, 58:9, 59:15, 224:5, 224:10, 200:1, 242:23, 259:10, 260:23, 100:8, 100:18, shouldn't 209:23,
23:2, 23:6, 23:11, 193:1 59:19, 59:24, 225:6, 225:12, 250:3, 250:14, 261:3, 265:6, 101:4, 104:19, 276:1
23:22, 23:23, Sam6:9 60:10, 60:12, 225:21, 226:5, 251:3, 251:6, 265:23, 266:2, 112:17, 115:18, show115:16,
24:22, 27:11, San 31:20, 32:2, 61:1, 61:2, 62:13, 228:14, 232:24, 261:13 266:20, 270:12, 181:20, 204:4, 134:16, 155:7,
46:16, 64:3, 230:21, 270:22 62:18, 62:19, 233:24, 246:15, sender 77:8 270:20, 272:20, 204:10, 204:16, 206:9, 206:11,
150:18, 168:20, Sass 66:1, 66:13, 63:2, 63:18, 252:1, 253:1, sending 131:10, 274:13, 276:20, 206:3, 305:5 207:2, 207:5,
175:10, 275:21, 83:1, 83:18, 63:24, 64:6, 64:8, 277:9, 287:8, 138:12, 138:20, 282:15, 287:24, service 234:10, 242:5, 258:16,
275:22, 275:23, 84:13, 85:17, 67:6, 67:15, 289:16, 290:1, 155:8, 186:15, 288:14, 289:2, 236:9, 236:21 259:23, 293:14
276:2, 292:10, 85:21, 86:1, 86:7, 67:24, 68:11, 291:9, 292:14, 199:8, 250:7, 291:5, 291:15 services 71:21 showed 281:24,
292:22, 299:24 86:9, 86:14, 69:14, 71:17, 295:23, 296:7, 256:15, 257:8, sentence 102:5, set 163:11, 181:16, 294:2, 294:5
safety 41:13 86:21, 87:9, 71:21, 73:23, 299:18, 300:14, 266:6, 274:13 114:6, 114:13, 314:5 showing 125:7,
sake 7:9, 293:2 87:17, 87:24, 74:15, 80:2, 80:6, 301:4, 301:8, sent 9:18, 9:20, 115:5, 115:15, sets 93:23 186:15, 199:2,
salaried 254:14 89:13, 97:23, 81:13, 81:22, 301:21, 304:15 54:21, 56:9, 115:22, 120:2, setting 35:20, 42:21, 222:9, 225:2,
salaries 224:1, 98:6, 102:9, 82:10, 82:19, saved 22:1, 302:9, 76:16, 77:7, 120:5, 130:23, 46:16 246:18
224:3, 224:12, 103:1, 104:10, 89:4, 97:22, 302:18 82:23, 83:4, 131:13, 134:6, settled 12:12, 15:1, shown 214:15
357 359

saving 70:16, 71:7 297:23, 299:4, 14:13, 17:12, 203:22, 208:2, shows 113:12, skills 23:20, 70:16, 153:16, 165:18, 311:13
saw32:15, 41:24, 299:13, 299:24, 17:14, 18:7, 31:2, 211:10, 215:10, 172:24, 173:21, 71:14 174:12, 178:18, sorts 9:16, 230:23,
50:5, 51:5, 51:13, 301:20 34:18, 34:22, 217:18, 222:8, 183:7 slept 72:13 183:23, 187:12, 259:9
52:16, 83:9, scalloway@atg.stat 40:6, 40:7, 48:14, 223:3, 225:1, shut 252:8 slightly 96:11 189:2, 193:4, sought 220:16
83:17, 85:4, e.il.us 3:11, 149:8 48:18, 48:19, 231:22, 231:24, side 66:19, 136:19, small 36:8 197:4, 214:4, sound 49:22
103:21, 109:23, scantron 70:7, 70:8, 51:12, 56:3, 232:3, 234:5, 146:16, 161:14 Smith 214:2 215:24, 229:12, source 305:6
129:23, 226:4, 70:24, 71:1, 71:2, 56:19, 60:5, 234:23, 235:17, sided 177:11 smtp 181:4 243:20, 244:1, sources 36:7, 173:7,
247:9, 248:13, 71:18, 71:23, 60:18, 60:23, 238:7, 239:8, sides 191:22 snail 134:10 244:3, 274:9, 250:10
301:10, 309:15 71:24, 72:1, 62:12, 62:17, 242:11, 245:5, sign 79:9, 79:16, so. 244:4 289:3, 289:8, speaking 58:6,
Saying 37:23, 45:17, 80:22, 93:5 65:9, 68:9, 73:15, 245:11, 245:15, 93:7, 120:7, 120:9 social 34:19 291:8 86:14, 137:16,
50:4, 56:10, scared 231:7 73:20, 77:5, 245:20, 245:22, signature 109:2, socialized 35:19 Somewhere 18:20, 160:21, 311:4
113:5, 113:9, scenario 99:1 77:11, 81:20, 249:21, 250:1, 297:17, 298:16, sold 269:19 19:1, 52:20, 228:5 Spears 214:4
127:3, 152:16, schedule 45:15, 83:13, 87:4, 255:1, 260:19, 298:19, 298:21 sole 58:10, 59:7 Sony 69:23, 70:1, specific 13:6,
169:17, 170:9, 162:23 90:10, 92:23, 265:1, 265:12, signed 57:10, 79:8, solely 113:3, 117:2, 70:7, 70:10, 236:17, 305:3
177:13, 198:8, scheduled 163:24, 93:8, 94:13, 95:6, 265:17, 265:21, 79:12, 79:18, 305:20 70:11, 70:19, specifically 27:3,
207:22, 210:9, 175:7 96:10, 97:4, 99:9, 270:9, 273:12, 120:8, 183:11, Solutions 75:4, 75:7, 93:1, 93:4, 93:10, 75:20, 207:1,
219:7, 222:15, Schiller 2:34, 6:20, 99:18, 100:14, 274:5, 274:19, 297:19, 298:4, 75:12, 75:15, 93:21, 115:17, 213:10, 220:8
228:5, 235:11, 44:2, 44:16, 45:4, 101:8, 101:20, 276:7, 276:11, 298:12, 298:14 75:19, 76:13, 115:19 specifics 306:9
261:10, 266:13, 105:23, 106:6, 101:22, 104:8, 277:19, 278:18, signed. 120:4 76:22, 77:14, soon 183:16, speculate 98:16,
266:14, 266:16, 108:8, 108:15, 104:22, 106:19, 279:9, 279:19, significant 223:5 78:6, 78:10, 192:22, 272:18 164:12
268:1, 268:13 108:21, 110:10, 106:24, 107:7, 280:7, 283:5, significantly 244:12 80:14, 82:1, 88:8, sooner 146:14 speculated 96:2
Says 92:8, 93:18, 120:21, 121:1, 108:1, 115:10, 283:10, 285:7, similar 166:17, 88:11, 90:4, Sorry 16:8, 17:11, speculating 103:3,
99:11, 100:1, 121:6, 121:12, 121:16, 123:2, 288:7, 290:19, 169:9, 169:11, 90:12, 90:23, 18:8, 18:23, 21:1, 309:18
102:6, 103:5, 123:22, 124:2, 125:6, 125:10, 291:3, 295:18, 169:18, 170:3, 91:4, 91:10, 92:1, 26:12, 31:8, speculation 55:23,
109:14, 115:12, 124:5, 128:8, 125:15, 129:13, 296:23, 297:8, 170:8, 170:19 92:10, 104:1, 31:12, 33:17, 56:17, 68:6,
115:23, 120:3, 145:19, 146:3, 130:6, 132:1, 298:21, 299:1, Similarly 30:4, 30:14 106:3, 120:13 48:13, 48:24, 81:17, 94:11, 99:6,
127:2, 135:10, 148:43, 165:20, 133:15, 134:22, 299:10, 300:24, Simple 302:9, Somebody 11:11, 58:15, 68:8, 100:10, 113:4,
135:19, 136:17, 172:22, 187:8, 136:1, 136:20, 303:1, 303:6, 302:18 27:18, 65:6, 66:9, 74:22, 74:23, 131:22, 140:23,
137:9, 138:7, 187:13, 187:19, 137:1, 140:8, 303:17, 303:22, simplicity 293:2 75:6, 78:23, 76:17, 77:12, 142:10, 164:4,
141:19, 146:7, 201:20, 202:19, 140:15, 141:1, 312:11 simply 133:23, 87:23, 88:1, 89:8, 82:17, 85:10, 167:14, 167:22,
160:6, 160:17, 209:13, 210:4, 143:19, 147:12, Science 300:7, 294:11 103:5, 107:3, 93:16, 107:20, 169:3, 180:14,
161:5, 170:8, 212:24, 213:5, 147:15, 148:25, 300:11 single 273:8, 302:2, 151:6, 161:13, 109:1, 113:20, 183:9, 234:4
173:8, 175:2, 214:11, 217:4, 150:6, 154:8, se 229:11, 229:12, 303:3, 303:8 161:15, 185:13, 114:18, 125:4, spent 10:6, 10:8,
175:3, 179:23, 218:11, 225:5, 158:8, 159:11, 230:2 sir 306:7, 306:16, 205:22, 280:1, 139:24, 140:3, 66:21, 126:15,
180:24, 181:11, 312:3 164:16, 166:23, se. 260:7 307:13, 310:4 311:23 159:7, 160:11, 196:15, 196:16,
183:11, 185:23, School 15:23, 16:2, 169:5, 171:4, searches 310:6 sisters 228:3 somehow 180:23, 161:22, 176:8, 218:20, 284:15
186:14, 186:21, 16:3, 16:15, 172:3, 172:11, searching 133:14 sit 72:6 232:24, 240:22 178:5, 183:3, SPIZZIRI 4:3
189:10, 192:18, 16:23, 17:1, 174:1, 174:6, second 93:15, site 139:7, 139:9 Someone 28:16, 184:1, 184:10, SPIZZIRRI 1:15,
194:6, 195:14, 21:11, 21:13, 176:9, 176:12, 98:24, 101:19, sites. 131:19 33:18, 34:13, 196:8, 205:20, 3:22, 6:2, 6:9,
196:10, 211:22, 21:16, 21:21, 176:16, 178:16, 108:19, 109:13, sitting 261:15 52:7, 75:3, 78:10, 208:12, 216:13, 6:18, 7:2, 13:4,
212:14, 214:10, 22:14 180:21, 183:1, 115:12, 120:3, situation 27:15, 81:24, 82:9, 223:24, 235:6, 13:23, 13:24,
222:19, 225:22, schooling 144:6 184:17, 188:1, 131:13, 134:23, 31:18, 38:5, 82:18, 86:16, 235:13, 241:12, 15:20, 25:21,
238:3, 238:8, schools 70:14, 189:21, 191:11, 141:6, 159:17, 58:23, 116:8, 101:12, 110:10, 244:24, 249:15, 73:21, 90:4,
239:5, 243:9, 70:15 191:14, 191:16, 159:22, 160:6, 147:7, 190:6, 112:22, 117:5, 263:6, 279:2, 101:24, 108:4,
244:13, 249:2, SCHWARTZ 2:3, 4:5, 193:9, 193:19, 160:17, 161:4, 305:10 122:7, 124:6, 280:4, 282:3, 109:17, 110:16,
249:9, 251:12, 4:8, 6:6, 6:14, 7:1, 193:23, 195:9, 173:24, 180:2, six 18:2, 67:8, 124:10, 128:24, 283:9, 283:22, 112:1, 114:3,
269:14, 271:19, 7:18, 13:3, 14:5, 196:5, 196:9, 186:19, 197:21, 286:16 133:21, 139:12, 284:3, 293:8, 115:23, 125:10,
278:17, 297:22, 14:8, 14:12, 199:1, 200:7, 211:22, 214:7, skill 93:23 143:22, 144:14, 305:12, 311:3, 125:16, 134:23,
358 360
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 92 of 93 PageID #:2080
2018
136:6, 137:3, 102:22, 103:1, 156:1, 197:12, 313:9 Terry 38:3 309:10, 309:18, Thursday 110:15 173:8, 186:5,
148:21, 149:16, 104:2, 104:14, 203:15, 207:4, Static 234:11, test 71:5, 71:11 310:5, 313:19, tickets 45:14, 210:1 186:13, 205:10,
150:1, 150:8, 141:10, 141:14, 218:13, 218:24, 236:10, 238:15, testified 6:4, 18:15, 313:23, 314:5 tied 233:20 228:4, 238:11,
164:20, 174:2, 175:2, 178:7, 219:6, 223:4, 241:9 19:15, 20:6, 30:5, text 43:7, 48:22, till 277:5 243:9
198:2, 198:3, 198:3, 244:12, 226:17, 230:18, stating 114:4 39:17, 40:14, 166:24, 167:2, timely 289:13 topic 159:4
211:13, 228:19, 300:5 231:14, 236:19, status 116:15, 42:6, 44:15, 167:6, 184:11 tip 48:18 total 10:21, 11:15,
232:4, 235:21, stakeholders 256:17 237:23, 250:4, 143:12, 147:3 44:18, 53:14, thanked 267:19 title 23:14, 190:20 195:14, 197:10,
238:13, 255:3, stalked 24:4, 26:21, 250:8, 250:15, stay 24:8, 54:20 56:4, 57:2, 60:6, theft 222:22 titled 195:12 223:4, 237:11
274:7, 297:10, 231:4, 270:21, 251:4, 252:11, stayed 72:12, 254:6 63:16, 63:21, themselves 6:13, today 6:17, 7:7, 7:9, totaled 194:7,
298:1, 299:15, 270:22, 272:23, 252:12, 253:16, staying 32:20, 32:21 67:22, 77:9, 80:9, 36:9, 72:2 8:10, 8:20, 9:1, 194:15
299:17, 300:2, 278:11, 285:4 253:21, 256:22, stealing 272:12 80:22, 81:8, 83:9, thereof 314:4 9:3, 9:8, 9:11, totally 69:23,
301:14, 301:23, stalking 271:14 266:10, 266:24, stenographically 86:20, 87:5, thief 272:20 9:24, 10:6, 20:15, 101:13, 129:23,
305:3, 313:7, stamped 90:5 272:19, 280:14, 313:20 105:8, 105:22, thinking 142:12, 32:14, 32:19, 132:12, 133:19,
313:16 stance 129:23 280:15, 280:18, step 160:1 107:15, 114:15, 228:24, 284:3 33:3, 33:8, 72:6, 214:11
Spoke 41:20, 48:4, standard 298:8 281:2, 281:3, Steve 291:17 120:8, 120:12, third 11:7, 28:20, 105:22, 108:5, touch 230:19
62:7, 87:23, standing 25:19 281:12, 282:11, Steven 291:9 127:21, 142:18, 115:12, 131:12, 125:24, 127:15, towards 197:22
109:15, 113:24, Start 15:22, 20:15, 286:2, 286:19, stick 210:19, 248:24 150:3, 151:12, 181:8, 194:4, 179:18, 211:14 tower 205:17
114:9, 117:19, 52:17, 209:20, 303:7, 310:22, stockholders 24:6 156:14, 157:10, 203:10, 232:8, together 36:10, towers 69:18, 69:21
118:23, 119:7, 232:4, 236:6, 311:6, 311:8, stole 88:18 157:14, 164:24, 232:9, 232:12, 36:22, 38:24, town 27:11
153:15, 161:5, 286:12 311:15, 313:1, stolen 27:20, 27:22, 166:3, 168:3, 251:11, 259:3, 103:19, 126:6, trace 78:19, 78:22,
166:7, 202:8, Started 6:12, 24:5, 313:6 264:3 179:17, 189:2, 266:24, 306:15 127:17, 128:4, 78:24, 102:7,
211:19, 256:22, 24:8, 36:5, 36:10, stated 62:15, Stolerow 166:5 194:1, 209:12, third-party 73:4, 143:18, 174:11, 102:13, 102:20,
303:5, 303:15, 37:20, 37:24, 109:17, 115:23, stood 79:18, 177:18 216:4, 248:20, 206:24, 258:4, 197:8, 197:9, 104:16, 105:7,
307:3, 307:4 66:4, 72:23, 140:21, 236:13, stopped 166:16, 251:24, 253:11, 306:3 197:16, 198:20, 113:11, 113:12,
spoken 30:20, 31:4, 117:24, 190:7, 238:16 167:24, 170:3, 267:3, 277:15, this...i'm270:17 205:6, 205:21, 114:14
31:14, 32:5, 263:8, 269:12 Statement 44:4, 170:17, 178:9 280:8, 280:11, Thomas 222:11 218:19, 218:21, traced 82:22, 83:3,
33:12, 34:1, starting 18:15, 22:2, 85:7, 94:6, stopping 218:13, 282:21, 285:8, though 122:14, 219:9, 220:12, 102:22, 103:1,
41:17, 43:4, 36:6, 36:18, 104:15, 108:20, 257:23 307:1, 307:8, 126:14, 144:21, 230:16, 267:13, 198:1
43:16, 46:20, 160:10, 160:12 109:10, 109:14, stopwatch 291:1 307:14 151:20, 185:8, 269:12, 269:13 traces 102:15
49:13, 49:17, starts 29:1, 136:17, 109:19, 114:3, store 69:22 testify 113:3, 164:10, 187:19, 214:20, Tom160:23, 161:18, track 139:18,
49:21, 50:9, 171:19 255:8, 255:10, stored 70:10, 70:11, 225:24, 255:20, 249:14, 270:23, 161:21, 161:22, 139:20, 194:3
51:23, 88:10, State 1:21, 2:13, 255:14, 255:24, 70:18 256:21, 283:1, 278:15, 311:24 221:16 tracking 71:19
157:11, 216:5 2:16, 3:3, 6:7, 256:6, 268:22, story 24:24, 132:12 313:16 thoughts 41:5 tomorrow162:24 Tracy 159:20,
spotted 194:23 27:1, 27:2, 29:5, 268:24, 289:13, straight 252:6 testifying 87:2, thrash 206:12, tonight 183:14, 159:24, 160:2,
Spring 157:7 37:17, 38:4, 39:2, 300:3, 301:13, Street 1:22, 2:5, 140:17, 166:9 207:7, 208:8 192:22 160:3, 160:4,
Springfield 126:7 39:13, 39:21, 303:11, 307:7, 2:28, 3:8, 148:17 TESTIMONY 8:20, threatening 85:8, Took 57:8, 57:10, 160:7, 160:9,
squad 181:2 40:1, 40:10, 307:17, 308:11 Strike 59:22, 121:4, 9:1, 25:10, 30:4, 287:5 64:8, 65:10, 160:17, 160:18,
squash 257:6, 43:13, 43:14, statements 292:8, 220:24, 228:9 33:3, 33:8, 55:16, Three 10:16, 10:19, 72:11, 73:12, 160:20, 160:22
286:20 94:3, 94:15, 294:23 strong 117:4 87:8, 113:22, 10:24, 11:15, 85:11, 107:4, train 23:19
squashed 257:10, 99:22, 121:7, States 1:1, 1:17, struck 219:24 115:20, 117:14, 51:10, 56:18, 139:7, 169:13, Trained 22:4, 70:8,
258:15, 258:24, 121:20, 124:7, 98:24, 110:14, stuck 64:13, 273:4 157:24, 158:15, 67:8, 71:13, 188:13, 248:15, 70:13, 71:10,
259:23 126:1, 127:12, 111:20, 131:13, student 142:15, 170:16, 170:21, 130:1, 166:16, 254:5, 259:1, 71:19, 71:20,
squirrelmail 192:18 127:16, 127:21, 137:6, 148:1, 144:2, 144:4, 178:17, 182:11, 168:1, 170:3, 273:8, 285:6, 295:24
staff 53:11, 53:15, 127:24, 128:11, 197:24, 211:17, 145:1, 145:7 262:23, 280:13, 170:18, 256:11, 307:21 training 20:12, 66:1,
53:18, 53:20, 128:14, 128:17, 225:11, 225:20, stuff 69:23, 70:18, 281:6, 281:9, 273:8 Top 136:17, 136:22, 70:10, 71:6, 97:24
82:3, 82:14, 128:22, 148:31, 234:9, 236:9, 117:7, 128:5, 281:13, 297:4, three. 10:15 165:3, 165:6, transactions 232:19
89:16, 89:17, 148:34, 149:3, 236:15, 238:3, 151:6, 151:7, 305:4, 305:7, throughout 8:15, 165:7, 171:1, transcript 7:23,
89:19, 89:20, 153:17, 155:20, 240:8, 240:13, 218:9, 296:14 307:15, 308:18, 129:23 172:16, 173:7, 229:7, 313:23
361 363

subcontractor 98:5 summoned 44:1 <T> Technology 16:6, transcripts 229:14 199:4, 213:8, 189:8, 199:9 types 70:4
subcontractors supervisor 56:11, table 72:13 16:13, 75:3, 75:6, transferring 37:14 217:21, 224:16, Turn 66:21, 93:14, typewriting 313:22
113:15, 118:24 58:22, 111:9 tabs 126:2, 127:2, 75:11, 75:15, translate 7:23 236:3, 252:23, 98:23, 102:1, typo 137:15
Subject 11:4, 12:9, supplement 14:2 127:4, 127:18, 75:19, 76:22, transpired 36:24 253:13, 255:4, 111:19, 125:23,
166:14, 172:19, supplemental 161:7 129:5, 129:6, 77:14, 78:6, travel. 232:20 260:22, 261:7, 131:12, 137:23,
182:2, 199:12, supplies 55:13 129:9, 129:12 78:10, 80:13, treated 294:4 265:5, 266:1, 138:22, 141:4, < U>
232:1, 261:22, Support 129:20, tag 94:4 82:1, 88:5, 88:8, trial 41:23, 42:1, 270:11, 272:14, 141:6, 155:12, Uh-uh 7:22, 128:11
266:5 144:16, 185:5, talked 12:18, 86:20, 88:11, 90:3, 42:4, 175:5, 274:8, 288:10, 159:22, 162:19, unauthorized
submitted 250:17, 185:6, 188:16, 118:15, 178:11, 90:12, 90:22, 175:6, 176:23, 291:4, 295:13, 171:1, 171:5, 194:21, 209:14,
298:3 188:18, 188:21, 221:16, 232:6, 91:3, 91:10, 92:1, 279:14, 280:9, 299:17, 300:4, 179:10, 194:4, 209:17, 209:22,
subpoeaned 259:16 189:8, 189:11, 287:11 92:10, 103:17, 280:12, 280:16, 301:3, 301:6, 214:6, 232:4, 209:23, 210:21,
subpoena 258:4, 198:14, 199:15, tall 280:23 103:24, 106:3, 280:19, 281:3, 302:1, 303:2, 234:8, 238:10, 212:3, 213:1,
258:19, 259:4, 200:1, 242:13, tamp 248:10 113:14, 114:20, 281:6, 281:9, 313:22 240:7, 243:22, 213:8, 213:13,
261:14 242:21, 266:5, tampered 27:20, 118:15, 120:13 281:12, 281:13, trun 154:13 244:22, 246:5, 213:17, 247:5
subpoenaed 258:13 267:20 28:5, 29:9, 29:11, techs 119:13, 140:24 281:18, 281:19, Trust 34:6, 250:16, 297:21, 299:21, unaware 133:12
subpoenas 256:15, supporting 54:4, 45:22, 194:11, telephone 3:26, 282:5, 282:6, 250:18, 250:20, 301:18 uncertainty 104:17
256:16, 257:8, 54:6 249:5 149:20, 182:24 282:7 251:1, 289:4, turned 28:13, 57:21, understand 8:4,
257:18, 257:24, supposed 144:9, Tampering 37:4, television294:19 Tribune 276:14, 291:12, 291:14 65:17, 263:10 22:12, 24:16,
258:1, 258:8, 282:14 42:4, 42:11, 46:17, temp 47:9, 47:15, 277:21, 278:19, trusted 300:18 Turning 141:15, 50:1, 53:19, 60:4,
258:23, 259:10, surprise 287:6 47:19, 51:1, 52:18, 53:3, 278:23, 279:6, truth 313:17 160:16, 197:18 64:10, 64:12,
259:14, 259:17, suspect 80:10, 51:15, 107:12, 58:13, 59:11, 279:14 truthful 8:20, 8:24 TV 293:12 64:17, 69:1, 74:1,
259:20, 260:8, 308:5 122:13, 196:17, 62:21, 62:22, tried 24:24, 53:20, try 7:10, 7:11, 45:21, twice 42:16, 142:24, 76:2, 84:21,
286:16 suspected 103:6 216:10, 217:5, 63:1, 63:17, 191:24, 229:18, 58:24, 67:24, 143:2 86:19, 92:4, 92:5,
substance 13:22, suspicion 74:6, 219:12, 221:2, 65:23, 162:6, 256:2, 268:4, 68:4, 101:15, Two 6:10, 11:6, 15:6, 92:6, 95:3, 96:17,
31:5, 33:2, 33:7, 74:7, 74:13 251:14, 251:16, 162:12, 198:1 270:23 102:6, 102:7, 15:7, 15:12, 129:19, 147:5,
76:15, 77:7, 84:15 suspicions 268:3 256:13, 281:18, temp. 53:5, 110:24 trolled 99:14, 99:20 123:4, 144:19, 15:15, 17:15, 171:10, 176:24,
substances 8:23 Suspicious 209:23, 282:5, 284:20, tempered 211:23 trolling 104:12 218:22, 229:20, 17:17, 32:24, 180:17, 180:20,
successfully 59:14 210:10 286:9, 286:13, tempering 107:17 trouble 272:16 271:23, 272:5, 39:17, 40:8, 182:13, 182:16,
sue 220:19 sustained 223:6 310:24, 311:22 temporarily 52:8 troubles 168:10 272:16 44:20, 44:21, 182:18, 186:18,
sued 25:1, 175:9, swear 85:14, 163:20 Tanya 214:4 temporary 55:10, Trudy 289:8, 289:15, Trying 18:22, 37:18, 56:18, 80:9, 186:21, 192:2,
175:10, 175:13, sworn 6:4, 150:3, tape 64:21, 65:5 83:1, 190:22 289:23, 290:14, 66:22, 84:9, 83:20, 93:2, 93:9, 216:18, 218:18,
221:8 313:16 taped 274:21, Ten 46:11, 67:19, 291:12, 291:20, 127:5, 128:4, 112:2, 112:22, 218:22, 256:16,
suggest 168:24 sworn. 6:1 274:24 215:14, 215:16 292:5 147:1, 155:5, 114:23, 134:11, 258:17, 259:6,
suggested 44:1, synopsis 32:12 task 36:11 ten. 67:20 True 30:8, 55:19, 155:7, 160:22, 142:24, 143:1, 269:3, 269:4,
44:24, 45:1, 48:2, system59:4, 65:8, tax 289:13 term99:20 90:15, 97:5, 97:8, 161:2, 161:24, 154:15, 154:22, 269:10, 269:11,
85:22, 91:2 71:18, 74:18, teach 70:15 terminate 55:21 97:11, 97:14, 162:14, 171:14, 191:9, 228:3, 293:8
suggestion 91:1 131:17, 134:10, Tech 66:11, 66:23, terminated 62:2, 97:16, 97:21, 190:13, 192:7, 230:20, 246:5, understanding 13:4,
suggestions 123:10, 166:14, 169:10, 75:2, 119:13, 62:19, 63:17, 97:23, 98:4, 98:6, 207:9, 218:20, 254:16, 276:19, 13:8, 68:17, 79:11,
123:12, 281:5 170:9, 170:11, 185:13, 188:15, 63:21, 63:23, 98:10, 98:11, 227:24, 239:14, 284:16, 289:4, 99:19, 102:12,
suit 221:9, 314:3 170:20, 188:9, 188:17, 188:21, 88:21, 89:2, 89:6, 98:14, 98:19, 239:17, 239:18, 292:21, 293:16, 111:5, 137:2,
Suite 1:22, 2:6, 2:29, 200:24, 222:21, 189:8, 189:11, 99:5, 111:2, 111:6 100:2, 103:16, 243:6, 254:9, 293:23, 308:1 170:7, 171:18,
3:17, 110:7, 277:9, 305:16 199:15, 200:1, termination 56:5, 103:24, 105:18, 256:4 two. 106:4, 281:23 180:22, 181:10,
148:18 system. 166:18, 242:21 57:3, 58:6, 62:4, 113:13, 114:19, Tsupport@gmail tying 305:13 269:12
summarizing 91:24 225:15 technical 93:20, 63:8, 81:9, 81:16, 115:1, 118:15, 189:14 type 16:18, 37:8, understood 8:7,
summary 109:17, systems 81:22, 89:5, 185:5, 185:6, 131:21, 211:24 120:12, 125:20, Tsupport@gmail.co 38:6, 105:16, 91:5, 95:16,
110:14, 238:23, 93:21, 305:5 198:14 terms 13:6, 15:6, 130:10, 133:1, m184:21, 186:7, 146:22, 158:12, 105:14, 110:23,
244:8 technician 93:23 16:1, 38:9, 38:13, 154:17, 159:18, 186:9, 186:12, 181:2, 209:24, 119:11, 161:17
Summer 157:7 Technologies 76:13 53:22, 76:12 191:6, 197:24, 187:17, 189:4, 296:13 undetermined 313:9
362 364
ACR REPORTING, LLP - 312.422.0515
Case: 1:13-cv-04924CAROL
Document #: 267-7 Filed:
SPIZZIRRI - 07/16/18
MAY 11, Page 93 of 93 PageID #:2081
2018
uneasy 287:2 39:1, 201:10 273:13 269:20, 269:24, 66:6, 84:4, 119:13, 123:19, 147:10,
unfortunate 130:24 vehicle 302:2, 303:3, violate 13:1 271:16, 272:4, 122:7, 127:17, 177:16, 201:5, < Y>
Unfortunately 246:9 303:8 violation 117:8 273:13, 273:19, 128:4, 129:1, 239:19, 278:5, yahoo 83:7, 84:1,
unit 44:8, 118:1 vendor 44:19 Vip 309:22 286:24, 287:1, 144:9, 145:1, 287:23 112:23, 181:3,
United 1:1, 1:17, vendors 44:20, Vipgeek 181:2, 310:10, 312:6 150:16, 162:16, written 85:5, 85:12, 186:20, 210:14,
148:1, 313:9 44:22, 45:1, 73:4, 181:4, 181:15, wanting 230:24 171:13, 189:15, 103:4, 132:15, 233:8, 247:20,
University 202:1, 203:10, 206:24, 181:17, 182:12 warn 95:7, 95:12 193:17, 218:19, 142:4, 180:20, 248:14
202:7, 302:13, 306:4 virus 151:8 warned 96:6 219:9, 220:11, 241:5, 246:17, yahoo-based 186:16
302:14 verbal 7:19 Virus/malicious warrant 79:13, 227:1, 227:3, 275:2, 300:4, yahoo.com112:3
unknown 111:21 verbatim109:18 99:11 143:4, 217:1 227:5, 237:1, 300:5 year 15:3, 19:12,
Unless 207:17, verification 294:7 viruses 151:5 wash 255:18 241:22, 242:23, wrongly 266:15 52:17, 53:1,
243:20, 262:7 verified 242:22 Visa 116:20, 142:15, Washington 2:18, 254:5, 254:7, wrote 54:2, 54:3, 108:13, 109:21,
unlikely 183:23, verify 70:9, 90:17, 144:2, 144:4, 22:6, 116:17 267:12, 267:15, 94:18, 111:12, 109:23, 159:4,
193:4 154:24, 155:2, 144:5, 145:1, watched 216:1 269:13 126:5, 132:6, 283:23, 290:9,
unsure 12:19 266:18 145:7, 202:12, Waukesha 16:7, works 242:21 145:2, 167:9, 292:7
Until 23:2, 52:8, via 3:26, 149:20 308:4, 308:5 17:21, 18:15, world-renowned 167:12, 167:17, years 17:16, 19:18,
52:23, 54:21, vicious 266:9 vital 219:21 18:17, 19:3, 20:9 302:16 177:3, 186:22, 21:13, 26:10,
56:14, 58:19, Victim225:12, voice 17:9, 31:20, Web 113:11, 114:14, worth 70:6, 212:15, 187:1, 187:16, 67:15, 67:19,
70:18, 117:17, 255:8, 255:9, 255:15 131:15, 134:7, 212:16 199:22, 217:22, 70:6, 132:19,
118:9, 119:12, 255:13, 255:23, void 124:11 188:14, 188:16, wow171:8, 171:19 238:20, 238:23, 284:16, 286:16
142:19, 147:17, 256:6 Voita 216:21 266:5 Wow...and 171:8 239:23, 245:16, young 63:15, 65:23
152:5, 162:9, Victor 59:11, 63:16, voluntarily 100:21, web/computer wrapping 57:5 245:23, 246:2, youngest 228:2
176:6, 176:8, 169:15, 169:18, 311:14 238:19 write 34:4, 34:8, 246:9, 264:18,
176:11, 187:6, 170:3, 221:6, volunteer 31:23 Web/email 131:18 54:5, 122:6, 268:10, 274:9,
200:19, 238:16 221:11, 221:12 volunteered 122:17, Webh 166:8 122:17, 129:4, 276:13, 277:20, <Z>
Update 125:24, view86:5 122:22 Webhsp 134:8, 130:23, 132:22, 280:1, 296:14, Zarkos 280:22
218:8 viewing 99:12 vs 1:9, 148:9, 313:12 139:5, 139:6, 134:6, 139:12, 307:16 Zebra 6:10
upset 177:12, Village 2:34, 6:20, 139:13, 139:18, 141:9, 142:14, WUNDER 2:26, 4:14, zeros 125:11
177:17, 178:10, 148:43 139:20, 140:20, 145:5, 145:9, 6:19, 99:6, Zs 6:10
259:12, 260:5, Vince 43:21, 44:2, < W> 166:4, 166:8, 162:22, 166:15, 131:22, 136:16, Zurich 225:4
286:7, 286:11, 44:15, 45:4, 55:3, Wait 124:1, 273:22, 180:19, 180:23, 167:24, 168:15, 136:23, 148:39,
286:14 55:6, 56:7, 56:23, 273:24, 297:14 181:12, 181:17, 169:9, 218:5, 180:14, 180:16,
upside 135:10, 58:17, 66:19, Waive 312:12 181:19, 181:20, 218:10, 219:15, 245:21, 276:10,
135:18 66:24, 67:2, 67:4, walk 90:2, 242:16, 182:12, 185:8, 232:17, 238:12, 290:23, 291:2,
us. 161:12 67:15, 68:21, 273:3 188:19, 188:22, 240:22, 241:14, 304:22, 305:2,
useful 119:19, 209:4, 86:4, 95:4, 100:5, wanted 47:24, 54:11, 189:5, 201:3, 241:20, 242:1, 309:6, 310:13,
209:9 100:6, 100:15, 65:1, 95:2, 95:11, 236:23, 237:2, 242:19, 255:7, 310:15
username 242:24 100:16, 105:23, 96:7, 123:11, 237:4, 239:12, 255:13, 256:8, Www.illinoiscorrupt
using 71:21, 134:10 106:6, 118:16, 124:12, 144:17, 240:14, 240:15, 267:6, 268:19, ion.net 226:11,
120:13, 125:17, 150:7, 168:23, 241:22, 242:2, 270:15, 272:8, 226:14
153:23, 187:10, 170:5, 170:15, 242:21, 244:5, 274:20, 276:23,
<V > 254:8, 257:9, 174:23, 197:15, 244:14, 246:13, 277:11, 277:23,
vacating 269:20 259:21, 259:22, 204:18, 204:19, 246:18, 246:21 278:1, 279:12, <X>
vaguely 214:19 260:1 220:13, 220:15, Webhsp.com242:13 291:8, 301:19 X2 214:10
Value 195:12, 197:5, Vincent 81:24, 239:1, 239:10, webmail 183:13, Writes 155:18, X4 166:16, 167:24,
253:15 203:1, 203:6 239:11, 239:18, 192:20 159:24, 180:3, 170:17
vandalized 225:14 vindication 272:9, 250:11, 256:19, Website 65:24, 244:1 X5 267:1
various 9:19, 36:7, 272:10, 273:7, 264:15, 269:8, 139:11, 193:14, writing 123:18,
365 367

202:5, 217:11, 119:23, 160:9, 121:17, 185:13, 286:15


226:10, 226:13, 204:3, 204:9, 203:20, 230:17, words 94:12,
226:21, 226:22, 208:14, 208:20, 230:20, 250:14, 139:15, 186:23,
227:10, 227:13, 283:12, 295:12 313:5 187:2, 255:15,
227:19, 228:6, white 36:23, 40:14, without 45:18, 309:15
228:10, 229:2, 40:18, 40:21, 41:7 82:10, 145:19, work 14:2, 20:15,
229:21, 230:4, who'd 234:12 145:20, 257:12 21:7, 21:10,
230:5, 231:9, who/what 102:8 WITNESS 4:2, 6:1, 21:13, 22:1,
231:16, 237:12, Whoever 28:6, 6:3, 7:16, 12:15, 35:20, 38:20,
257:20, 264:7, 28:19, 29:4, 17:11, 18:5, 45:10, 46:1,
267:21, 271:4, 263:17, 264:8, 48:13, 56:2, 52:11, 52:21, 53:3,
271:24, 273:16, 268:16 56:18, 60:3, 65:5, 55:10, 61:23,
277:5, 296:10, whole 32:12, 101:13, 68:8, 77:2, 77:4, 63:18, 65:16,
301:5, 301:9, 126:15, 127:7, 81:19, 93:4, 67:10, 67:15,
301:11, 309:24 297:3, 311:4, 94:24, 99:8, 67:23, 68:3,
websites 152:20, 313:17 100:12, 101:6, 68:24, 94:10,
264:6, 269:11, whom63:20, 291:12 104:21, 106:15, 95:2, 95:11, 95:16,
271:4, 277:12 Whomever 262:10 107:2, 115:6, 96:7, 98:4,
websites/related whore 228:2, 228:4, 123:1, 125:5, 103:16, 124:20,
271:20 228:7 129:11, 131:24, 126:9, 126:19,
Wednesday 245:8, wife 18:1, 18:10 133:10, 140:12, 150:17, 163:12,
245:9 Wildman 160:7 140:24, 142:11, 163:16, 163:17,
week 69:6, 272:18, Will 6:16, 7:6, 7:10, 143:16, 147:14, 163:23, 176:4,
291:13 8:4, 8:5, 8:7, 8:15, 150:2, 164:6, 205:7, 205:11,
weekend 66:18, 12:20, 14:2, 14:9, 164:11, 166:21, 205:19, 216:8,
67:24, 68:4 56:2, 104:7, 169:4, 172:2, 216:20, 218:3,
weeks 81:21, 82:7, 120:4, 134:16, 178:5, 180:15, 254:6, 257:11,
89:10, 121:19, 134:24, 137:3, 180:17, 183:10, 259:24, 264:19
153:8 162:24, 174:22, 188:7, 191:13, work-in 162:7
West 2:18, 3:8 175:5, 177:3, 196:8, 203:20, worked 17:4, 17:5,
Western 17:5, 17:15 183:13, 183:17, 211:5, 224:18, 17:17, 21:11,
whatchamajigger 183:22, 183:24, 234:22, 238:3, 22:14, 29:13,
205:12 184:2, 188:5, 239:6, 249:24, 29:15, 35:11,
whatever 12:22, 191:13, 192:20, 265:10, 265:16, 45:19, 46:5, 46:6,
14:3, 83:21, 85:6, 192:23, 193:3, 273:23, 279:8, 52:4, 59:18, 65:1,
144:15, 176:6, 193:5, 201:10, 283:9, 285:3, 66:18, 67:9,
196:17, 202:16, 237:12, 256:14, 298:18, 302:5, 67:13, 68:13,
204:18, 205:24, 284:5, 297:3, 303:5, 303:15, 69:17, 97:11,
241:9, 247:9 305:7 309:4, 310:14, 98:6, 103:19,
whatsoever 285:16 William2:33, 43:17, 310:17, 312:10, 111:18, 128:5,
Whenever 121:19 148:42 313:8, 313:21 150:18, 181:3,
Whereas 185:10 willing 123:8, 294:3 witnesses 303:20 205:11, 216:19,
wherein 313:11 Wisconsin 20:4, woman 160:2 218:21, 240:10
WHEREOF 314:5 26:13 wonderful 67:5 working 21:16,
Wherever 268:22 wise 69:14 Woods 3:15, 149:12 21:21, 36:3,
whether 12:19, 48:1, wish 64:10 word 26:22, 26:23, 52:17, 53:23,
96:5, 96:13, Within 1:20, 17:6, 72:10, 90:21, 58:8, 62:19, 63:2,
102:19, 109:19, 17:7, 19:13, 21:3, 184:10, 188:6, 63:24, 65:23,
366
ACR REPORTING, LLP - 312.422.0515