Case: Document 166-2 Filed: 02/02/16 Page 50 of 191 PageID #:958

Exhibit 

Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 51 of 191 PageID #:959

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS

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EASTERN DIVISION

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SHANNON SPAULDING and

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DANIEL ECHEVERRIA,

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Plaintiffs,

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-vs-

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No. 12 CV 8777

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CITY OF CHICAGO, et.

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al.,

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Defendants.

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The Deposition of JAMES O'GRADY taken before

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Thomas A. Manno, C.S.R., pursuant to the Federal Rules of

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Civil Procedure pertaining to the taking of depositions

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for the purpose of discovery, at Christopher Smith Trial

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Group, One North LaSalle Street, Suite 3040, Chicago,

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Illinois 60602 on March 5, 2015, at 9:30 a.m.
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1 APPEARANCES:
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CHRISTOPHER SMITH TRIAL GROUP
One North LaSalle Street, Suite 3040
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Chicago, Illinois 60602
BY: MR. CHRISTOPHER SMITH
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Chris@lawsja.com
312-432-0400
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Appearing on behalf of the Plaintiffs;
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DRINKER, BIDDLE & REATH, LLP
191 North Wacker Drive, Suite 3700
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Chicago, Illinois 60606
BY: MR. ALAN S. KING
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312-569-1334
Alan.king@dbr.com
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Appeared on behalf of the Defendants.
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(Witness sworn.)
JAMES O'GRADY,
being first duly sworn, was examined and testified as
follows:
EXAMINATION
BY MR. SMITH:
Q. Can you please state your name and spell your
name for the record?
A. James O'Grady, O-G-R-A-D-Y.
Q. Where are you currently employed?
A. The Village of Harwood Heights, Illinois.
Q. And what is your position there?
A. I'm the Chief of Police.
Q. And when did you become the Chief of Police
there?
A. December of 2013.
Q. Prior to that, where did you work?
A. I was employed by the Chicago Police Department
from 1986 until 2013.
Q. What reason did you leave?
A. I retired from the Chicago Police Department
and I took another position.
Q. And I know that's a long period of time, but
essentially if you could try to do your best to give me

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1
INDEX
2
3 WITNESS:
PAGE:
4 James O'Grady
5 (Exam. By Mr. Smith)
4
(Exam. By Mr. King)
87
6 (Further Exam. By Mr. Smith)
88
7
8 EXHIBITS:
9 No exhibits were marked.
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your main assignments and the years, timeframe, as to
when you moved or were promoted-A. Sure.
Q. --within the Chicago Police Department.
A. I started with the Chicago Police Department in
July of 1986. I was first assigned to the academy for
training. Subsequent to that, I was assigned to the 13th
District, west side of Chicago. I worked there until
1988, when I was detailed to the Area 4 Gang Task Force.
I worked there until approximately 1990.
I returned to 13th District and was then
assigned to the Narcotics Division in 1991. I worked
there until 1997, I believe, when I applied for and was
assigned to the Internal Affairs Unit, where I worked
undercover on police impersonators and police corruption
cases.
I was then promoted as sergeant in 1998 and
assigned to the 15th Police District until 1999, where I
returned to the Narcotics Division as a sergeant.
Approximately 2002, I was detailed to the
Office of Legal Affairs as the commanding officer, where
I dealt with issues, legal issues, affecting the Chicago
Police Department, including contract issues, labor
issues, suspensions, terminations, investigations

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involving police officers.
And then returned to the Narcotics Unit, I
believe, in 2003, at which point I was assigned to the
DEA Task Force, Group 47, Federal Task Force, operating
out of Homan Square.
I was promoted to the rank of lieutenant in
2006, assigned to the 15th District again as a watch
commander on the third watch.
In 2008, I returned to the Narcotics Division
as a lieutenant, and promoted to the rank of commander
in, I believe, August of 2008, commander of the Narcotics
Division.
And then assigned as the commander of the 11th
District in 2013, October of 2013. And then I retired in
December of 2013.
Q. Thank you.
A. I was all over the place.
Q. Could you explain a little how you got the
position within IAD when you were assigned there? How
did that come about?
A. I applied for it. There was an opening.
My former commander, Michael Hoke, he was a
former commander of the Narcotics Division. He took over
as the Deputy Superintendent of Internal Affairs.

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there was sufficient grounds to terminate or to suspend.
Q. Okay. So at that stage you weren't making the
initial assessment of whether to recommend a suspension
or termination, you were essentially helping the process
of reviewing whether that was appropriate?
A. Correct.
Q. And were there times where you would disagree
with a suspension or a termination, and believe that it
wasn't sufficient evidence for a suspension or a
termination?
A. Yes.
Q. And other times you would agree there was?
A. Other times we would concur. Sometimes concur
with the investigation, but not concur with the penalty,
maybe suggesting an alternate penalty.
On several occasions, I personally didn't feel
there was legal sufficiency to support termination, and I
would draft a synopsis of that for the Superintendent to
review.
Q. Was there ever a situation where somebody
recommended a suspension, or something short of
termination, where you recommended that there should be a
termination?
A. I don't recall specifically.

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He and I had a conversation regarding me
working for him. I thought that was an exciting for
myself to learn more and to assist and helping the police
department. I then applied for it and was accepted to
the position.
Q. Okay. You mentioned also that you had worked a
position where you were kind of, I don't want to misquote
you, but you essentially had a role in reviewing
suspensions and viewing contracts and things of that
nature.
A. Correct.
Q. What would have been your role with respect to,
if there was somebody who was recommended for a
suspension? At what stage would you be involved in that
process?
A. The General Counsel would receive I think it
was any suspension of 15 days or more, or any termination
cases. The General Counsel, she would then refer them to
attorneys in the office.
I was one of the attorneys who, we would review
these CR numbers for legal sufficiency, that the
investigations were done properly.
And then we would do a cover sheet for the
Superintendent to review to determine whether or not

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I do remember when I was in Internal Affairs I
recommended termination on a couple of cases. But when I
was in Legal Affairs, I don't remember.
There were so many CR numbers. I mean, on a
daily basis, I'd have four or five CR numbers waiting for
me.
Q. Now, in terms of both as somebody who worked in
IAD and as an officer with 30 years experience, including
years as a commander, would it be fair to say that you
have a fairly good understanding of the rules and
regulations and general orders?
A. A general understanding. Obviously our general
orders are quite large. To say I know every single
general order, no, I wouldn't. No, I don't.
Q. In other words, you certainly don't have them
all memorized?
A. Absolutely not.
Q. However, would you agree that, generally, you
feel that you tried to have a decent understanding, and
you also know where to go if you have a question about a
general order?
A. Correct.
Q. For the most part, when you look at the general
orders, in particular with respect to harassment and

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issues of, retaliation-type issues within the Chicago
Police Department, you would agree that all the
department members should follow the rules and
regulations, that there's no exception based on rank?
A. Correct.
Q. And with respect to the rules regarding the
complaint registers in terms of when officers should
report misconduct, and when they should report crimes by
other officers, you would agree that those rules and
regulations don't have exceptions based on rank?
A. Correct.
Q. When you were first assigned to narcotics as a
lieutenant, what shift were you working?
A. When I first returned to the Narcotics Division
as the lieutenant, I was running the Asset Forfeiture
Unit, which is a sub-unit. At that time it had changed.
Asset Forfeiture at one time was under
Narcotics. Then it moved to Vice, then it was back to
Narcotics and back to Vice.
But at that time, in 1998, they needed a
lieutenant to work, to cover that forfeiture. So I was
still assigned to the Narcotics Division, but I was
working in the Asset Forfeiture Unit.
Q. And then when you were promoted to commander,

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investigations being conducted against any members within
the Narcotics Unit?
A. Did our office conduct any investigations, or
that our officers were being investigated?
Q. That your officers were being investigated.
A. Not to my memory, no.
Q. Were you briefed about any officers being
suspected for use, sale or possession of narcotics within
the unit?
A. My unit? No.
Q. During your course as the commander of
Narcotics, were you a made aware of any corrupt officers
involved in the sale, use or possession of illegal drugs?
A. My unit or outside units?
Q. Any of the units. Any of the individuals
within the Narcotics Unit.
A. No.
Q. As a commander of Narcotics, were you ever
informed by any outside agencies of any investigations of
members of the department being investigated for criminal
activity?
A. My officer or outside?
Q. That question would be outside.
Essentially outside agencies, like the DEA or

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what units would you be overseeing? You'd be overseeing
Asset Forfeitures and other units as well?
A. It was the Narcotics Section then, and their
Asset Forfeiture Unit.
Q. And the Narcotics Section would be teams of
officers who were going out with a primary goal of
investigating narcotics traffic and the related crimes?
A. Correct.
Q. Who did you replace as the commander of
Narcotics?
A. Nicholas Roti.
Q. And when you first replaced Commander Roti, did
you have any type of meeting where you reviewed what was
going on with the Narcotics Unit and were given a
briefing of what concerns there were, and generally the
way things were working?
A. Yes. I mean, I was one of his lieutenants, so
I had a pretty fair understanding. And obviously having
been there for most of my career, I would say I had a
fair grasp of -- obviously he brought me up to speed on
certain things I didn't know about as a lieutenant, but
yes, that would be fair to say.
Q. When you were arrived as either a lieutenant or
the commander, were you informed of any corruption

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FBI, did they come to you and say, we're investigating
any Chicago police officers for criminal activity?
A. Not that I can recall.
We did have our own independent investigations
that, but nothing from the outside agencies, like DEA,
ATF or FBI.
Q. When you say you had your own independent
investigations, were there investigations by narcotics
officers of other officers in different units suspected
of criminal activity?
A. Well, where violation of department orders were
involved, yes. So I would say, yes.
Q. When you say violations of orders involved, are
we talking about crimes, or just...
When I say "crimes," I mean like narcotics,
stealing, or more serious crimes even.
A. I mean, during the course of many of our wire
investigations, a police officer would come on the wire
as either an associate or some type of involvement with a
target.
And then in that case, we always initiated a CR
number on that officer.
Q. And were those investigations with wires, did
any of them involve co-op investigations that also

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involved the DEA?
A. Some yes and some no.
Q. When you first arrived at Narcotics -- I'm
sorry.
When you first arrived as a lieutenant in
Narcotics, were you aware of Shannon Spaulding and
Danny Echeverria?
A. By reputation. I had heard about them.
Q. And what had you heard?
A. That Danny was a decent officer.
That Shannon Spaulding was very, very
difficult. She was difficult to supervise, difficult to
work with. She wasn't well regarded. She wasn't well
liked by supervisors or other officers.
Q. And when did you hear this?
A. When I returned to the unit.
At some point, Chief Nick Roti, the Deputy
Chief, informed me that they were still on our sheets but
working on a special investigation. So their names came
up.
Q. And was that when you were made a commander or
was that when you were a lieutenant?
A. Made commander.
Q. And before that time, had you ever heard

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Q. Do you know what circumstance he came to you to
have that conversation?
A. No. Just in his office, having an informal
talk about officers in the unit, what's going on with the
teams, how guys are getting along, how are the teams
working.
Q. Did you ask him if he had any specific examples
of what Spaulding did that was inappropriate, or made it
difficult for her to work with?
A. Just the general -- argumentative with the
supervisors. Didn't get along with people. More general
than specific.
Q. Had you met Shannon Spaulding at that point in
time?
A. I've never met her.
Q. Was there anyone else present when you had this
conversation?
A. No. I think that was just in his office.
Q. Did he talk to you about any other officers
besides Spaulding and Echeverria at that time?
A. Yes, I'm sure we did. I don't recall
specifically who, but just the overall well-being of the
unit and officers on different teams. I can't remember
specifically who.

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anything about them?
A. Yes.
Q. From whom?
A. Other officers in the unit.
Q. Anyone in particular?
A. One in particular, but I can't remember when he
had this discussion. It was either when I was just made
commander, or it might have been prior to that. That was
Lieutenant Robert Cervenko.
Q. And what did he tell you?
A. That Shannon and Danny had to be split up.
That she was very difficult to supervise. That she
didn't get along with her team members. That she thought
very highly of herself. She didn't work well with -basically didn't work well with anyone else.
She was very adamant that she had to work with
her partner. She was very, very upset that they split
up, that they were split up, her and Echeverria, that
they were put on separate teams, and she did not like
that.
Q. At that time you were not supervising Danny and
Shannon, correct?
A. I never supervised Danny and Shannon, ever.
Never met them.

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Q. Do you remember any comments he made about any
other officers?
A. I think one of the supervisors, too, we were
also having an issue with.
Q. And who was that?
A. Sergeant Danny Allen.
Q. What did he say about Danny Allen?
A. Danny Allen just had a -- he had a difficult
time keeping him focused on tasks, and wanting to do
different things other than what he was assigned to.
Q. Did you give him any advice as to what he
should do with respect to Shannon Spaulding?
A. They were already gone.
Q. And do you have any idea why he brought that to
your attention at that time?
A. Basically grateful that they were gone, that
she was out of the unit. He said he dodged a bullet on
that one, she's gone, because she's very difficult to
work with.
Q. So, do you know how long after
Shannon Spaulding was gone that you had this conversation
with Robert Cervenka?
A. No. She was gone by the time I took over.
Q. Did you know what Shannon Spaulding's

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assignment was when Cervenka was having these issues with 1
her?
2
A. I'm not saying that Cervenka had issues with
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her. I'm just saying that that was her reputation. He
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was telling me about her.
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Q. Did you know what her assignment was when she
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allegedly had difficulties with other officers?
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A. When she was having difficulty with other
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officers, she was on one of the teams in Narcotics.
9
Q. Did you ever talk to any of those team members
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about Shannon Spaulding?
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A. No. It didn't come up. She was already gone.
12
Q. When was the next time after that conversation
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that you became aware of Officer Spaulding, or
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Echeverria?
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A. Became aware of them? I mean, Chief Roti, he
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was at that point Deputy Chief Roti.
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He informed me Shannon Spaulding and
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Danny Echeverria were informally on loan to Internal
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Affairs, working on a police corruption case.
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Q. When did he inform you of that?
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A. When I took over as commander.
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Q. And did he tell you any details about what they
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were doing?
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A. That was something Chief Roti -- I keep saying
"Chief," it's Deputy Chief then -- Deputy Chief Roti had
worked out with Chief Scale from Internal Affairs.
Q. Did you ever talk with Chief Scale about that?
A. No.
Q. Did you have an understanding how practically
that was working, in terms of where they would report,
Danny and Shannon would report, and who they would report
to and how they would report?
A. I have no information whatsoever, other than at
some point they were officially detailed to Internal
Affairs, I'm not sure of the date.
Q. Did Nicholas Roti tell you anything about
Spaulding and Echeverria, in terms of whether they were
good officers, not great officers, hard working, not hard
working?
A. He did, but I don't recall when that took
place.
Q. What did he say?
A. He said that they couldn't account for them.
They didn't know where they were. He said he had checked
with the FBI, and he verified how often they were
actually coming to work. And they said, we only use them
sporadically. So no one really knew where they were.

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A. Nothing specific. Just that they were working
on a police corruption case.
Q. And did he tell you that it involved
Officer Watts and Mohammed, or any officers in Public
Area Housing South?
A. I don't believe so.
Q. When did you first learn, if ever, that they
were involved in -- when did you first learn, if ever,
that there was an investigation regarding corruption of
Watts and Mohammed?
A. There was some rumors that they were being
looked at, but I didn't know either one of them.
So I didn't really -- it didn't really come up
on my radar.
Q. And where did you hear those rumors?
A. Sometime in late 2008, perhaps.
Q. Do you know who you heard them from?
A. I don't recall.
Q. Did you ever work with Sergeant Watts or
Mohammed?
A. No. I don't know either one of them.
Q. Did you ever have any conversations with either
-- what was your understanding of how the arrangement
worked where they were being loaned out?

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So I think Deputy Chief Roti told me his
concern was, no one was supervising them.
So, he wanted to ensure that they were
adequately supervised and formally under the IAD
umbrella, because he didn't us to be responsible for
them, because we didn't know where they were.
Q. When was that conversation? Was that at the
same time-A. I think it was subsequent. It was after that.
Q. Do you know how long after that?
A. No. I don't remember physically when.
Q. Did you ask him any questions about in what
manner they were assigned to the FBI?
A. No. It didn't affect me.
Q. Were they under your supervision as commander
at that time?
A. No. I never supervised either one of them.
Q. When they were being loaned out, at that point
in time when they were being loaned out from Narcotics,
would technically you have been their supervisor or
commander?
A. Technically I would have been in their chain of
command, but I had no idea who they were working for, or
on what, or their hours or their duties. I had no idea

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Page 22
1 what they were doing.
2

Q. Would you even have known who to contact to see

3 if they were doing their jobs?
4

A. No.

5

Q. Did you ask Roti who he had contacted to

6 confirm whether or not they were doing their job?
7

A. No. Deputy Chief Roti told me that they were

8 on a special assignment and on loan to Internal Affairs.
9 And other than, that that's all I knew.
10

Q. Well, at some point it was brought up that they

11 working with the FBI, correct?
12

A. At some point, yes.

13

Q. And did you know what -- did Roti tell you what

14 he did to check on whether they were showing up on time,
15 and working a full day and so on and so forth?
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A. He did, but I'm not sure when.
He said he contacted the FBI agent assigned to

18 that case, and he apparently said they had no idea where
19 they were.
20

Q. Did you have any sense of what timeframe the

21 FBI agent was asked about?
22

A. No.

23

Q. Did you come up with any plan to deal with, you

24 know, knowing where they were and how to account for them

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initiated. It was online on my cue for me to review, to
either concur or not concur. And I don't even remember
the date it came through.
Q. Do you remember if it was before or after the
conversation you had with Roti about Spaulding and
Echeverria working with the FBI?
A. The CR number was after. I already knew they
were working with the FBI and Internal Affairs on this
special investigation. The CR number came in subsequent
to that.
Q. So, had Deputy Chief Roti mentioned anything
about Shannon or Danny's character at any time before
that CR?
A. I don't recall.
Q. And did you talk to Deputy Chief Roti about the
CR?
A. Yes.
Q. What did Deputy Chief Roti tell you about the
CR?
A. That he was very concerned about it. It was
very -- it was pretty disgraceful. I mean, just that she
definitely was in violation of department rules.
MR. KING: Who is she?
THE WITNESS: That Officer Spaulding was in

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with Deputy Commander Roti?
A. It was Deputy Chief Roti.
Q. Deputy Chief Roti.
A. I had no involvement with them whatever. They
were on loan, supposed reporting to Internal Affairs.
At some point they were officially, Roti and
Scale worked out a deal, or worked out an arrangement,
where they would be officially detailed over. I'm not
even sure of the date.
Q. Did he mention whether he spoke to Juan Rivera
about where they were working, and what their assignment
was at that time, Deputy Chief Roti?
A. He didn't mention it to me.
Q. Was anybody else present for the conversation
you had with Deputy Chief Roti about Spaulding,
Echeverria and him contacting the FBI?
A. I don't recall. I don't know if I was present
or not.
Q. Did Deputy Chief Roti make any comments about
either Spaulding or Echeverria's character?
A. They did at some point. I believe when that CR
number came in.
Q. When was that?
A. I don't recall if there was a CR number

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violation of department rules, and it borderlined -- in
my personal opinion, it was borderline criminal, what she
did.
But I once I reviewed it, it was then submitted
to Roti for his review of that same CR number.
MR. SMITH: Q. And did you do any investigating of
that personally, the incident itself?
Other than reviewing the report, you didn't do
any actual investigating on your own regarding the
incident?
A. No.
Q. Did Nicholas Roti tell you what his
relationship was to the individuals, to the complainants
in the case, in the CR?
A. I don't recall, no.
Q. Were you aware that Nicholas Roti had a
relationship to individuals who were related to the
complainants?
MR. KING: Object to the lack of foundation.
You can answer.
THE WITNESS: I don't recall.
MR. SMITH: Q. Would it be appropriate for a
supervisor to be involved and investigating, or
commenting on a CR, if they had relatives that were the

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complainants?
MR. KING: Object to the form, lack of
foundation.
THE WITNESS: He had no role in the
investigation. I know that.
MR. SMITH: Q. Do you know if he had any role in
initiating the CR?
A. I don't know.
Q. So you had a role in reviewing the CR, correct?
A. Yes.
Q. And he was aware of that?
A. Yes, he was aware of it.
Q. You heard rumors about a possible investigation
of corruption of Watts and Mohammed.
Did you ever become formally aware that there
was an investigation like, where you knew that there had
been an investigation?
A. Only when I read about it.
Q. Did you become aware of whether or not there
were other officers under investigation at that time who
were connected with Watts or Mohammed?
A. No.
Q. Did you have any conversations with
high-ranking officers within the Chicago Police

Page 28

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Chief Rivera about Shannon or Danny?
A. No, I don't think so.
Q. And again, that's Shannon Spaulding and Danny
Echeverria.
A. I don't believe I did, no.
Q. Were you ever present in a meeting with
Chief Rivera in which Danny Echeverria or
Shannon Spaulding's positions were being discussed
A. Absolutely not.
Q. Did you have any reason to believe any of your
unit members were under suspicion for any criminal
activity during your tenure as commander in the Narcotics
Division?
A. One of my officers was arrested for a DUI that
resulted in him going to prison.
Q. Anything beyond that?
A. Criminal, no. Well, I take it back. A
domestic. One of my officers was arrested for a
domestic.
Q. Anything related to drugs, drug use or drug
sales, other than the DUI?
A. No.
Q. In your 30-plus years of experience, you're
aware of corruption investigating regarding officers

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Department about the indictments of Watts and Mohammed? 1
2
A. No. It didn't affect me whatsoever.
3
Q. You know Chief Juan Rivera, correct?
4
A. Yes.
5
Q. How long have you known Chief Rivera?
6
A. Almost 20 years.
7
Q. And were you ever personal friends with him?
8
A. I wouldn't say personal, not friends, but
9
certainly friendly. He was a sergeant in Narcotics when
10
I was an officer.
11
So I knew him and certainly had respect for him
12
and was friendly with him. I wouldn't say he was a
13
friend.
14
Q. Did Chief Rivera ever tell you about an
15
investigation of members outside Unit 189 relating to
16
drug crimes?
17
A. No.
18
Q. Did Chief Rivera ever tell you that Shannon or
19
Danny were involved with IAD?
20
A. No. I don't recall that.
21
Q. Did Chief Rivera ever tell you that Danny or
22
Shannon were working with the FBI?
23
A. I don't believe so, no.
24
Q. Did you ever have a conversation with

Page 29

within the department such as Finnegan, Majanowski,
Edward Lee Jackson? Are you familiar with those three
examples?
A. I'm familiar with -- I heard about the SOS
scandal. I heard about Jerry Finnegan being involved in
that. I never met him. I had met Majanowski.
And the other one was Reginald Lee? Is that
the 15th District officer?
Q. Edward Lee Jackson is known as Pacman, 15th
District.
A. I definitely heard of him, yeah.
Q. Are you aware he was accused of home invasions
and other criminal acts, in that light?
A. I'm aware of it, yes.
Q. Were you aware that all three of those
investigations were done by a joint investigation between
the federal agencies and the Chicago Police Department?
A. Just general. What I read in the newspaper.
Q. Do you know or do you think it's a benefit when
federal agencies join together with the CPD to
investigate Chicago police officers?
A. Sure it's a benefit. However, when I was with
Internal Affairs, I arrested officers for home invasion
and drug crimes.

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Q. And do you recall who they were?
A. The team I was on, we arrested
Officer John Labiak, Karaster and Hutchinson (phonetic
spellings) for home invasion and robbing of drug dealers,
and I was the one who arrested them.
Q. While you were in IAD, when officer were
charged with crimes by the federal agencies, did you ever
then reopen CRs to see if there was potentially other
officers who worked with them were also involved in
corruption?
A. I didn't. I wouldn't of at that point in my
career. I was an investigator. I wasn't a supervisor.
Q. Did anyone ever tell you to do that, to go back
and look at CRs that involved the indicted officers to
see if other officers were involved in corruption?
A. When we did the Labiak case, I do remember the
team I was on, we did some follow-up. I don't recall
specifically. It's been so long. It was back in '97, so
I don't recall specifically.
But we did look into furthering an
investigation. I remember we did a search warrant on one
of the lockers in the 11th District. I don't remember if
other officers were involved in that.
Q. Were those officers investigated at this point

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corruption of another officer either who was inside your
unit?
In other words, one Chicago police officer says
that somebody in the Narcotics Unit is committing crimes.
A. No one ever made that allegation to me, no.
Q. Did anyone at any point in time -- well, has
anyone ever approached you while you were in Narcotics
about a police officer outside of your unit committing
crimes?
A. I mean, I can speak of specific examples.
My team, when I was supervisor, we encountered
a -- in one of our investigations, it became apparent
that a police officer was involved, and we seized a
substantial amount of narcotics from his residence. I
obtained a CR number on him.
And then I was the affiant of a search warrant
on his vehicle, because we believed his vehicle was used
for transportation of narcotics. I was the affiant of
the warrant for that.
As a lieutenant, we did a search warrant on an
apartment that, a state search warrant where one of my
officers had a search warrant, and it ended up being the
residence of a Chicago police officer.
We obtained CR number on her, and I ordered her

Page 31

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then?
A. I know they were investigated. I don't recall
the specifics though.
Q. Were there attempts to look at other older
allegations of criminal activity?
In other words, when you learned there was
sufficient evidence to believe there was a potential for
the criminality in the instance that you were involved in
investigating, did you then go back and look at older CRs
that involved different people in different instances
connected to those officers?
A. I remember we looked at old allegations against
those officers to see if -- obviously there was a common
thread, because they were subsequently charged with home
invasion, but I don't recall when we did it. Just prior
to the arresting or post arrest, I don't recall.
Q. Were there supervisors interviewed concerning
their activities?
A. I don't know.
Q. If a member of your command came to you with an
allegation of corruption within the Chicago Police
Department, what were you required to do?
A. Obtain a CR number.
Q. Has anyone ever approached you regarding

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in to be drug-tested.
There was someone potentially selling drugs out
of her apartment. So, yes.
And then as a commander, I would be informed
that an officer had touched one of the investigations in
some regard, and the CR number would be obtained on that
officer.
Q. Was there ever an instance where a Chicago
police officer came to you about something that you
weren't involved in an investigation, there wasn't an
ongoing investigation where they simply just came to you
to report illegal acts that they saw another officer do?
A. I don't recall any of those, no.
Q. Are there instances where breaches of
confidentiality concerning IAD investigation could
potentially be dangerous to the investigators who were
working on a case?
MR. KING: Just object to the form of the
question.
MR. SMITH: Q. Is it something you consider when
working in IAD that people finding out, officers finding
out that they're being investigated, could be a dangerous
situation for the officers who are investigating them?
A. Well, personally, I worked undercover in

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Internal Affairs. I was working on police corruption
cases. And yeah, that would be an issue.
Q. What things are done to protect IAD officers
from being exposed when they're investigating other
officers?
A. Investigations are relatively closed. Only a
few people usually know. It's not widely discussed or
brought up.
Q. And is there anything said to assure that it
doesn't leave that circle of the people who are in the
know of the investigation?
A. I can only speak from personal experience.
When I was in Internal Affairs, my team knew
what I was doing, my supervisor, and that was pretty much
it.
I'm sure my supervisor informed her lieutenant,
the lieutenants, who would inform the Deputy
Superintendent.
Q. Beyond that, would you think people were free
to talk to other high-ranking members within the police
department?
A. Regarding...
Q. Regarding a confidential investigation?
A. No. It was confidential. It's implied by the

Page 36
1

A. Absolutely get a CR number, and if it's

2 appropriate, make an arrest.
3

If an officer witnessed another officer

4 committing a criminal act, then that officer should take
5 immediate action, not just get a CR number.
6

Q. If a situation like that, a hypothetical

7 situation arose, where someone under you in Narcotics,
8 say a patrol officer, came to you and said, I saw another
9 officer dealing drugs, would the officer who came forward
10 with the complaint, would his identity be kept
11 confidential, or hers?
12

MR. KING: Just object to the form and lack of

13 foundation. It's a hypothetical. If you can answer.
14

THE WITNESS: In that specific situation, it

15 would be documented and reported up the chain of command.
16

MR. SMITH: Q. Would you expect that it be

17 confidential in terms of the identity of that
18 complainant? Would it be confidential within the
19 confines of the investigation in terms of, that you
20 wouldn't feel free to talk to other officers who weren't
21 in the loop or the circle of who would be involved in
22 getting the complaint and investigating the complaint
23 about who the identity of the person making a claim
24 against another officer?

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name that it's confidential. It's not to be discussed,
unless it's for briefing purposes, yes.
I mean, in that case, high-ranking officers in
the department customarily are aware of confidential,
ongoing investigations.
Q. Did you ever learn that -- aside from the
media, when you read about the Watts investigation, did
you ever learn what type of case Spaulding and Echeverria
were working on with the FBI?
A. There was a police corruption case, and I
believe at some point I learned it had something to do
with housing, public housing.
Q. And who did you learn that from?
A. I don't remember.
Q. Do you know who else was present when you found
out about that?
A. I don't remember.
Q. You indicated that if another officer came to
you with corruption, that he saw corruption of a criminal
nature of another officer, you would start a CR
concerning that issue.
Would you agree that the general orders would
require that you, as a supervisor, would start a CR if
you were told of corruption of another officer?

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A. In that situation, it would be documented.
The name of the complaining officer would be documented
and it would be forwarded to my deputy chief, then to the
chief, and then obviously to Internal Affairs.
Q. And would you expect that name be kept
confidential within the circle of the investigation until
the investigation was completed?
A. Probably, yes.
Q. And you wouldn't consider an officer who made
such an allegation against a fellow officer to be a rat?
You'd agree with that?
A. I would agree with that, considering I worked
Internal Affairs and I worked undercover in Internal
Affairs, and I arrested police officers. And I worked in
Legal Affairs.
I would not consider anyone coming forward with
that information to be any type of -- anything less than
a hero.
Q. And certainly you didn't consider yourself or
your fellow IAD officers to be rats?
A. No, we did not.
Q. And you never told Nick Roti that you didn't
want those two, referring to Shannon and Danny, IAD rats,
to be here, meaning in Narcotics, correct?

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A. I never referred to them as rats in my capacity
at any time in my career.
I was asked at some point, did I want
Shannon Spaulding and Echeverria back in the Narcotics
Division, and my opinion was no.
Q. And who asked you that?
A. Chief Nick Roti.
Q. And who else was present when he asked you
that?
A. I don't remember. It might have been a phone
conversation. It might have been in person. I don't
remember.
Q. At that point in time, he was a supervisor
above you in rank, correct?
A. He was always above me in rank.
Q. And was he recommending that they be put in
Narcotics?
A. No.
Q. Or kept in Narcotics?
A. No.
Q. Were they technically assigned to narcotics at
that time, when you had that conversation?
A. At that point they were detailed out. They
were out of the unit.

Page 40
1 conversation with Roti about Danny and Shannon not coming
2 back to Narcotics, do you know whether, on that CR, there
3 had been a finding on the CR? I believe we're talking
4 about the one regarding the dog, where you believe you
5 said where she stole the dog?
6

A. Essentially that's what I believe, yes.

7

Q. Had that CR come back with any type of finding

8 at the point you had conversation with Nick Roti?
9
10

A. Yes. It was sustained.
Q. Do you know if that CR being sustained was

11 upheld?
12

A. No. I didn't know.

13

Q. Were you aware that it was not upheld?

14

A. I learned subsequent later. Much later.

15

Q. And were you aware of what the recommended

16 punishment would have been in connection with the CR?
17

A. At the time I reviewed it, the punishment for

18 Shannon Spaulding was four days suspension. And I
19 believe for Echeverria, it was two.
20

I reviewed it carefully. I believe that the

21 punishment of four days was excessive.
22

I then recommended an alternate penalty that it

23 be reduced to two days for her, and then reducing it one
24 day for him.

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Q. You would agree that in terms of when you say
they were detailed out, were they detailed in a manner
that they were still technically assigned to Narcotics,
or that they were fully transferred to a different unit?
A. They were assigned to the Narcotics Division,
but detailed to another unit. So, no longer under my
command.
Q. Did Nick Roti have any position or tell you his
position on whether they should be returned to Narcotics?
A. I believe he concurred. He asked me, do you
want them back. I said no. And essentially he agreed
based on what he knew of them and that CR number.
Q. Have you ever given, as part of a discipline in
connection with a CR, that somebody be transferred out of
a unit, or their assignment?
A. I don't recall specifically.
Sometimes on occasion I reduced the penalty if
I thought the penalty was unjust. Sometimes I would
concur. Sometimes I wouldn't concur with the
investigation, but I don't recall...
I did ask on occasion that officers be
transferred out or detailed out. I don't remember if it
was associated with a CR number. I don't believe so.
Q. Do you know at the time that you had the

Page 41

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Q. When you say essentially Shannon stole a dog,
are you aware of whose dog it was?
MR. KING: Object to the form. At the time
he's reviewing it or-MR. SMITH: Any time.
THE WITNESS: I believe that it was -- the best
that I -- I don't recall the specifics. It was quite a
while ago.
Specifically it was Shannon's daughter's dog
that they gave to a gentleman who adopted the dog. And
at some point, Shannon decided she wanted the dog back,
or daughter wanted the dog back, and they then engaged
and on-duty member to go to the residence to essentially
threaten the guy with arrest if he didn't return the dog
to them.
MR. SMITH: Q. And do you know who the officer was
that allegedly threatened arrest?
A. My memory was that it was Officer Spaulding, or
I believe it was Officer Spaulding who at least implied
that there could be an arrest if the dog was not
returned.
Q. Were you aware of the relationship between her
daughter and the other individual who had possession of
the dog?

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A. I don't recall.
Q. Did you know that they were -- well, okay.
Did you ever find out why the suspension was
not enforced?
A. No.
Q. Did you ever find out why the finding was
reversed or vacated?
A. No.
Q. Did you ever talk with Nick Roti about the
incident again?
A. At some point I mentioned to Nick that that -it was one thing that Officer Spaulding had a problematic
reputation with the unit for me to learn that -- that CR
number really cemented the fact that I didn't want her
under my supervision.
Q. Was there any discussion or consideration of
having Danny come back to the unit without Shannon?
A. No. My impression was that they had come
together. I would have taken Officer Echeverria. Had he
contacted me, I would have taken Echeverria back.
Q. Did you in any way make that known to
Echeverria?
A. I've never spoken to Echeverria. He never
contacted me.

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They were in 189. I was a supervisor, but I
was in DEA at that time, so I never met them.
Q. So you weren't directly supervising them at
that time?
A. I never did, no.
Q. Did you review any of their internal reviews of
their performance before making a decision to recommend
they not be brought back to Unit 189?
A. No.
Q. When you reviewed the CR concerning the dog,
did you review their performance evaluations at that
time?
A. No.
Q. Have you ever reviewed any of their performance
evaluations, Danny's or Shannon's?
A. Yes.
Q. And when was that?
A. At some point subsequent to the filing of this
litigation, I found old evaluations in a file, a number
of them. And I was going through them, and I did in fact
find one for Shannon, from Lieutenant Navarro. The
direct supervisor was Sergeant Johnson.
And there was one in there for Shannon, I
believe, for Officer Spaulding as well as Echeverria.

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Q. Did you make that known to Chief Roti?
A. I don't recall if I said specifically that to
him or not.
Q. Were you aware that Spaulding and Echeverria
wanted to return to their unit assignment in 189?
A. No. They never spoke to me, either one of
them.
Q. Did Nick Roti in any way indicate to you that
they wanted to come back?
A. There was an inference there. He just asked
me, do you want them back in the unit and my opinion was
no. It was as simple as that.
Q. Did you ever consider the work that Danny and
Shannon were doing with the FBI as a factor in deciding
whether or not to bring them back to the Narcotics Unit,
189?
A. No. It didn't really play a role.
Q. Did you make any recommendation as to what
should be done with Danny and Shannon?
A. No. It was beyond my authority.
Q. At any point in time, were Danny or Shannon
actually active as members within Unit 189 when you were
a supervisor in Narcotics?
A. No. Well, I take that back.

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Q. And when would that have been?
A. May 2012, maybe.
Q. And why did you do that?
A. Because of this litigation, I knew there had to
be some type of paper trail regarding their old
evaluations, and I wanted to see if I could find them.
Q. And other than that evaluation, did you find
any evaluations regarding Danny or Shannon?
A. Those were the only ones I found.
Q. Were either of those evaluations good
evaluations?
A. His was okay. He was decent. Hers was
terrible. She was toxic.
Q. Do you know how long Shannon Spaulding worked
for -- well, who was the evaluator again?
A. Sergeant Johnson was the direct supervisor and
Lieutenant Kevin Navarro would have been the lieutenant.
Q. Do you know how long Shannon worked with
Sergeant Johnson?
A. No.
Q. Do you have any idea what instances
Sergeant Johnson saw Shannon perform in or do that led to
any negative evaluation?
A. No.

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Q. Did you ever talk with Sergeant Johnson about
that?
A. No.
Q. And when you were doing a search, did you come
across anything else that reflected negatively on Shannon
or Danny?
A. No.
Q. Did you search for the CR that you knew about,
the dog incident?
When you did that search, looking for
evaluations, did you also search for records about the CR
involving the dog and Shannon?
A. The only record that made available to me was
that CR number which was in my cue, we call it, online.
Once I hit "submit," it was out of -- there was no paper
trail then.
Q. So, that wasn't something that you had access
to at that point in time?
A. No.
Q. Did you come across any other papers that
involved Danny or Shannon at all?
A. No.
Q. Did you ever talk with other supervisors who
Shannon or Danny worked with?

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to him.
Q. Did you say anything in response to that?
A. I think he just agreed that was kind of odd.
Q. Did you think it was odd?
A. Yes.
Q. Why would you think that was odd?
A. Her characterization in the media that she was
working undercover on a corrupt police officer who knew
her, I thought that was kind of -- usually you don't -you can't go undercover and conduct operations on someone
who knows you, knows that you're a police officer.
You're not really undercover.
Q. Would you agree that if somebody didn't know
you were investigating them, that would be a form of
being undercover?
A. My interpretation of undercover is someone
doesn't know your identity, and you're conducting some
type of surveillance, or narcotics transaction, or some
type of an elicit activity. That to me is working
undercover.
Q. And were you aware of the timeframe that
Shannon Spaulding worked with Sergeant Watts at Public
Housing South?
A. No.

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A. I did speak to Sergeant Rod Watson.
2
Q. And who's Rod Watson?
3
A. He's a Narcotics Division sergeant.
4
Q. And when did you speak to him?
5
A. Sometime after the litigation was filed, I had
6
a discussion with him.
7
Q. And who else was present for the discussion?
8
A. I don't recall. I believe it was in the
9
hallway of the Narcotics Division.
10
Q. And did you approach him or did he approach
11
you?
12
A. I don't remember.
13
Q. And what was the discussion about?
14
A. Just about the allegations that she had made in
15
the media, about this case specifically. About her being
somehow damaged by her having worked in Internal Affairs. 16
17
Q. And what did he say?
18
A. He just thought it was ironic. My memory is,
19
he thought it was ironic that she's stating that she was
working undercover, when apparently his memory of it was 20
21
that Sergeant Watts knew her. They worked together in
22
the same building.
23
So, for her to say she was undercover working
on Sergeant Watts when he knew her didn't make any sense 24

Page 49

Q. Were you where it was years before the
investigation?
A. I don't have any details of it.
Q. Were you aware that Sergeant Watts had been
under investigation even before Shannon Spaulding and
Danny Echeverria started to work on the investigation?
A. I have no information whatsoever on
Sergeant Watts.
Q. Do you know who Officer Shar Khalid is?
A. Yes.
Q. And was Shar Khalid an individual who was
involved or accused of a domestic battery?
A. Yes.
Q. And do you know if he was convicted?
A. Criminally?
Q. Criminally.
A. I don't believe he was. Not to my knowledge.
Q. Do you know if there was a CR against him
related to the domestic battery charges?
A. Yes.
Q. And was there a finding regarding that CR?
A. I don't remember.
Q. Do you know if he was stripped, at some point
in time, of his badge or his gun during the course of the

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investigation?
A. I believe so. He was, yes.
Q. Did you allow Shar Khalid to continue, remain
working in Narcotics, even after he was stripped in
relation to that domestic battery CR?
A. I had no authority to determine where he was
assigned. He was assigned there.
Q. But did you allow them to continue to work with
you there?
A. Yes.
Q. Did you ask that he be transferred out of
Narcotics?
A. No.
Q. Did you think that the incident with Shannon
and the dog was more serious than the domestic battery
charge?
A. Well, first of all, at that point the
allegation against Shar Khalid had not been resolved.
I didn't know whether it was sustained or not sustained.
Secondly, Shannon was already away from my
unit. She wasn't in my unit and got the CR number. She
was out of my unit when she got the CR number.
So she was not under my control. It's apples
to oranges.

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open, so I didn't make a determination one way or the
other yet.
Q. Do you know a Sergeant Avery?
A. Yes.
Q. What is Sergeant Avery's first name, if you
know?
A. Vincent.
Q. Do you know an Officer Tony Hernandez?
A. Yes.
Q. Did you ever learn that Shar Khalid was
bragging about punching his wife in the face in front of
Sergeant Avery and Officer Hernandez?
A. I did not know that.
Q. Do you know Officer Hernandez, Tony Hernandez?
A. Yes.
Q. Did you ever ask Officer Tony Hernandez to
allow Khalid to work in his position so that Khalid could
remain in days and keep weekends off?
A. No.
Q. How do you know Tony Hernandez?
A. Tony Hernandez was an officer that was assigned
to the Narcotics Division during my tenure there as
commander.
Q. And were you aware that Tony Hernandez was an

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Q. Did you ever come to have an opinion of whether
the charges against Shar Khalid were -- let me re-ask the
question.
Did you ever have any opinions about the
seriousness of the charges against Shar Khalid?
A. I have an opinion. I didn't believe, based on
what I knew -- and obviously I was only hearing his side
of it.
But I knew that him and his wife were still
together, and they have a daughter together, and she was
supporting him. So, I didn't think there was any
substance to it.
My memory of it, which is not very good, was
that she was not the complainant against him. It was
some other individuals that he had arrested or had an
altercation with. They were the accusers against him.
Q. If somebody would have asked you whether you
thought Shar Khalid should remain in the Narcotics Unit,
would you have had an opinion one way or the other?
A. Yes, I have an opinion.
Q. What's the opinion?
A. I thought he was a good officer. He worked
well with his team members. He was very well-liked.
And to my knowledge, that CR number is still

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officer was assigned to a guard shack at one point in
time?
A. He was assigned to the 24 hour -- the security
detail at Homan Square. If you want to characterize it
as a guard shack, that's not really accurate.
Q. I mean, is that a phrase you would use, "guard
shack," in relation to his position?
A. He was assigned that number of positions within
Homan Square for the 24-hour security detail.
Q. And what positions would they have been?
A. Fillmore side security detail. There was the
Spaulding Street detail, and then the 24-hour desk.
Q. And was he under your command at that time?
A. Yes.
Q. Are you familiar with a Sergeant Padar?
A. Yes.
Q. How are you familiar with Sergeant Padar?
A. Sergeant Padar was one of the sergeants
assigned to the Narcotics Division during my tenure as
commander.
Q. And how long have you known Sergeant Padar?
A. From '08 until present.
Q. And did you become aware that Sergeant Padar
was being criminally investigated at some point?

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A. Yes.
Q. And when did you become aware that
Sergeant Padar was being criminally investigated for?
A. Sometime in 2014, I believe.
Q. What did you find out that he was being
criminally investigated for?
A. Some issue on testifying at a criminal
proceeding. I was already gone from the Chicago Police
Department at that point.
Q. Were you ever made aware that there was CR
against Sergeant Padar relating to falsifying records in
connection with Tony Hernandez?
A. Yes.
Q. When did you become aware of that?
A. During my tenure as commander.
Q. And after you found out about that CR, you
continued to allow Padar to work with you, underneath
you, in your command?
A. Yes.
Q. Were you aware of any allegations made against
a Sergeant Mel Roman while you were working as a
commander in Narcotics?
A. No.
Q. Do you know who a Tracy walker is?

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some of the time period in which Lewellyn was
investigated and charged? Were you aware of that?
A. I don't believe that he was his partner.
Q. In terms of on the team.
A. I believe he was on the same team, yes.
Q. Do you know who a Sergeant Herrera is?
A. Yes.
Q. Was he a sergeant who came to be assigned to
Narcotics?
A. Yes. He was from Internal Affairs.
Q. Did you ever talk with Chief Juan Rivera about
a Sergeant Herrera?
A. Yes.
Q. What circumstances did you talk with
Chief Rivera about Sergeant Herrera?
A. I don't recall when, but Chief Rivera asked me
if Sergeant Herrera could be assigned to the Narcotics
Division, and I was happy to have him.
Q. And do you know what the circumstances of that
situation was, why Rivera came to you?
A. First, I don't believe he came to me. I think
it was a phone call.
My memory is that Sergeant Herrera wanted to
return to Narcotics because that was first love and he

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A. I know who she is. I'm not really clear I
remember hearing the name. I don't know her.
Q. If I told you she might be an officer in
Narcotics, would that ring any bells?
A. I don't believe she's in Narcotics. Not to my
memory.
Q. Were you aware that she made allegations that
she was being sexually harassed by a Sergeant Mel Roman?
A. No.
Q. Did you have any role in promoting a
Lieutenant Noel Sanchez?
A. Yes.
Q. Were you aware if he was ever a subject of a
Federal criminal investigation?
A. I'm not sure of the details. I remember that
he was -- somehow he worked with an officer that was
under investigation. I'm not sure if Noel himself was
the subject of an investigation or not.
Q. And that person was Officer Glen Lewellyn
(phonetic spelling)?
A. Yes.
Q. Who is serving 18 years in a Federal prison?
A. Yes.
Q. And was a partner on the team with Lewellyn for

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had a passion for it.
And he had served with distinction in Internal
Affairs, and wanted to come back to the Narcotics
Division.
Q. Did you have a pending CR at the time you had
that conversation with Juan Rivera?
A. Did I have a pending CR?
Q. Correct.
A. I don't remember if I did or not.
Q. You've had CRs, correct?
A. Yes.
Q. How many CRs have you had, approximately?
A. In my career?
Q. Yes.
A. I don't know. I couldn't even tell you.
Q. Is it more 10?
A. Yes.
Q. Is it more than 20?
A. Probably.
Q. Is it more than 30?
A. I'm not sure.
Q. Is it less than 50?
A. Probably.
Q. Have you ever had any CRs sustained against

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Page 58
1 you?
2

A. No.

3

Q. Have you ever been suspended or disciplined in

4 any way as a Chicago police officer?
5

A. I think I might have taken a day suspension for

6 not having a City sticker on my new wife's car, my wife's
7 car.
8

We had just gotten married, and I drove her car

9 to work, not thinking, and she didn't have a City
10 sticker.
11

Q. Do you know how many CRs Shannon Spaulding has

12 against her?
13

A. No.

14

Q. Do you know if it's more than 10?

15

A. I have no idea.

16

Q. Did you ever investigate any complaint made by

17 any of your command staff in Narcotics against either
18 Shannon Spaulding or Danny Echeverria?
19

A. No.

20

Q. And I believe you mentioned that you learned of

21 a...
22
23

(Brief pause.)
Did Chief Rivera ever release to you any

24 confidential information regarding any investigations

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career.
Q. Did you ever become aware that Shannon and
Danny Echeverria never were assigned to IAD?
A. No. I have no idea.
Q. Did anyone ever tell you they were assigned to
IAD, Internal Affairs Division?
A. I was under the impression they were assigned
or detailed there.
Q. Who told you they were detailed there?
A. I don't recall. Probably Chief Roti.
Q. Were you aware of any situations where officers
had gone to the FBI and reported police corruption
outside of the chain of command?
A. I don't personally recall that, no.
Q. Were you aware of any situations where officers
within the Chicago Police Department decided to go to the
FBI when supervisors were not investigating reported
corruption?
A. In my experience, anytime police corruption has
been reported to a supervisor, they have taken
appropriate action. That's my understanding and
recollection.
Q. How would you be able to know that?
A. It's my impression and recollection that any

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regarding Chicago police officers?
A. No.
Q. Do you believe that you became aware that
Spaulding and Echeverria were involved in a confidential
investigation involving police corruption?
A. Can you repeat the question, please?
Q. Do you believe, before the lawsuit, that you
were aware that Spaulding and Echeverria were involved in
a confidential investigation involving police corruption?
A. Yes.
Q. Did you think it could be a problem to have an
officer in Narcotics who was involved in investigating
undercover corruption?
A. Well, considering I worked in Internal Affairs
working corruption cases. Sergeant Herrera worked in
Internal Affairs on corruption cases.
Sergeant Noel Sanchez, who then I assisted in promoting
to lieutenant, worked in Internal Affairs on police
corruption cases.
Lieutenant Karen Kono, who ran the
investigations on police officers, I requested her
specifically to work for me.
So I would say I had no problem with anyone
having worked in Internal Affairs at anytime in their

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cases that came to me, I forwarded, and cases that came
to my similar-ranking officers did the same.
Q. Would you expect an officer who was assigned to
you to report corruption directly to you rather than go
to an outside agency?
A. I always expect officers who work for me to
follow the chain of command, yes. They should be
reported to the supervisor.
Q. If an officer who saw drug dealing or extortion
being committed by a fellow Chicago police officer did
not go to their supervisors, would you think that was a
problem?
A. Yes.
Q. If they chose to go to an outside agency
instead of a supervisor, would that be a problem?
MR. KING: Just object to form and the word
"problem," but you can answer.
THE WITNESS: They should follow the directives
of the Chicago Police Department and notify the chain of
command -- obtain a CR number and notify the chain of
command so they can protect the department and other
officers.
MR. SMITH: Q. Why would you feel that going to an
outside agency would somehow jeopardize the department or

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other officers?
A. If you have a corrupt police officer actively
involved in narcotics or gang involvement, then not only
are you placing the general public at risk, because
obviously an officer has access to information and arrest
powers, you're exposing other officers, the officers that
work with them on a daily basis -- officers that are
encountering them. You're placing everyone in jeopardy.
Q. Would it surprise you that Officer Watts was
engaged in narcotics distribution and sales for over 10
years while he was a Chicago police officer, without the
Chicago Police doing anything to discipline or take him
off the force?
MR. KING: Object to the form, and lack of
foundation.
THE WITNESS: I don't know Sergeant Watts.
MR. SMITH: Q. Did you ever receive a confidential
informant packet from a Sergeant Padar?
A. Yes.
Q. Did you ever receive a confidential information
packet that included Shannon Spaulding and
Danny Echeverria's name on it?
A. Yes.
Q. Did you have a conversation with Sergeant Padar

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them stay within the Narcotics Division?
A. This was before I had that conversation with
Roti, to the best of my memory.
Q. So weren't they technically still within the
Narcotics Division at that point in time?
A. I don't believe they were.
Q. What did you believe they were doing?
A. I believe they were detailed out of the unit,
out of Organized Crime. They weren't working in
Organized Crime.
Q. And what did you believe they were doing?
A. I had no idea what they were doing.
Q. And so what made you believe that they couldn't
work with confidential informants?
A. I don't care if they worked with confidential
informants.
Q. So what exactly was the problem that you had
with Danny and Shannon seeking a confidential informant
approval, request for approval for a confidential
informant?
A. No problem at all. However-Q. I would ask that counsel not gesture to the
witness to make further statements.
Did you ever direct Sergeant Padar to inform

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regarding their request -- and by their, I mean Danny and
1
Shannon's request for approval for a CI?
2
A. Yes.
3
Q. What did that conversation entail?
4
A. First of all, I informed Sergeant Padar that
5
Officer Shannon Spaulding and Danny Echeverria were not 6
working in the Organized Crime Division. Therefore, they 7
should not be signing up informants.
8
Secondly, I looked at the documents. And
9
Officer Hernandez, who was in fact assigned to the
10
Narcotics Division, wasn't on there, at least one of
11
documents that I reviewed.
12
Q. What do you mean by that in terms of, he wasn't
13
on? Or-14
A. His name was not included on one of the pages
15
of the CI, the package.
16
Q. Why would that be a problem or an issue?
17
A. Because they don't work for me.
18
Shannon Spaulding and Danny Echeverria were not working 19
in the Organized Crime Division. They're not authorized
20
to sign up informants in the Organized Crime Division if
21
they're not working in the Organized Crime Division.
22
Q. And when was that? Was that before or after
23
your conversation with Deputy Chief Roti about having
24

Page 65

Spaulding and Echeverria what you thought of their
request for approval of a CI?
A. I told Sergeant Padar that if his team wanted
to work with Shannon Spaulding and Danny Echeverria, I
did not have a problem with it, but their supervisors
needed to contact me, because apparently no one knew what
she was doing.
Q. And did Sergeant Padar say anything in response
to that?
A. He said okay.
Q. Did you approve the request for a CI?
A. I couldn't. They don't work for me.
Q. Do you know if anyone did approve the request
for a CI?
A. To clarify, anyone can work with informants,
Internal Affairs.
However, to assign an informant up with the
Organized Crime Division, you have to work in the
Organized Crime Division. They were not working in the
Organized Crime Division, Echeverria or Spaulding.
Neither one of them was working in the Organized Crime
Division. Therefore, they could not sign up an informant
in the Organized Crime Division.
They're more than free to sign up an informant

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with any other -- Detective Division, Internal Affairs,
whatever.
When I was in Internal Affairs, I was not
allowed to sign up informants in the Organized Crime
Division because I was not working in the Organized Crime
Division.
Q. Do you know if that particular confidential
informant was approved to work with any other unit or
division?
A. I have no idea.
Q. Would Sergeant Padar...
(Brief pause.)
Did you ever instruct supervisors or officers
within Narcotics not to work with Spaulding and
Echeverria?
A. Honestly, just the opposite.
I told Sergeant Padar I had no problem with him
working with Spaulding and Echeverria, if it was
assisting in their investigation, if their supervisors
knew what they were doing and would contact me.
Q. Did you have any conversations with anyone
other than Sergeant Padar within Narcotics as to
Spaulding and Echeverria?
A. No.

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called for help, that the members of Unit 189 would not
be there to back them up?
A. I doubt very highly that ever happened. I have
no knowledge of that whatsoever.
Q. If you had become aware of a statement like
this being made, what actions would you have taken?
A. I probably have initiated a CR number on the
supervisor who made that statement. It's totally
inappropriate.
Q. Did you ever issue an order, either verbal or
written, that Spaulding was not allowed in the Homan
Square building?
A. No.
Q. Do you know whether or not Spaulding had a
locker in the Homan Square building?
A. I don't know.
Q. Did you ever call Lieutenant Cesario and tell
him that Spaulding was not allowed in Homan Square?
A. I don't believe I did, no.
Q. Did you ever tell any member of the Fugitive
Apprehension Unit that Spaulding was not allowed in the
Homan Square building?
A. I never said that.
Q. Did you ever tell Lieutenant Cesario that

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Q. So in your view, who would have been Shannon
and Danny's chain of command supervisors who could
approve a confidential informant working with a unit at
that time?
A. Whatever unit they were working under.
At that point, Shannon Spaulding and
Danny Echeverria had a chain of command. They had some
type of supervision.
They should have gone through that proper chain
to work with that informant.
Q. Did you know who that was?
A. No. They never called me.
Q. Did anyone ever tell you who that was?
A. No.
Q. Did anyone ever tell you that they weren't
under your chain of command?
A. I knew they weren't under my chain of command.
Q. When somebody is loaned out from a unit to
another detail, whose chain of command is that under?
A. They'd follow the chain of command of the
person they're detailed to, or the unit they're detailed
to.
Q. Were you aware of any of the supervisors in
your unit telling Spaulding and Echeverria that if they

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Shannon Spaulding should not go to any part of the Homan
Square building?
A. I never said that.
Q. Did you ever give any directive to anyone
relating to that Shannon Spaulding be allowed to -- let
me re-ask the question.
Did you ever tell anyone that Shannon Spaulding
should not be or should be restricted from going to any
part of Homan Square?
A. I did contact Commander Salemi and asked him if
Shannon Spaulding was at Homan Square on a specific date,
if she was working and if she was doing some type of
police work. He said no, on this specific date.
I said, well, she's over here goofing off,
visiting her boyfriend, are you aware of it. He said no,
and that he would handle it.
Q. Did you ever indicate to Commander Salemi that
Spaulding shouldn't be visiting her boyfriend at Homan
Square?
A. I did tell him unless she was there for a
proper police purpose, she shouldn't be in a restricted
area.
Q. Did you tell him that she should not be at the
restricted area of Homan Square?

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A. Yes. She should not be at the restricted area.
Q. And did you any way limit this -- strike that.
What's the address of Homan Square?
A. 3340 West Fillmore.
Q. Is this in any way a restricted access
building?
A. Yes.
Q. How so?
A. The general public can't walk into the
building, and only officers allowed in the Organized
Crime or for a proper police purpose are allowed on the
2nd floor.
And the east parking lot is restricted to
undercover officers and supervisors only.
Q. And is there an identification system in place
to determine what officers are allowed to go into the
Home Square building?
A. The general building, any police officer can go
into it. However, the 2nd floor is where the Narcotics
Division and the Gang Intelligence Unit are located.
That's restricted by keypad on -- that would be the south
side of the building and then on the 24-hour desk.
There's an officer assigned there to challenge
anyone that comes up to the 2nd floor.

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Q. How would the word get out that officers
weren't supposed to go to the east parking lot?
A. They would be challenged.
If someone tried to walk in -- the license
plates of authorized vehicles are encoded into the
system. Where an undercover officer that is assigned to
Narcotics or Gang Intelligence would pull up, it would
read the plate and let them in.
Q. Did you ever see Shannon Spaulding inside the
east parking lot?
A. No.
Q. Did you ever see Shannon Spaulding internally
at Homan Square?
A. I've never seen her. I've never met her.
Q. How was it that you came to know that she was
at Homan Square?
A. Somebody informed me, I don't recall who, that
Officer Hernandez had left his assigned post and was
visiting his girlfriend, Shannon Spaulding, in the area
where she was not supposed to be.
Q. And you don't remember who that was?
A. No.
Q. Did you ask Tony Hernandez if that was true?
A. Yes.

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Q. Do you know if Shannon Spaulding had access to
that 2nd floor?
A. She shouldn't have, but I don't know if she
did.
Q. Do you know if she was allowed to be in the
building generally?
A. Sure.
Q. And was there any restriction that would have
been placed on her that -- was there any area, other than
the 2nd floor, she would much restricted from going to?
A. She should not have been in the east parking
lot.
Q. And was there any written directive relating to
officers not being allowed in the east parking lot?
A. I'm not sure if it's in writing somewhere.
It's the policy of -- the Deputy Chief of Organized Crime
is in charge. He's basically the landlord of the
building.
And it was the policy not allow anyone other
than authorized officers, undercover officers, to go in
that east parking lot.
There was a guardrail, and there's an officer
assigned there always to verify the identify of anyone
who came through.

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Q. And what did Mr. Hernandez say,
Officer Hernandez say?
A. She was his girlfriend and she was dropping
something off to him.
Q. Did he say she was in the restricted area?
A. I'm sorry?
Q. Did he say she was in the restricted area?
A. He did not say that, no.
Q. Did you ask him.
A. No. I didn't have to.
Q. Did you make any effort to contact
Shannon Spaulding to determine whether, to let her know
that she was doing something that she wasn't supposed to
do?
A. No. I contacted her supervisor.
Q. Was this in any way documented?
A. Yes.
Q. How so?
A. I documented in the Departmental Evaluation
System regarding Officer Hernandez visiting his
girlfriend when he was supposed to be working.
Q. And when did you do that?
A. I believe that day or the day after.
Q. Have you seen that document in connection with

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this litigation?
A. In this litigation, no.
Q. What documents did you review before this
deposition, if any?
A. I did in fact review the command channel review
for the CR number where it indicated I reduced the
penalty against Shannon Spaulding from four days to two
days, and reduced the penalty on Danny Echeverria from
two days to one day.
I knew it existed, and I spoke to counsel
regarding that.
Q. Did you talk to Mr. Hernandez about -- did you
tell Mr. Hernandez that he shouldn't meet with
Shannon Spaulding at Homan Square?
A. I don't believe her name specifically came up.
I said, you're not supposed to be visiting your
girlfriend while you're working, and you're not supposed
to leave your assigned post unless your supervisor knows
about it.
Q. Was there any indication of how long
Shannon Spaulding was with Mr. Hernandez on that
occasion?
A. No, I don't believe so. I don't recall.
Q. Was there any inquiry done as to, did you ask

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A. No.
Q. Did your kids ever attend school in Park Ridge?
A. Yes.
Q. Were you living in Park Ridge at that time?
A. No.
Q. Is that a private school?
A. Yes. St. Paul of the Cross grade school.
Believe me, I've got the receipts to prove it.
Q. Did you ever send your children to any suburban
public school?
A. Ever?
Q. Yes.
A. Yes.
Q. While you were a Chicago Police Department
officer?
A. Yes.
Q. How did you make those arrangements?
A. I owned a condo in the 1400 block of Touhy in
Park Ridge, Illinois, and my father-in-law lived at that
location with my daughter.
Q. And did you list that address as their
residence?
A. That was listed as his. He lived there. That
was his residence.

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Mr. Hernandez how long she was there for?
A. No. He admitted though that he had left his
post without supervisory approval.
Q. How far from his post did he go?
A. I don't recall.
Q. Is IAD allowed on the 2nd floor in Homan
Square?
A. They are allowed, but they have to be checked
in. They can't just walk in off the street, if that's
what you're asking.
Q. Did you ever tell Tony Hernandez that if
Shannon Spaulding returned to the building at Homan
Square, he was to arrest her?
A. No, I did not.
Q. You aware of the residency requirements for the
Chicago Police Department?
A. Yes.
Q. When you were a commander in CPD, were you
aware of the school district you lived in?
A. The school district I lived in?
Q. Yes.
A. I believe it was Ebinger.
Q. Did you ever falsify your address to send your
kids to Park Ridge?

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Q. As your children's residence?
A. My oldest daughter, yes, she lived there, you
know, when she was in high school, the last year of high
school.
Q. Did you go to law school?
A. Yes.
Q. And what law school did you go to?
A. John Marshall.
Q. Were you going to law school while you were
working as a Chicago police officer?
A. Yes.
Q. Did you ever take classes during your hours as
a Chicago police officer?
A. No.
Q. Are you familiar with orders from the Chicago
Police Department and the City of Chicago relating to
whistle blower rules?
A. Not specifically.
Q. Have you ever spoken with Nick Roti about
Shannon Spaulding -- I'm sorry. I believe we already
brought that up.
Have you ever spoken with anyone other than
Nick Roti about Shannon Spaulding or Danny Echeverria
being involved or working with the FBI?

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A. No.
Q. Were you ever present at any meeting where a
discussion of where Danny and Shannon were assigned was
brought up?
A. Never.
Q. Were you ever present in any meeting where
Danny and Shannon working with the FBI was brought up?
A. Never.
Q. Did you ever tell anyone, other than
Deputy Chief Roti, that you didn't want Danny or Shannon
back in your unit?
A. No.
Q. Did you think that not bringing Danny or
Shannon back to your unit might hurt their careers?
A. No, not at all.
Q. Do you know if Sergeant Padar was ever stripped
for any alleged felony criminal act?
A. Yes, he was stripped.
Q. Do you know if this occurred while you were
still commander of Narcotics?
A. No, it was not then.
Q. Were the allegations concerning his criminal
acts, did they occur while you were his commander?
A. I don't know.

Page 80
1 allegations against another sworn member?
2

A. Not specifically, no.

3

Q. Were you aware of any general order that

4 protects members of CPD who make complaints or
5 allegations against another sworn member when you were
6 working in IAD?
7

A. I don't remember. That was many years ago.

8

Q. Were you aware of a general order that

9 protected whistle blowers when you were working IAD?
10

A. No.

11

Q. Were you aware of a general order that protects

12 a member of CPD who makes a complaint or allegations
13 against another sworn member when you were the commander
14 of Narcotics?
15

A. I don't recall it specifically, no.

16

Q. Are you aware of any employee rights that

17 protect whistle blowers?
18

A. As far as an attorney or as far as general a

19 order?
20

Q. In terms of within the CPD, the Chicago Police

21 Department?
22

A. Like specific provisions or general orders, no.

23

Q. Would you have knowledge of how -- I'm sorry.

24

(Brief pause.)

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Q. How did you become aware of the criminal
allegations regarding Padar?
A. I believe I read it in the paper.
Q. Do you know if any other sworn members working
under your command were also accused, together with
Padar?
A. Of the criminal act?
Q. Yes.
A. Yes.
Q. Who?
A. Vince Morgan.
Q. And how did you learn about that?
A. I read it in the paper.
Q. Did you take any action when you learned of
these allegations?
A. I told my wife.
Q. Were you still a commander at that point?
A. No.
Q. Are you aware of a specific general order that
protects whistle blowers within the Chicago Police
Department?
A. No.
Q. Are you aware of any general order that
protects a member of CPD who makes a complaint or

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MR. SMITH: If I could have just a few minutes,
and I'm pretty sure we'll be less than 15 minutes, but
I'm probably going to go through names.
(Brief recess.)
MR. SMITH: Q. Do you know a Jan Hanna?
A. No.
Q. Do you know a Kevin Sadowski?
A. No.
Q. Do you know a Lieutenant Deborah Pasqua?
A. No.
Q. Do you know a Commander Adrienne Stanley?
A. I do know her, yes.
Q. How long have you known her?
A. Probably met her in '08 when I first made
commander, and we went to meetings together. I've never
really -- I don't really know her well at all.
Q. Do you know a Sergeant Maurice Barnes?
A. Yes.
Q. How do you know Sergeant Maurice Barnes?
A. Sergeant Barnes and I worked together in the
Narcotics Division, I believe, when I was a police
officer.
Q. And did you work on the same team or just in
the same unit?

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A. In the same unit.
Q. And do you know a Lieutenant Robert Cesario?
A. I know him. I spoke to him a couple of times,
and I was involved with the Chicago Police Memorial
Foundation. I presented a check to his family for his
brother who had cancer, I believe.
But I don't know him really well. I met him a
couple of times.
Q. Do you know Joseph Salemi?
A. Yes.
Q. How long have you known Joseph Salemi?
A. Approximately 15 years.
Q. And are you personal friends?
A. I don't see him socially. However, as
commanders at one time we were both in Investigative
Services, Narcotics, the Detective Division. We went to
the same meetings together.
I'm certainly friendly with him. I would
consider him a friend, but I don't see him socially.
Q. Do you know Thomas Mills, a sergeant?
A. Yes.
Q. How do you know Sergeant Mills?
A. Sergeant Mills and I worked together in
Narcotics.

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Q. Did you ever talk with Joseph Salemi about the
lawsuit itself?
A. Not specifically.
Q. Did you ever talk with Robert Cesario about the
lawsuit?
A. No, not at all.
Q. Did you ever talk with Robert Cesario about
either Danny or Shannon?
A. I don't believe so.
Q. Did you ever talk with Sergeant Barnes about
Shannon or Danny?
A. No.
Q. Did you ever talk with Sergeant Barnes about
the lawsuit?
A. No.
Q. Did you ever talk with Adrienne Stanley about
the lawsuit?
A. Not at all, no.
Q. Did you ever talk with Adrienne Stanley about
Shannon or Danny?
A. No.
Q. I think you said you didn't know
Deborah Pasqua.
A. No.

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Q. Have you ever spoken to Thomas Mills about
Danny or Shannon?
A. No.
Q. Have you ever spoken to Thomas Mills about that
this lawsuit?
A. I might have mentioned it, that it was, you
know, that this lawsuit was filed.
Q. Did he say anything about the lawsuit?
A. How sad he was. He just kind of, you know,
bothered by it.
Q. Anything beyond that?
A. Not really.
Q. Did you discuss any details of the allegations
n the lawsuit with Thomas Mills?
A. No.
Q. Were you friends with Thomas Mills?
A. I would say yes, he's a friend. I don't see
him socially, but I certainly consider him a friend.
Q. The time you spoke to him about the lawsuit,
where was that?
A. I don't remember. Maybe at a police function.
Q. Were you still a police officer with Chicago at
that time?
A. I believe, yes.

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Q. And you didn't know Kevin Sadowski?
A. No.
Q. We may have already talked about something with
Nicholas Roti, but did you ever talk with Nicholas Roti
about the lawsuit?
A. Yes.
Q. Did you ever talk to him about the specifics in
the lawsuit?
A. Some of the allegations.
Q. Which allegations?
A. Specifically that I would refer to anyone
having worked in Internal Affairs as being rats.
Having spent a very important part of my career
in Internal Affairs, it really bothered me personally.
Q. Any other allegations that you talked to him
about?
A. Nothing specific.
Q. When you talked about the lawsuit, did you
discuss the incident concerning Homan Square at all with
Nicholas Roti in terms of Shannon Spaulding visiting
Tony Hernandez?
A. I spoke to Nick, Chief Roti, on a daily basis.
I'm sure I mentioned to him that I contacted
Commander Salemi to inform him one of his officers was

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goofing off.
Q. And would that have been at the time shortly
after it happened or when you were talking about the
lawsuit?
A. Probably shortly thereafter, to the best of my
memory.
Q. Shortly after the incident itself?
A. Correct.
Q. Have you talked to Deborah Kirby about the
lawsuit?
A. No, not at all.
Q. And I think you already indicated you didn't
talk to Juan Rivera about the lawsuit?
A. No.
Q. I am correct, you did not talk to him?
A. No, I did not.
Q. Have you ever talked to Deborah Kirby about
Shannon Spaulding or Danny Echeverria?
A. No.
Q. Now, do you know Jimmy Jackson?
A. Yes, sir. Yes, I know him.
Q. Who has been a high-ranking member in the
Chicago Police Department?
A. Yes.

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criminal act, he's got to -- he has to take police
action. He should, if necessary, make an arrest.
Q. Okay. So, they should report it under their
chain of command and potentially make an arrest, is that
your...
A. Yes.
Q. Hypothetically speaking, if that circumstance
occurs, an officer reports another officer through their
chain of command, if the reporting officer, for whatever
reason, doesn't feel the response is appropriate, do you
have any problem with that reporting officer then going
outside of the Chicago Police Department to a third party
law enforcement agency, such as the FBI?
A. Not at all, as long as they follow the
protocols initially as they're required to do, whatever
step they feel necessary to safeguard the department is
fine with me.
MR. KING: No further questions.
FURTHER EXAMINATION
BY MR. SMITH:
Q. Do you know any instances where that's
occurred?
A. Not personally, no.
Q. What would be a sufficient amount of activity

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Q. Is he still with the Chicago Police Department,
if you know?
A. No.
Q. How long did you know him?
A. From at least from 1999 on. So, 15 years.
Q. Did you ever discuss Sergeant Watts with
Jimmy Jackson?
A. No. I don't know Sergeant Watts.
Q. And have you ever talked with Jimmy Jackson
about Shannon Spaulding or Danny Echeverria?
A. Never.
MR. SMITH: Nothing further.
MR. KING: I have a couple of questions.
EXAMINATION
BY MR. KING:
Q. Mr. O'Grady, counsel was asking you some
questions earlier in the deposition about, if a police
officer observed or witnessed another police officer
potentially engaging in illegal conducts.
I think you indicated that you would expect
them to report that internally within CPD through the
chain of command; is that correct?
A. Yes. However, that doesn't preclude them from
-- if an officer observes another officer commit a

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within your chain of command if you saw an officer
engaged in criminal action, for an officer to take before
going to outside agency, in your opinion?
A. In my opinion, if an officer witnessed a
criminal act, he has to take proper police action. That
very well could be, make an arrest or intercede.
If one of my teams was out there conducting a
narcotic surveillance, and a subject was engaged in a
narcotics transaction, and they knew that subject to be a
police officer, they wouldn't merely file a report.
They'd have to make an arrest.
Q. Okay.
A. And officers in the division have arrested
police officers before.
Q. Let's take it back a notch.
If an officer gets seemingly strong evidence
that another police officer is engaged in a crime, and
they, according to you, are then supposed to go to their
supervisor to report, that would that be fair to say, if
they can't make an arrest at the time?
A. Then they should definitely report and obtain a
CR number, see that a CR number is obtained.
Q. And to what extent would you believe they would
have to go internally before they should go to an outside

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agency?
A. Well, any officer can get a CR number at any
time. All you have to do is pick up the phone and call
Internal Affairs or IPRA and obtain the CR number.
So, there's no -- it doesn't eliminate that
duty. They're required to obtain a CR number, but they
should go through the chain of command. They should
notify a supervisor.
Q. If they notify their immediate supervisor, and
the immediate supervisor did not obtain a CR, do you
think they would be in a position to then go to an
outside agency?
A. They should still obtain the CR number
themselves. They don't need a supervisor to get the CR
number. They should get the CR number themselves.
Q. Do you think that would be a problem if they
didn't get the CR number themselves?
A. If they didn't get a CR number, that would
definitely be a problem.
Q. If they had suspicions that the police
department wouldn't take any action, would you believe it
would be okay to go to the outside agency at that point?
A. If that officer subjectively felt that that was
the only way to safeguard the police department and the

Page 92

1 STATE OF ILLINOIS )
) SS.
2 COUNTY OF C O O K )
3
4
I, THOMAS A. MANNO, C.S.R. and Notary Public,
5 do hereby certify that I reported in machine shorthand
6 the testimony held at the deposition of JAMES O'GRADY
7 taken on March 5th, 2015, and that this transcript is a
8 true and accurate transcription of my machine shorthand
9 notes so taken to the best of my ability, and contains
10 all of the proceedings given at said deposition.
11
12
______________________
THOMAS A. MANNO, C.S.R.
13
License No. 84-001174
14
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well-being of the general public, yes. I have no
problem.
I worked with the FBI myself. I worked with
DEA myself. So I have no problem with them going to
outside agencies.
Q. When you worked with the FBI and the DEA
agencies, that was within your job as a Chicago police
officer within the Chicago Police Department, correct?
A. Correct.
Q. You weren't going to them outside of your work
at the Chicago Police Department to report-A. No.
MR. SMITH: Nothing further.
MR. KING: Okay. We'll reserve.
(The deposition ended at 11:52 a.m.)

Page 93
1

Veritext Legal Solutions
1 North Franklin Street - Suite 3000
Chicago, Illinois 60606
Phone: 312-442-9087

2
3
4

May 22, 2015
5
To: Alan S. King
6
Case Name: Spaulding, Shannon, et al. v. City Of Chicago, et al.
7
Veritext Reference Number: 2026015
8
Witness: James O'Grady
9
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Deposition Date: 3/5/2015

Dear Sir/Madam:
Enclosed please find a deposition transcript. Please have the witness
review the transcript and note any changes or corrections on the
included errata sheet, indicating the page, line number, change, and
the reason for the change. Have the witness’ signature at the bottom
of the sheet notarized and forward errata sheet back to us at the
address shown above, or email to production-midwest@veritext.com.
If the errata is not returned within thirty days of your receipt of
this letter, the reading and signing will be deemed waived.

Sincerely,
Production Department

24 (Pages 90 - 93)
Veritext Legal Solutions
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888-391-3376

 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 75 of 191 PageID #:983

Page 94
1

DEPOSITION REVIEW
CERTIFICATION OF WITNESS

1

2
ASSIGNMENT NO: 2026015
3 CASE NAME: Spaulding, Shannon, et al. v. City Of Chicago
DATE OF DEPOSITION: 3/5/2015
4 WITNESS' NAME: James O'Grady
5
In accordance with the Rules of Civil
Procedure, I have read the entire transcript of
6 my testimony or it has been read to me.
7
I have made no changes to the testimony
as transcribed by the court reporter.
8
_______________
________________________
9 Date
James O'Grady
10
Sworn to and subscribed before me, a
Notary Public in and for the State and County,
11 the referenced witness did personally appear
and acknowledge that:
12
They have read the transcript;
13
They signed the foregoing Sworn
Statement; and
14
Their execution of this Statement is of
their free act and deed.
15
I have affixed my name and official seal
16
this ______ day of_____________________, 20____.
17
___________________________________
18
Notary Public
19
___________________________________
Commission Expiration Date
20
21
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25

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Page 96
ERRATA SHEET
VERITEXT LEGAL SOLUTIONS MIDWEST
ASSIGNMENT NO: 2026015
PAGE/LINE(S) /
CHANGE
/REASON
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________

_______________
________________________
20 Date
James O'Grady
21 SUBSCRIBED AND SWORN TO BEFORE ME THIS ________
22 DAY OF ________________________, 20______ .
23
___________________________________
Notary Public
24
___________________________________
25
Commission Expiration Date
Page 95

1

DEPOSITION REVIEW
CERTIFICATION OF WITNESS

2
ASSIGNMENT NO: 2026015
3 CASE NAME: Spaulding, Shannon, et al. v. City Of Chicago
DATE OF DEPOSITION: 3/5/2015
4 WITNESS' NAME: James O'Grady
5
In accordance with the Rules of Civil
Procedure, I have read the entire transcript of
6 my testimony or it has been read to me.
7
I have listed my changes on the attached
Errata Sheet, listing page and line numbers as
8 well as the reason(s) for the change(s).
9
I request that these changes be entered
as part of the record of my testimony.
10
I have executed the Errata Sheet, as well
11 as this Certificate, and request and authorize
that both be appended to the transcript of my
12 testimony and be incorporated therein.
13 _______________
________________________
Date
James O'Grady
14
Sworn to and subscribed before me, a
15 Notary Public in and for the State and County,
the referenced witness did personally appear
16 and acknowledge that:
17
They have read the transcript;
They have listed all of their corrections
18
in the appended Errata Sheet;
They signed the foregoing Sworn
19
Statement; and
Their execution of this Statement is of
20
their free act and deed.
21
I have affixed my name and official seal
22 this ______ day of_____________________, 20____.
23
___________________________________
Notary Public
24
___________________________________
25
Commission Expiration Date

25 (Pages 94 - 96)
Veritext Legal Solutions
www.veritext.com

888-391-3376