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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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CHICAGO POLICE OFFICER

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SHANNON SPALDING and

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CHICAGO POLICE OFFICER

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DANIEL ECHEVERRIA,

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Plaintiffs,

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-vs-

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No. 12 C 8777

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CITY OF CHICAGO, et al

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Judge Feinerman

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Defendants.

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The deposition of LIEUTENANT JUAN RIVERA,

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taken pursuant to the Federal Rules of Civil Procedure

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of the United States District Courts pertaining to the

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taking of depositions, taken before CHRISTINE

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LIUBICICH, Certified Shorthand Reporter of the State of

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Illinois, at One North LaSalle Street, Suite 3040

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Chicago, Illinois, on Thursday, December 4, 2014, at

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1:00

p.m.

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1 APPEARANCES:
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CHRISTOPHER SMITH TRIAL GROUP
One North LaSalle Street
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Suite 3040
Chicago, Illinois 60602, by
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MR. CHRISTOPHER SMITH
office@crstrialgroup.com
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appeared on behalf of Plaintiffs;
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DRINKER BIDDLE & REATH LLP
191NorthWacker Drive
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Suite 3700
Chicago, Illinois 60606-1698, by
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MR. ALAN S. KING
Alan.King@dbr.com
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appeared on behalf of Defendants.
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ALSO PRESENT:
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SHANNON SPAULDING.
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18 REPORTED BY CHRISTINE LIUBICICH, CSR.
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Exhibit No. 16 E-mail ......................136
Exhibit No. 17 E-mail ......................137

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1
INDEX
2 WITNESS
PAGE
3 LIEUTENANT JUAN RIVERA
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Examination By Mr. Smith .....................5
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EXHIBITS
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MARKED
8 NUMBER
FOR ID
9 Lieutenant Juan Rivera Deposition Exhibit
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Exhibit No. 1 Letter of recommendation .......9
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Exhibit No. 2 Overtime slips ...............115
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Exhibit No. 3 Counseling session report ....115
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Exhibit No. 4 E-mail ......................118
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Exhibit No. 5 E-mail .......................119
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Exhibit No. 6 Notice .......................120
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Exhibit No. 7 E-mail .......................122
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Exhibit No. 8 E-mail .......................124
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Exhibit No. 9 E-mail .......................125
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Exhibit No. 10 E-mail ......................126
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Exhibit No. 11 E-mail ......................128
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Exhibit No. 12 E-mail ......................128
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Exhibit No. 13 E-mail ......................132
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Exhibit No. 14 Note ........................133
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Exhibit No. 15 Two e-mails .................134

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(Witness duly sworn.)
LIEUTENANT JUAN RIVERA,
called as a witness herein, having been 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 court reporter?
A. Juan, J-U-A-N, Rivera, R-I-V-E-R-A.
Q. What is your current position?
A. I'm the Chief of the Bureau of Internal
Affairs.
Q. Did you review any documents in preparation
for this deposition?
A. Yes.
Q. What documents did you review?
A. I believe it was certain e-mails, reports, I
think, was tendered to you for discovery.
Q. Do you recall any e-mails in particular that
you reviewed?
A. I think there were e-mails between myself and
some of the exempts, Kirby. I believe e-mails from
Echeverria.
Q. What reports did you review?

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A. Some of the reports that were generated by
Echeverria.
Q. Were there reports in connection with
Operation Brass Tacks or reports relating to
Mr. Echeverria outside of Brass Tacks?
A. It was related to Brass Tacks.
Q. I'm going to ask you basically why don't
we -First of all, before you were a Chicago
police officer, did you have any other law enforcement
jobs?
A. No.
Q. What was your first assignment after the
Academy.
A. After the Academy I was a patrol officer in
the 3rd District.
Q. What did you do after that? And when was
that that you started?
A. I started the Academy in '86. I believe I
was in the 3rd District until '89.
Q. Then what was your next assignment?
A. I was detailed to the gun -- a gun task force
specialized unit.
Q. Then what was your next assignment?

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Q. Where did you go after that?
A. I was promoted to lieutenant and assigned to
the 5th District.
Q. And then where did you go after that?
A. From there I was assigned to Internal Affairs
as lieutenant in charge of the confidential
investigation section.
Q. So what year was that?
A. I believe 2004.
Q. What was next assignment?
A. From there I was promoted to commander of the
25th District. I believe that was in '05.
Q. And where would you go after that?
A. After commander of the 25th District I was -I took a lateral move to Area 4 Detective Division
Commander, Detectives.
Q. And then where did you go after that?
A. From there I was promoted to deputy chief and
I was put in charge of Area 5.
Q. When was that?
A. It would have been -- Let's see. Probably
'08, somewhere in that range.
Q. And where were you moved to after that?
A. From there I went to, I was promoted to chief

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A. From there I went to the 1st District as a
Tact officer.
THE COURT REPORTER: T-A -THE WITNESS: Tactical officer.
BY MR. SMITH:
Q. After that where did you go?
A. I was promoted to sergeant. I went to the
4th District as a sergeant.
Q. When was that?
A. '94, I believe.
Q. And what was the next assignment after that?
A. From there I was detailed to Summer Mobile as
a sergeant in '96, I believe.
Q. After that where were you assigned?
A. From there I went to Narcotics.
Q. How long were you at Narcotics?
A. I was there till, I'd say, 2003.
Q. So from what about -A. '96 or so.
Q. To 2003?
A. Yes.
Q. Did you supervise a convicted officer by the
name of Len Lewellyn during that time?
A. No.

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and was put in charge of the Bureau of Internal
Affairs.
Q. Do you know the date specifically you were
promoted to chief and put in charge of the
Bureau of Internal Affairs?
A. I don't know, March of '09, I believe, is
when I -Q. March of 2009.
A. Yes.
Q. And then were moved at any time after that?
A. No, still in place. Presently still there.
Q. I'm going to show you what has been marked
as -- or I will have marked as Rivera deposition
Exhibit No. 1 for identification.
(Lieutenant Juan Rivera Exhibit 1
marked.)
BY MR. SMITH:
Q. And it's also Bates stamped DEFS1527; do you
recognize that document?
A. Yes.
Q. What do you recognize Exhibit No. 1 to be?
A. It's my letter of recommendation for
Officer Echeverria to be considered for assignment in
the fugitive.

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Q. Did you also do a letter of recommendation -And this is dated February 22, 2012.
A. Correct.
Q. Did you do a letter of recommendation for
Officer Shannon Spalding at that time, also?
A. I believe so, yes.
Q. And if you could take a look at the letter of
recommendation and I'm going to ask you if you believe
everything in that letter of recommendation to be
correct in your opinion?
A. Again, this is based on my conversations with
the officer when I inquired as to his accomplishments.
So that's what I based it on.
Q. Well, did you believe -- Did you believe you
were truthfully stating your opinions of Mr. Echeverria
when you made this letter of recommendation?
A. I had no reason at the time to doubt the
officer, so I ...
Q. And then with respect to the letter of
recommendation that you did for Shannon Spalding, did
you also believe you were being accurate when creating
that letter of recommendation?
MR. KING: Object to the form. I think it
misstates his testimony. But you can answer it if you

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A. Yes. Not -- Not at the time he was detailed,
but after he was already there I took the position of
the chief. He was already in place, yes.
Q. And you were at the time you wrote this
letter, correct?
A. That's correct.
Q. And you indicated that Officer Echeverria was
instrumental in a highly confidential investigation
involving corrupt police personnel, correct?
A. Yes, he provided a source.
Q. And you believe that -- You were aware of
what -- that Mr. Echeverria was involved in a highly
confidential investigation, correct?
A. Yes.
Q. In fact you were -- You were overseeing, at
least in part, that investigation with the FBI?
A. It was a joint -- joint operation, yes. I
wasn't -- I wasn't overseeing it. It was just
cooperating the with the federal investigation.
Q. You're not indicating that you didn't agree
with that sentence that you wrote at the time of this
letter, correct?
A. Correct.
Q. And you were aware that Mr. Echeverria and

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understand it.
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BY THE WITNESS:
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A. Again, it's based largely on a conversation
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that I with the officer and their explanation of their
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work history.
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And again, I had no reason to doubt the
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officers.
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BY MR. SMITH:
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Q. Well, let's go through it then.
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A. Uh-huh.
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Q. Did you unequivically recommend after
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Officer Daniel Echeverria for consideration of the
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assignment of the Department Fugitive Units on
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February 22, 2012?
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A. Yes.
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Q. Did you also do that for Shannon Spalding? 16
A. Yes.
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Q. It notes here:
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"Officer Echeverria is currently detailed
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into the Bureau of Internal Affairs from the Narcotics 20
Unit"; do you see that sentence?
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A. Yes.
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Q. And you were the chief of the
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Bureau of Internal Affairs, correct?
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Miss Spalding were involved in extensive surveillance,
federal wire taps, use of confidential informant and
the ultimately covert operations, correct?
MR. KING: Just object to the form of the
question.
Go ahead.
BY THE WITNESS:
A. Again, I'm basing it on what I had been told
and had learned when I arrived there as the chief.
BY MR. SMITH:
Q. You were aware of Operation Brass Tacks,
correct?
A. That's correct.
Q. In fact, you were getting documents even from
the FBI for your review; isn't that correct?
A. No, I was not.
Q. You've never seen any of the documents
prepared by FBI personnel relating to
Operation Brass Tacks?
A. No, that's strictly all -- As far as I'm
concerned, or at least I was told, that's grand jury,
16 material.
Q. And you were getting to-from memos to you
from Mr. Echeverria and Miss Spalding regarding things

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that they were doing in connection with that?
A. Yes. Throughout the time frame that this was
going on I would get certain reports from them.
Q. On February 22, 2012 you believed that to be
true that Mr. Echeverria was involved in extensive
surveillance, federal wire taps, use of confidential
informant and the ultimately covert operations,
correct?
A. I believe that to be true, yes.
Q. Do you have any reason to believe that's not
true at this time?
A. Again, I have no reason to doubt it.
Q. You indicated.
"That his experience, knowledge and
exceptional efforts contributed to the successful
conclusion of Operation Brass Tacks, correct?
A. Yes.
Q. And in your conclusion -- In your opinion
Operation Brass Tacks had a successful conclusion?
A. Yes.
Q. And you had no reason at this point in time
to not believe that Mr. Echeverria made exceptional
efforts to the contribute to this that success?
A. I'm sorry. Can you repeat that?

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"Officed Echeverria also has extensive
experience as a gang tactical officer working in public
housing complexes which is ing challenge environment,"
correct?
A. Yes, I indicated that.
Q. And you were aware that Shannon Spalding was
also involved in public housing, correct?
A. Yes.
Q. As a tactical officer?
A. This is based on what the officers related to
me.
Q. You agree that both Shannon Spalding and
Daniel Echeverria have extensive experiences as gang
tactical officers working in public housing, correct?
MR. KING: Object to the form. Asked and
answered.
BY THE WITNESS:
A. Again, I had no reason do doubt.
BY MR. SMITH:
Q. Have you ever reviewed any of their
performance review?
A. No.
Q. You were aware that -- You had learned that
Officer Echeverria and Officer Spalding were

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Q. You had no reason to believe at this time
that Mr. Echeverria did not make exceptional efforts to
contribute to that successful conclusion?
A. No, I -- I -- I believe they made the effort.
Q. And the same for Shannon Spalding?
A. That's correct.
Q. You indicated in the second paragraph:
"Mr. Echeverria's willingness to take on some
of the most dangerous and highly sensitive assignments
demonstrate his commitment to the department's
mission," correct?
A. Yes.
Q. Did you believe that at the time you wrote
that?
A. I had no reason to doubt the officer.
Q. Do you have any reason to doubt that at this
time?
A. No.
Q. Did you also say that about Shannon Spalding?
A. Yes.
Q. Do you have any reason to doubt that at this
time?
A. No.
Q. You also put in the third paragraph:

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instrumental in the successful conclusion of
Operation Fall Out?
A. Yes.
Q. And you indicated that you believe that
Officer Echeverria possesses the necessary skills and
traits that would allow him to contribute tremendously
to the department's Fugitive Unit, correct?
MR. KING: Just show a continuing objection to the
form of the questions.
He testified the basis of that knowledge and
then Counsel is asking him questions without
referencing the basis of that knowledge. I think it's
improper form.
But you can answer his question.
BY THE WITNESS:
A. Again, I had no reason to doubt the officers.
BY MR. SMITH:
Q. And you indicated in your recommendation that
it was your belief that Officer Echeverria possessed
the necessary skills and traits that would allow to
contribute tremendously it the department's
Fugitive Unit, correct?
A. It was my belief at the time, yes.
Q. Is there anything that's occurred since that

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time that you're aware of that has changed your view of
that?
A. I haven't had any contact with the officer,
so no.
Q. In terms of Officer Shannon Spalding, you
also believed that she possessed the necessary skills
and traits that would allow her to contribute
tremendously to the department's Fugitive Unit?
A. That was my belief, yes.
Q. Has anything changed that belief?
A. Again, I have not had any contact with the
officer since then, so no.
Q. When is the first time that you met
Officer Shannon Spalding, if you recall?
A. I'm not sure of date, but it was shortly
after I took the position of chief.
Q. And what were the circumstances in which you
met Officer Shannon Spalding?
A. Scahill -- During the transition, Scahill
actually walked into my office and introduced me to the
officers.
Q. The officers, Danny and Shannon?
A. Yes.
Q. Who else was present during that meeting?

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money from the drug sellers.
Q. Did she tell you the name of the officers at
that time?
A. She mentioned -- I think it's the
Sergeant Watts, the officer, I believe, Mohammed.
Q. Were you familiar with Sergeant Watt's name
from your time previously within Internal Affairs?
A. I don't think at that meeting, but
eventually, yes, I recalled -- After reading some
reports, I recalled that back I believe in 2004 there
was a complaint made and investigation initiated on the
same information.
Q. Do you recall that you assigned that
complaint to Thomas Mill?
A. That I don't recall. I believe the agent
that was with me was -- I might be mistaken, but
believe it was Caldwell, I believe.
Q. Did Tina Scahill tell you anything else at
the time?
A. No, that's it. Again, she didn't stay.
Q. Did Tina Scahill tell you what Shannon and
Danny's assignments were at that time?
A. Again, other than they were handling the
informant.

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A. Just Scahill and myself and the officers.
Q. What were you informed of at that time?
A. She briefed me on their role in the
investigation of Brass Tacks.
Q. And what did she tell you that their role was
within Brass Tacks?
A. Essentially that they had -- They had
provided a source and that they were handling or
handlers -- They were be handling the source.
Q. Anything else?
A. That was it. She didn't stay long. She left
after the introduction and the briefing.
Q. Was there any information given about the
investigation itself in that meeting?
A. Not from -- from -- Who? From anyone in
particular? Scahill didn't, other than briefing me as
to their involvement. She didn't give me a status or
anything regarding the investigation.
Q. Did she tell you what the investigation was
about?
A. Yes.
Q. And what did she tell you that was?
A. She told me it was regarding a sergeant and
an officer that were, I believe she put it, extorting

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Q. Did you talk to Danny and Shannon at that
point in time?
A. Yes, I did.
Q. What did you say to them and what did they
say to you?
A. They basically stated that -- which kind of
through me a little bit, but they were like, well, this
is a good investigation. We were looking to get
promoted -- or task force from this investigation. And
at that point I asked, Well, is it at the point where
it's going to be concluded here shortly and they were
like, no. I said, well, where exactly is it? And from
what I recall, they were telling me that they were
still trying to create a scenario or a sting utilizing
their informant.
Q. Did they tell you anything else at that time?
A. I think for the most part that was -- that I
could recall more or less the gist of the conversation.
Q. Did you recall which one of them said those
things?
A. Shannon, I believe was the one who was
talking.
Q. In terms of -- So at that time you were aware
that were working with the FBI, correct?

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A. Yes.
Q. Were you told that the investigation was -Were you told at all who knew of their involvement in
the investigation?
A. They kind of filled me in on -- I can't
remember the dates, but they told me how they came
across the source and how they passed the information
along to the FBI, and as a result they were asked to
work with Internal Affairs and the FBI regarding the
investigation.
Q. Did you ever learn that to be untrue?
A. No.
Q. Did you have an understanding of who within
the Chicago Police Department was aware at that point
in time that Shannon and Danny were investigating
police officers misconduct?
A. Well, as far as -- Again, from the
conversation, they told me that their superiors were
aware of it and they allowed them to assist.
Q. Who did you believe was their superiors?
A. I would assume O'Grady and I'm assuming their
sergeant and I have no idea who he is, but their
Sergeant O'Grady and Roti.
Q. Did they ever tell you specifically that

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BY THE WITNESS:
A. Again, that would be me speculating, but I
would assume everybody above Scahill. I would assume
she would be briefing her superiors.
BY MR. SMITH:
Q. Who would that have been at the time?
A. Obviously, I'm not sure who she would have
briefed, but it would have been whoever was her
superior, including, I would assume, the superintendent
at that time.
Q. Who was that?
A. I think -- believe, Weese.
Q. Anybody else who was above her besides Weese?
A. I'm not sure if Brus would have known or -Q. Did you find it unusual in any way that
Officer O'Grady would have known that -A. What was that?
Q. Did you find it unusual at all that Shannon
said that Officer O'Grady knew that she was
investigating undercover -- I mean police officers for
wrongdoing?
A. Commander O'Grady?
Q. Commander O'Grady.
A. That's her superior. Obviously, they would

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O'Grady was aware -- and that in this meeting that
O'Grady was aware that they were investigating
undercover police?
A. Yes, they told me.
Q. Did they tell you personally that they were
aware that Roti was aware that they were investigation
undercover police?
A. Yes.
Q. I mean, police officers for corruption?
A. Yes.
Q. Do you know who said that?
A. Shannon .
Q. Was Officer Scahill in the room at that point
in time?
A. No.
Q. Who else did you believe knew about them
investigating police officers?
MR. KING: Object to the form.
MR. SMITH: At that point in time?
MR. KING: Who else did she tell him, or who did
he believe?
MR. SMITH: Who was it his belief that was aware
that they were investigating police officers.

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have had to give her permission to work the operations.
Q. Did Tina Scahill ever tell you that
officer -- Commander O'Grady was aware that they were
working that mission?
A. No.
Q. Did Tina Scahill ever tell you that Roti was
aware they were working that mission?
A. No, Tina didn't.
Q. Did you make a list of -- in any way of all
the people who with aware of -- that you believe were
aware that Shannon and Danny were working an
investigation of corrupt police officers?
A. No.
Q. Did you think it was important to be aware of
who was in the know of this investigation?
A. I just assumed they had been working on it, I
don't know how many years, prior to me arriving there
that, you know -- Those were her superiors. They
would, obviously, have given her permission to
cooperate in the investigation.
Q. Why did you assume that?
A. That's what Shannon told me.
Q. So only because Shannon told you you assumed
it?

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A. No, not just because she told me and,
obviously, she's not -- she's detailed out to the FBI.
Q. Was it your understanding that she was
detailed out to the FBI at that time?
A. That's what Scahill had mentioned, yes.
Q. Did anyone tell you that Danny and Shannon's
identities involvement in this case to were remain
confidential?
A. No, it was -- it's assumed they -- no one had
compromised them. They were working on it.
Q. You assumed that nobody compromised them on
it?
A. Right. It was still an ongoing
investigation.
Q. Did anyone say, we've got to keep their names
confidential and their identities confidential and
their involvement in the case confidential?
A. No.
Q. Was that ever an expressed concern by anyone?
A. "Anyone" meaning?
Q. Anyone either Danny, Shannon, Scahill or -at any point in time to you?
A. No.
Q. And in your role as Chief of the Bureau of

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BY MR. SMITH:
Q. Were you aware of who all the targets of the
investigation were?
A. I was told it was a sergeant and a police
officer.
Q. Did you ever learn that other individuals
were identified as potential other -- other officers
were potentially identified as people who may have been
involved with Watts and Mohammed?
A. Obviously, it's from -- From when I can
recall, it was a team of officers. But at the point in
time where I was involved, the FBI and US Attorney were
targeting the just sergeant and the PO.
Q. You were never told that the other team
members weren't involved in potential drug operations,
correct?
A. I was not told.
Q. Did you make any efforts to know who
Sergeant Watts had worked with in the past?
A. I personally did not, but -- Again, I know
the FBI was looking at all that. They were the lead
agency in the investigation. So everything you're
telling me is more so something that the FBI would be
following up or ...

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Internal Affairs, you understand the importance of
keeping officers who are investigating other officers
confidential, correct?
A. Yes.
Q. Obviously -- Wouldn't did be fair to say that
in order to keep something confidential you would have
to know who you could tell and who you couldn't tell
you?
MR. KING: Just object to the form and lack of
foundation.
BY THE WITNESS:
A. First of all, I would only be discussing that
with my superiors. So there would be no reason and I
had no reason to speak to anybody else other than my
superiors about the investigation.
BY MR. SMITH:
Q. So you would have never spoken to anybody who
wasn't your superior about this investigation at the
point in time it was going on?
A. No, other than my command staff.
Q. Were you aware of who the targets of the
investigation were at the time?
A. The sergeant and the officer?
MR. KING: Just object as asked and answered.

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MR. KING: Just answer his question.
BY MR. SMITH:
Q. Were you aware of what type of danger Danny
or Shannon might be in if Sergeant Watts were to find
out that they were investigating him and other Chicago
police officers?
MR. KING: Object to the form. Lack of
foundation.
BY THE WITNESS:
A. Yeah, I -- I'm trying to understand, danger
in terms of ...
BY MR. SMITH:
Q. The potential dangers of being found out that
they were informants -- I mean that they were working a
confidential investigation against Chicago police
officers for corruption?
MR. KING: Same objection.
BY THE WITNESS:
A. There is always a potential for danger.
BY MR. SMITH:
Q. Were you ever made aware that individuals
suspected Sergeant Watts of murders?
A. The officers did mention that that was part
of the investigation.

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Q. Do you have any reason to doubt that at this
time?
A. No.
Q. Were you aware that while they were -- while
Danny -- when Danny and Shannon first met you and were
working with the FBI they were assigned to the
Narcotics Unit still?
A. Yes.
Q. Were you aware that they were detailed to
Detached Services Unit 153?
A. Yes.
Q. And that they were to report directly to FBI
headquarters to work directly on Operation Brass Tacks?
MR. KING: Just object to the lack of foundation
without a time frame.
BY MR. SMITH:
Q. When you first met with them?
A. Yes, they were reporting to the FBI facility.
Q. Did you believe them to have any other work
assignments at that point in time other than reporting
to FBI headquarters to work on Operation Brass Tacks?
A. No.
Q. Were you aware that -- In fact, did you allow
them, encourage them to develop other narcotics-related

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A. I mentioned to them that the bottom line is
the more contact they have out there the chances
increase that they could get compromised.
Q. And did you ever tell them not to cell other
narcotic-related cases when they were working on
Operation Brass Tacks?
A. No.
Q. At some point in time before August of 2010
did you tell an individual by the name of Ernie Brown
that Shannon Spalding and Danny Echeverria were doing
an operation investigating officers?
A. No.
Q. Did you ever talk to Ernie Brown about
Operation Brass Tacks?
A. No.
Q. You know Ernie Brown, correct?
A. I know who he is, yes.
Q. Were you ever confronted by Shannon or Danny
that Commander O'Grady came to know that they were
investigating police officers?
MR. KING: Object to the form of the question.
BY THE WITNESS:
A. No.

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cases which overlapped with their work on
Operation Brass Tacks; in other words, if an informant
or a lead in working on Brass Tacks lead to a possible
other narcotics delivery or sales or operation that
they were encouraged to actually continue to develop
those leads?
A. No.
Q. You never told them that it was okay for them
to gather information and help other officers make
busts, narcotic-related busts at the time they were
working on Operation Brass Tacks?
A. No.
Q. Did you ever know of them to develop and help
other officers get narcotics-related arrests while they
were still working with Operation Brass Tacks?
A. They did inform me they had developed
information and I immediately told them to pass that
information along, yes.
Q. Well, it was -- Were you doing it in a way
that was -- Or did you tell them to not do that or stop
doing that?
A. I didn't encourage them.
Q. Did you think there was anything wrong with
doing that?

Page 33
1 BY MR. SMITH:
2

Q. Did you ever tell or talk to

3 Commander O'Grady about Shannon or Danny being involved
4 in Operation Brass Tacks?
5

A. No.

6

Q. Or any type of investigation of police

7 officers?
8

A. No.

9

Q. Have you ever had any conversations with

10 Defendant O'Grady about Shannon or Danny?
11

A. No.

12

Q. Did you ever talk to Nicholas Roti about

13 Danny or Shannon?
14

A. Are you -- Regarding that time frame?

15

Q. Well, let's start with regarding that time

16 frame, sometime around August of 2010?
17

A. No.

18

Q. Did you ever talk to Nicholas Roti about

19 Shannon Spalding or Danny Echeverria ever?
20

A. Yes.

21

Q. When was that?

22

A. This was -- Had to be sometime after the

23 conclusion of the operation and I think it was the time
24 the lawsuit was filed.

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Q. And what did you talk with Nicholas Roti
about at that time?
A. In a conversation he mentioned how he had had
an issue with them and he explained to me the issue.
Q. What was the issue?
A. According to Chief Roti, he related to me
that he had allowed the officers to work with the FBI
on this operation and that he had called the agent, I'm
not sure who it was, and he spoke to them and asked
them if the officers were working out. At that point
in time the agent said, yes, we used them twice or
something like that during a week. And Roti at that
point in time told me he went to Shannon's supervisors
in Narcotics and asked him whether they had been to
work and the sergeant had told them that, no, they had
been gone for the entire week.
Q. Anything else he said?
A. He stated that he saw that as an issue and he
then had a conversation, I believe, he mentioned
Scahill and that he basically told her it's best to
detail them to Internal Affairs so that they can be
supervised.
Q. And what time frame did you believe he was
talking about?

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A. Again, I'm speculating. I mean, all I can
tell you is it's after the conclusion of the operation
and after the lawsuit was filed.
Q. That's the first time you ever talked to
Nicholas Roti about Operation Brass Tacks or
Shannon Spalding or Danny Echeverria?
A. That I can recall, yes.
Q. Did you ever tell Danny or Shannon that it
may have been your fault that -- or you may have leaked
the fact they were involved in investigation of police
officers?
A. No.
Q. So after the first meeting with Shannon and
Danny, what was your next involvement with Shannon and
Danny?
A. I think we had -- I -- I'm trying to think
back. I think I had the sergeant, Tom Chester, in a
separate meeting and, again, I'm just -- I'm not sure
what date or whatnot, but with the officers.
Q. And what was that meeting concerning?
A. Status.
Q. And what was the status that was given to
you?
A. My understanding is they were, again, trying

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A. I believe it was early on when they were
detailed.
Q. And where were you when you had that meeting
with Roti?
MR. KING: Object to the form, "meeting."
BY MR. SMITH:
Q. Spoke with Roti.
A. I'm sure it was during -- From what I can
recall it was during some other meeting or something
where we were sitting in a room. I'm not sure about a
date or a meeting or a time.
Q. Who else was present?
A. At that point in time it was just me and
Roti, I believe.
Q. Other than it being after the filing of the
lawsuit or after the lawsuit was filed, do you remember
an approximate date?
A. No.
Q. Was it within the year, the year from now?
A. Honestly, I wouldn't be able to tell you more
or less.
Q. It would be fair to say that it was at least
four years after the period that Shannon and Danny were
first assigned to investigate Operation Brass Tacks?

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to create a scenario, I believe a sting.
Q. Were they going into details about the
scenarios that they were trying to create?
A. You know, I can't recall if they went into
details. I do recall they were referring to a
scenario.
Q. Did you have any complaints about what they
were doing at that time?
A. No.
Q. Did you hear any complaints by any
supervisors in relation to or even other officers about
Danny or Shannon at point in time?
A. At that second -- No. Second meeting.
Q. Or at any time between the first meeting and
the second meeting?
A. No.
Q. Do you know approximately when the second
meeting would have been, about how long after the first
one?
A. I'm, again, speculating, maybe a couple of
days or ...
Q. And then what is the next involvement? How
often would you meet with Danny and Shannon during that
period of time?

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A. It became almost every other day and it was
actually Spalding or Echeverria that would meet me at
the lobby area of the headquarters and try and engage
me in conversations.
Q. Almost every other day after the first
meeting with them?
A. Yes.
Q. For how long did that go on for?
A. It may have went on for a few months.
However, I discouraged them from doing that, obviously,
because of the issue of compromise.
Q. And what were the discussions during these
meetings at the lobby of headquarters about?
A. It varied. It could have been from them
trying to tell me of a scenario that would work, um,
with regards to a sting or something directed to the
targets. It would be conversations regarding vehicles
that they would use.
Q. And when you discouraged them from continuing
to do that on an every-other-day basis, did you tell
them what they should do instead or did you tell them
how often you wanted to see them or any information as
to in what manner they should report to you?
A. Yes, I told them go directly to their

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there.
Q. Did anyone from the FBI ever come to you to
talk about Shannon and Danny in particular?
A. No.
Q. And anyone ever make a complaint to you from
the FBI or the federal government about
Danny Echeverria or Shannon Spalding?
THE WITNESS: Could I -MR. KING: Just -- Object to the form of the
question.
If you understand it, you can answer.
BY THE WITNESS:
A. No.
BY MR. SMITH:
Q. So after you told Danny and -MR. KING: Do you want to take a break?
MR. SMITH: Do you need a break.
MR. KING: Yeah, take a quick one.
MR. SMITH: Sure.
(Recess taken.)
BY MR. SMITH:
Q. In terms of when -- Were you aware that when
Shannon and Danny were detailed to Unit 543 that they
were -- their immediate supervisor was a Liz Glass?

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sergeant which was Tom Chester or if it was important
call.
Q. Did they have your personal cell phone?
A. No, they had my work cell phone, BlackBerry.
Q. But it was a cell phone?
A. Yes.
Q. And were you -- had you met with
Patrick Smith or spoken to Patrick Smith on the phone
at any point in time during this first period or first
month or two that you had learned of Shannon's
involvement with the FBI?
A. I'm sorry. Can you repeat that?
Q. Do you know who Patrick Smith is?
A. I was aware of Agent Smith, yes.
Q. Did you speak with him or meet with him at
some point in time about Operation Brass Tacks?
A. I don't recall. We may have, because we had
quarterly meetings with the FBI for updates.
Q. In those quarterly meetings, did you get
updates about Operation Brass Tacks?
A. I'm sure I did, yes.
Q. Do you know who would give you the updates on
Operation Brass Tacks?
A. I don't recall who was all in the meeting

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A. Well, she's not their immediate supervisor.
Tom Chester was their immediate supervisor.
Q. Were you aware that they were to report to a
Liz Glass?
A. Administratively they reported to her, yes.
Q. And the ANA sheets -- Where did you believe
the ANA sheets that they were assigned -- they were to
to sign were at that point in time?
A. I'm assuming Detached Services were handling
that.
Q. And were you aware that they weren't supposed
to report to Narcotics Unit 189 at that time?
MR. KING: Just object to the form of the
question.
BY THE WITNESS:
A. I'm sorry. Can you rephrase that?
BY MR. SMITH:
Q. Were you aware of any directive that Shannon
and Danny were supposed to report to Unit 189 Narcotics
during the time that they were signed to Detail 543?
A. No. I mean, they should have been working
with Internal Affairs and the FBI.
Q. So did you ask Nick Roti why the heck he
would have thought that Shannon Spalding and

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Danny Echeverria should be reporting to his unit at
that point in time?
MR. KING: Just object to the form, lack of
foundation, different time frames, misstates his
testimony.
BY THE WITNESS:
A. Different time frame.
BY MR. SMITH:
Q. Were you aware of any point in time where
the -- that before Shannon Spalding and
Danny Echeverria were reporting -- were detailed to
Unit 543 by Tina Scahill that Shannon Spalding and
Danny Echeverria were working for the FBI and the
Chicago Police Department -- with the
Chicago Police Department?
MR. KING: Just object to the lack of foundation.
BY THE WITNESS:
A. Repeat that.
BY MR. SMITH:
Q. Was there any point in time to your knowledge
that Shannon Spalding and Danny Echeverria were working
at Narcotics, Unit 189, and assigned to work with the
FBI?
A. That would have been prior to me taking the

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A. When they briefed me on how they became
involved in this.
Q. And when was that?
A. It was probably early on. I'm not sure. I
wouldn't be able to tell you what day or meeting.
Q. What did they tell you in terms of -- What
made them talk to you about the -- How did they tell
you that they worked -- had been working in Narcotics
and assigned to the FBI?
A. Basically they told me that they came up with
the source, the information and they were given
permission to work with the FBI when the FBI needed
their assistance.
Q. And by who were they given permission to work
with the FBI for is their assistance?
A. The way they put, it was their supervisors
O'Grady and Roti and their sergeant was aware of it.
Q. Are you aware that Shannon Spalding and
Danny Echeverria went to the FBI on their own without
permission from supervisors?
MR. KING: Just object to the form. You can
answer it.
BY THE WITNESS:
A. Yes. The way it was relayed to me was that

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position of chief, yes.
Q. Who told you that?
A. I'm sorry.
Q. Who told you that that was happening?
A. Who told me that?
Q. That Shannon Spalding and Danny Echeverria
were working with the FBI while they were assigned to
Narcotics Unit 189?
A. The officers did.
Q. Danny and Shannon?
A. Yes.
Q. Did anyone else ever tell you that before a
meeting with Nick Roti after the lawsuit was filed?
A. Other than the officers that I can recall.
Q. No one?
A. I can't recall anybody.
Q. Tina Scahill never told you that, correct?
A. I'm not sure if -- Again, she may have. I'm
not sure if she mentioned what had happened prior to
all that.
Q. When did this conversation with -- where
Shannon Spalding or Danny Echeverria told you that they
were working at Narcotics 189 and reporting to FBI,
when did that happen?

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they had information and they went to the FBI with the
information and they were allowed to work the
investigation with the FBI.
BY MR. SMITH:
Q. You believe that they went to the FBI after
talking to supervisors?
A. My understanding was that they had -- the
information they had related to the supervisors in
their unit.
Q. Well, if I told you that Danny Echeverria and
Shannon Spalding went to the FBI without the knowledge
of supervisors, including Tina Scahill, would that
surprise you?
MR. KING: Just object to the -BY MR. SMITH:
Q. In connection with the CI?
MR. KING: -- to the form and lack of foundation.
Are you saying when they initially went to
the FBI?
MR. SMITH: Yes.
BY THE WITNESS:
A. It would surprise me, because normally
something like that, some type of misconduct is,
according to the directive, should have been reported

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to their immediate supervisor.
BY MR. SMITH:
Q. So you're saying that you never even heard,
to this date, until right now, is this the first time
you ever heard that somebody claiming that
Shannon Spalding and Danny Echeverria went to the FBI
on their own, in their off time before going to any
supervisor, including Tina Scahill?
A. Again, I wasn't aware of that. The way it
was put to me was that this they had information and
went to the FBI and were allowed to work the
investigation.
Q. And were you aware that -- that the FBI went
to Tina Scahill's office and had a meeting with
Tina Scahill asking that she be allowed to work with
them?
MR. KING: Just object to the form and lack of
foundation, assuming facts not necessarily in evidence,
certainly for this deposition.
BY THE WITNESS:
A. Again, that was before I was there, so ...
BY MR. SMITH:
Q. Do you have any idea of the time period, the
date that Shannon and Danny were first assigned to the

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in Narcotics and with the FBI?
MR. KING: Objection. Asked and answered at least
fours times.
BY THE WITNESS:
A. Again, I would be speculating.
BY MR. SMITH:
Q. Is it correct that you don't know any dates?
MR. KING: Five times.
THE WITNESS: Yes.
BY MR. SMITH:
Q. Is that correct?
A. That's correct. I would be speculating.
Q. In terms of Danny or Shannon, did they
ever -- either one of them ever communicate to you that
they were feeling that people were mistreating them or
treating them differently because they were
investigating police officers?
A. Investigating police officers, no.
Q. Involved in Operation Brass Tacks?
A. No.
Q. Did they feel that people were treating them
unfairly? Did they make any complaints to you at all
that they were being treated unfairly?
A. There was a conversation that Spalding

Page 47
1 FBI?
2

A. I mean, I would be speculating. I'm sure

3 they kind of mentioned it to me, but it was prior to me
4 taking the position of chief.
5

Q. Do you know how -- If it was within days of

6 being assigned to 543 -- the detail to 543?
7

MR. KING: Just --

8 BY THE WITNESS:
9

A. I think would it be days. It would be

10 speculating. Do really don't know the time frame they
11 would be there.
12 BY MR. SMITH:
13

Q. How long do you think it was between the

14 time they got permission to work with the FBI by the
15 Chicago police department supervisors and the time they
16 were assigned to Unit 543?
17

A. Again, I -- I would be speculating.

18

Q. It possible that it was two days?

19

A. Again, you're asking me to speculate on

20 something ...
21

Q. In terms of -- Can you give any time period

22 that in terms of specific time periods, even weeks,
23 days, months, in which you believe that
24 Shannon Spalding and Danny Echeverria were working both

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initiated and that's probably the only time I heard her
make an issue of what she believed was compromising her
and Officer Echeverria.
Q. When was that?
A. You know, I don't have specific dates,
because we had, you know, numerous conversations. But
in one particular -- I can recall one conversation
where she initiated -- where that she stated that she
had been concerned because there was talk in Narcotics,
the people were calling or telling people that they
were snitches or rats. And at that point in time I
asked her, Where are you hearing this and she's saying,
It's talk. I then went into, she's asking me, you
know, if I thought maybe that was happening -- I told
her, I had not heard it. Is it possible that people
maybe saying stuff, anything is possible, I told her
but I have not heard it. I then asked her -- I said
where or who's telling you this and she then tells me
it's a friend in Narcotics by the name of Hernandez.
Q. Was Danny Echeverria there for that
conversation?
A. No.
Q. Did she tell you what Hernandez was saying to
her?

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A. Basically the same thing. I said -- I asked
her is Hernandez a witness to any of this, she says, No
it's rumors.
Q. So she told you Hernandez didn't witness it
but he had heard it?
MR. KING: Objection. Misstates his testimony.
BY THE WITNESS:
A. According to Shannon he had told her it was
rumors.
BY MR. SMITH:
Q. Did Shannon Spalding ever tell you that she
had heard that Defendant O'Grady was informing his
personnel that she and Officer Echeverria were rats?
A. She mentioned O'Grady and Roti.
Q. And did she say the words "Rat" in particular
at that point in time?
A. She said "Snitch" and "Rat," yes.
Q. Did she tell you that she had heard that
O'Grady had ordered the unit not to work with her and
Echeverria and they should is not assist Shannon or
Danny?
A. No, that was never said.
Q. Did she tell you that O'Grady was prohibiting
her from earning of overtime?

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without more specific time frame.
And also detailed to 543?
MR. SMITH: No, assigned.
BY MR. SMITH:
Q. You know the difference between assigned and
detailed?
A. Yes.
Q. You were aware that they were still assigned
to the Narcotics Unit 189 at that point in time when
she raised those concerns about O'Grady and Roti?
MR. KING: Object -Can you repeat that question?
( Record read.)
BY THE WITNESS:
A. As far as I understand, yeah, I believe they
were assigned to 189 and to 543, I believe.
BY MR. SMITH:
Q. In terms of -- We titled the discussion
about -- In terms of the overtime issues, we talked
about how you did not tell Shannon or Danny that they
could not develop other narcotics leads while they were
working on Operation Brass Tacks; do you remember that?
A. I'm sorry. Can you repeat that?
Q. We talked about earlier in the deposition

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A. No.
Q. Did you make any contact with O'Grady or Roti
at that time to investigate her concerns?
A. No. It's -- According to Shannon, it was
rumors.
Q. Did you make any efforts to in any way to
investigate that at all?
A. Again, they're unsubstantiated rumors.
Q. Did you tell her anything in relation to her
concerns?
A. Other than I -- I basically told her, I said,
do you have or does your friend has witnesses.
Q. And what did she tell you?
A. Again, she reiterated, according to her
friend, Hernandez, it was rumors.
Q. And do you remember the time periods
generally when that occurred?
A. Nah. I said I would be speculating because
there was numerous conversations throughout the time
when they were involved.
Q. Were you aware that it was at a time,
certainly, that they were still assigned to the
Narcotics Unit 189?
MR. KING: Just object to the lack of foundation

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that you did not tell Shannon or Danny Echeverria they
couldn't develop other narcotics leads while they were
working in Operation Brass Tacks; do you remember us
talking about that?
MR. KING: Just object. I think it misstates his
testimony, but you can answer if you -BY THE WITNESS:
A. Can you repeat that?
BY MR. SMITH:
Q. Do you remember us talking about Danny and
Shannon in connection with developing other narcotics
leads while they were working with
Operation Brass Tacks?
A. I recall, yes.
Q. In fact, isn't it true that you approved of
overtime for them in connection with some of the work
they did in developing other leads while working on
Operation Brass Tacks?
A. When they informed me that they had
information I allowed them to work it and I also
discouraged them from doing it, because they could get
compromised.
Q. It's true you actually approved overtime for
Danny and Shannon for doing work on other cases

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while -- other leads while they were assigned to
Operation Brass Tacks?
A. Yes, once they had the information yes, I
allowed it.
Q. Do you recall at some point in time
approximately August of 2010 Shannon and Danny coming
to you relating to an issue with a sergeant or a
Officer Padar about work or information that he got
that led to a search warrant and that they had met with
Padar and had a conversation with Padar relating to
coming him others in his unit with information from
confidential informants?
A. No.
Q. Do you remember an indication that -- being
told that Sergeant Padar had informed them that O'Grady
does not want anybody in his unit to work with them on
any leads?
A. No.
Q. Do you recall ever seeing or approving
overtime or work for a search warrant that Shannon and
Danny did with Sergeant Padar?
A. I don't recall. Again, if you have something
that can refresh my memory.
Q. Do you know who Sergeant Padar is?

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A. The sergeant was not submitting the slips,
therefore, the officer was not -- Obviously, his hours
were not being removed, so he was keeping his hours
while not at work.
Q. Did you ever have any conversations with
Commander O'Grady about possible reassignment of either
Danny or Shannon within the department?
A. No.
Q. Did you have any conversations with Nick Roti
about possible reassignment within the department -A. No.
Q. -- of Danny or Shannon -A. No.
Q. Were you ever involved in a meeting -MR. SMITH: Strike that.
BY MR. SMITH:
Q. Did you ever inform -- In discussing overtime
work, were you ever told by Shannon or Danny that they
were being told that O'Grady wasn't allowing them to
work with them to get overtime with Unit 181?
A. No.
Q. I mean 189.
Were you ever told that if they were told
that they are ever in a 10-1, Unit 189 officers were

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A. Yes, I do.
Q. How do you know Sergeant Padar?
A. Sergeant Padar came up -- Again, with Shannon
came to me and asked for advice. I met with her and
that's when she informed me that, again, her friend
Hernandez was doing work with Sergeant Padar and there
was a dispute over the payment of whatever work he was
doing at his summer home or vacation home. At that
point in time in that conversation I told her, To me,
it's a civil matter, you know. That's, obviously,
contractual issues. And at one point she then stated
that he's also holding slips for Hernandez while he's
out working at his summer home, I'm like, Okay, there's
an issue here. At that point in time I told her,
Shannon, call your friend in -- and this is at
Internal Affairs -- and we're going to initiate a
complaint register number.
Q. Had you ever heard of Padar other than that,
relating to that incident?
A. I don't recall ever hearing about him until
that date.
Q. And do you know what "holding slips" meant?
A. Yes.
Q. What did it mean?

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told not to assist?
A. No.
Q. You know what a 10-1, correct?
A. Yes.
Q. Officer in need of assistance?
A. Yes.
Q. You don't recall having a conversation in
which you said -- where they asked you at that time if
O'Grady knew that they were working on an investigation
of officers?
A. No, they never asked that.
Q. Do you have any idea who their supervisor was
at the time or -MR. SMITH: Change that question.
BY MR. SMITH:
Q. Do you have any idea if O'Grady was their
supervisor at the time that they were assigned to
Unit 543 -- I mean detailed to 543 from 189?
A. O'Grady being their supervisor?
Q. Yeah?
A. No.
Q. Do you have any idea if O'Grady was their
supervisor at the time that they were in 189 when they
were first met with the FBI?

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A. Again, I wasn't in place at the time. I'm
not -- I would be speculating if he was or not.
Q. But you're confident and certain that
Shannon Spalding told you that her supervisor, O'Grady,
knew that she was working with the FBI?
A. She stated -- I'm not sure if she used the
name "O'Grady"; my commander and and the chief were
aware, they've given us permission to work with ...
Q. So she never used the name "O'Grady"?
A. Again, I don't recall. I don't know if she
mentioned O'Grady, Roti or chief, but she basically
said her superiors were aware and they had given her
permission to work with FBI.
Q. And you also -- You don't you recall telling
Shannon or Danny that you told Ernie Brown and that's
how O'Grady knows?
A. No.
Q. Do you recall being involved in a meeting in
which Nicholas Roti was present where -- and O'Grady
were present in which the subject of Shannon and Danny
came up?
A. Can you repeat that?
Q. Do you recall being at a meeting with
Nicholas Roti and James O'Grady in which

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A. Yes.
Q. Do you know who Beatrice Cuello is?
A. Yes.
Q. Did you ever talk to Beatrice Cuello about
Shannon Spalding or Danny Echeverria?
A. There was -- I was called to the
superintendent's office and she was the assistant
superintendent at the time and that point in time in
that I had a conversation with Beatrice Cuello.
Q. What did you talk to her about?
A. It was regarding the assignment of Spalding
and Echeverria to 543.
Q. What did you talk to her about regarding that
assignment?
A. I was asked by Beatrice Cuello, as well as
the interim superintendent, Terry Hilliard, as to what
the two officers were involved in.
Q. What did you tell them?
A. I told them the -- I don't recall the exact
wording or -- you know, I'm not sure how it was, but I
basically informed them of the investigation and the
status.
Q. What did you tell them about the
investigation and the status?

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Shannon Spalding and/or Danny Echeverria came up during 1
2
the meeting?
3
A. No.
4
Q. Did you ever talk to a Debra Kirby about
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Shannon or Danny's involvement in
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Operation Brass Tacks?
7
A. Yes.
8
Q. When was that?
9
A. Again, I don't know the specific time frame,
10
but Kirby was promoted, I believe, to Deputy
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Superintendent of the Bureau of Professional Standards.
12
So in essence she was my superior. As such I would
13
give her weekly updates on all the cases.
14
Q. Did you give her weekly updates on
15
Operation Brass Tacks?
16
A. Yes.
17
Q. When would that have been that you started
18
giving those weekly updates?
19
A. I would be speculating, but she was put in
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that position, Deputy Superintendent, and at that point
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in time she was my superior and I reported to her.
22
Q. So you had made her aware that certainly that
23
Shannon and Danny were assigned to work with the FBI
24
while they were detailed to Unit 543?

Page 61

A. I told them the investigation at this point
in time was involving the sergeant and an officer. I
explained to them the allegation and I also informed
them that the investigation was not making progress due
to a review by the US Attorney and the FBI, that they
were looking at assigning a new case agent to the
investigation and I told them it was, obviously, still
a viable investigation.
Q. And in terms of -- Do you know what time
frame that would have been in?
A. In -- I'm not sure if it's April, May,
somewhere in that range, 2011. I'm not sure. I'm
speculating on that.
Q. How did you learn that the FBI was looking
for a new case agent?
A. I was told that there was an issue with the
previous agent. I believe his name is Smith.
Q. Who told you that?
A. This came, I'm almost positive, from Chester,
Tom Chester.
Q. Did he tell you what the issue was?
A. I don't know if he went into -- I can't
recall if there was details -- I recall that there was
some documentation or use of the informant that was in

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question.
Q. Did either Hilliard or Beatrice Cuello ask
you what -- any questions specifically about Danny or
Shannon's assignment at that time?
A. It was mentioned that they were looking to
put officers back into patrol and that the -- I believe
it would Bea Cuello's sergeant had reach out to the
officers and I believe there was a conversation with
Echeverria regarding what they were involved in and
that phone conversation went bad. I'm not sure what
happened at that point in time, but that's when I was
called over by the interim supervisor and by
Bea Cuello.
Q. Were you contacted before that by either
Danny or Shannon?
A. Yes.
Q. What did they tell you? Which was one it
first of all?
A. It was Danny Echeverria, basically he told
me -- he made me aware that they were -- that 543
personnel were asking the people detailed there as to
what they were assigned to or involved in and I
basically told them if they were to contact them that
they were to refer them to me and I believe shortly

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and I would deal with the situation.
BY MR. SMITH:
Q. In your view, they certainly weren't under an
obligation to tell Beatrice Cuello what they were
investigating, correct?
MR. KING: Object to the lack of foundation.
BY THE WITNESS:
A. Again, the way Echeverria put it to me was
people were calling individuals that were detailed
there, so again, I would speculate -- Obviously, I
didn't know or wouldn't know who was going to call him
and ask.
BY MR. SMITH:
Q. Well, you would agree that he was -- if
somebody was -- if a person in the same position as
Beatrice Cuello called him, you know, and asked him
what his assignment was, he did not have to tell them
he was investigating police officers?
A. I directed him not to and for him to refer
anybody that called him to me. That's the way I
directed him.
Q. Did you ever become aware that Debra Kirby
was asked by either Beatrice Cuello or
Superintendent Hilliard if Danny and Shannon were

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thereafter they were. I think Danny Echeverria was
contacted and that's when that conversation took place
with the sergeant from Bea Cuello office.
Q. Did Beatrice Cuello inform you that Danny
had refused to give specifics about what he was doing?
A. No, she didn't mention that. She just
basically said he was -- like borderline insubordinate
to her sergeant or something to that effect.
Q. Did she tell you or were you aware that it
was concerning disclosure of his assignment?
A. Yes, because that's the -- that's what she
explained to me. Bea Cuello, the sergeant was asking
personnel what their assignment was or what they were
involved in.
Q. Were you aware and were you in agreement that
Danny and Shannon were told that they shouldn't tell
anyone outside of the confidential circle who knew
about their assignment or what they were doing in
specifics?
MR. KING: Object to the form and lack of
foundation, but ...
BY THE WITNESS:
A. Again, I gave them direction. I told them to
have -- to refer whoever it is that called them to me

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assigned to work with the FBI at that time?
MR. KING: Object to the the form and assuming
facts not in evidence.
BY MR. SMITH:
Q. Working with an undercover investigation at
that time?
A. I'm sorry.
Q. Were you aware of whether or not anybody
asked Debra Kirby about Shannon and Danny's assignment?
A. No.
Q. Were you aware of any point in time where
Debra Kirby indicated to -- Did you ever direct
Sergeant Steven to call Debra Kirby about Danny and
Shannon?
A. No.
Q. Do you know who Sergeant Steven is?
A. I believe it's the sergeant that worked for
Beatrice Cuello.
Q. Did you ever speak to Sergeant Steven about
Shannon and Danny?
A. No.
Q. Did you ever receive a call from
Sergeant Steven in which he was talking about
individuals who were assigned to Detail 543 about what

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they -- whether they could be to assigned out to
another unit.
A. No.
Q. Did you ever direct anyone regarding -- Did
you ever tell Danny Echeverria to have Sergeant Steven
or Beatrice Cuello call Kirby?
A. No.
Q. Did you ever tell Danny Echeverria to have an
individual who was asking about what he was doing in
Unit 543 to call Debra Kirby?
A. No.
Q. Did you ever learn from either
Beatrice Cuello or Shannon or Danny Echeverria or
Sergeant Steven or anyone else that there was an
instance where Debra Kirby failed to inform either
Beatrice Cuello or Sergeant Steven that Danny and
Shannon were working with the FBI while they were
detailed to Unit 543?
A. No.
Q. Did you ever speak to Danny or Shannon about
Beatrice Cuello's call to you about moving them from
Unit 543?
A. There was no call.
Q. Okay. Did you meet with -- I'm sorry. If it

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Q. Did you hear anything about what O'Grady's
position was with respect to their being removed from
the unit?
A. He was not mentioned.
Q. Did you ever tell Danny or Shannon that Roti
said he didn't want them back?
A. I told them that he had an issue, that the
discussion was that they would not go back to 189.
Q. Did they ask you what the issue was?
A. Yes.
Q. What did you say?
A. I told them exactly what I knew. I said I
did not know, they did not tell me.
Q. Did you ever tell either Danny or Shannon
that O'Grady said that he didn't want those IAD rats
back?
A. No.
Q. And that, God help them if they need help in
the street, it ain't coming?
A. No.
Q. So was that an actual meeting that was had?
A. No, it was -- Apparently, there was a meeting
prior. I was called in after the fact.
Q. Who was at the meeting?

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wasn't a call, when you met with Hilliard and Cuello
and discussed removal from 543, did you ever discuss
with Danny or Shannon that conversation?
A. Yes.
Q. And what was the discussion about?
A. They questioned me with regards to,
obviously, the phone call and the manner in which
apparently the conversation went, and I confirmed that
they were not happy with the way the conversation had
gone and I had told them that, in essence, they were
looking at reassigning them to patrol and they had
mentioned that they would not be going back to their
unit of assignment. And at that time they -- I heard
in the conversation mentioned that Roti had an issue
with them and they would not be going back to 189.
Q. Who told you that, Roti had an issue with
them?
A. That was a conversation that Hilliard and
Bea Cuello were having.
Q. So you overheard Cuello and Hilliard having a
conversation that Roti had a problem with them?
A. An issue, yes.
Q. Did you hear what it was?
A. No.

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MR. KING: Object to the form.
BY MR. SMITH:
Q. That you saw that was still there?
A. When I was called over I don't recall
everybody, but I know the interim superintendent was
there, Bea Cuello, and I'm not sure. I don't know if
there was any other person of rank there.
Q. Did you see Tina Scahill there?
A. No.
Q. Did you see in any unranked people who
weren't of rank there?
A. Um, while this conversation was going on I
don't believe I mentioned anything in front of anybody
else.
Q. Did you see Debra Kirby?
A. No.
Q. In the area of the meeting?
A. No.
Q. I'm sorry. You may have already said it, was
Nick Roti there at the time?
A. No.
MR. SMITH: Can we take a minute break?
MR. KING: Sure.

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(Recess taken.)
MR. SMITH: Back on the record.
BY MR. SMITH:
Q. When you saw Hilliard and Cuello concerning
Shannon and Danny, did you know specifically what they
were working on at that time with -- within the
Operation Brass Tacks investigation?
A. I'm sorry. Repeat that.
Q. When the meeting happened where Cuello and
Hilliard had mentioned to you the possibility of
reassigning Officers Spalding and Echeverria, were you
aware of what Danny and Shannon were working on
concerning Operation Brass Tacks?
A. Was I aware?
Q. Yes.
A. Yes.
Q. Did you know what they were specifically
doing that day?
A. I would be speculating. I don't recall that
day.
Q. Did you know at some point in time that Danny
and Shannon were meeting with a relative, I believe a
brother of somebody who was killed in connection with
selling narcotics in the area where Watts was suspected

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in Brass Tacks?
MR. KING: Object to the lack of foundation of the
question.
BY THE WITNESS:
A. To my knowledge they were not removed the
next day.
BY MR. SMITH:
Q. Do you know if they were ever removed
from Brass Tacks?
A. They were -- well, again -Q. I guess -A. -- can't give you a time frame, but there was
an order that came out transferring them to patrol.
Q. And do you know when that was in relation to
the meeting?
A. Again, I would be speculating. I don't know
if it's a week, two weeks. I'm not sure.
Q. Do you know if they were ordered to report
anywhere before the transfer to patrol?
A. Yes, they were -- which is common practice.
They were told to report to the academy for retraining.
Q. Were you aware that they were told at some
point in time that they were actually transferred there
to train other people?

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to be shaking down drug dealers?
A. I don't recall.
Q. In terms of -- so at the conclusion of the -Did either Hilliard or Beatrice Cuello ask you any
questions as to what should be done with Danny or
Shannon?
A. Ask me?
Q. Yes.
A. No.
Q. Did you tell either Hilliard or Cuello at
that point in time that Danny and Shannon were still
actively working with the FBI?
A. They were aware that they were assisting it.
Right, yes.
Q. Were you aware that Danny and Shannon were
scheduled to sign out an individual, Monk Fagus
(phonetic) from jail the next morning to proffer and
work with the FBI?
A. I don't recall.
Q. Have you ever heard the name -- nickname
"Monk" in connection with Operation Brass Tacks?
A. Yes, I believe so.
Q. And were you aware that the next day after
that meeting that Shannon and Danny were removed

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A. No.
Q. What training were they supposed to report
for?
A. It's retraining. Basically when you're
returning back to patrol after I believe -- and I'm
speculating -- after a certain time frame, I believe
it's over six months, they, what they call retread or
retrain you to make sure that you proficient at report
writing and so on, usage of the computer and so on.
That's my understanding.
Q. Do you know if it's a class or do they just
report to a particular individual?
A. That I won't be able to tell you.
Q. Do you know how long this retraining takes?
A. No.
Q. Do you know anything that it would entail
besides the computer?
A. I'm sure they touch on other subjects, but I
wouldn't be able to tell you.
Q. Do you have any idea how they were supposed
to know who was going to retrain them?
A. Apparently the academy personnel were going
to do it.
Q. Do you know in any way, shape or form how,

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generally, retraining takes place?
A. I'm not familiar. I mean, I couldn't tell
you details, but that's, again, I gave you a summary of
what I -- that I know.
Q. And you're not aware that they were sent
there the next day after the meeting?
A. I don't recall them being sent immediately
the next day. I know it did happen. I would be
speculating as to the time frame. But there was an
order, it came out and they were transferred.
Q. In terms of -- Have you ever recommended that
following a police officer's working with FBI
investigating other police officers that the police
officer, when the job is done, be reassigned to work in
IAD?
A. I'm sorry. Repeat that again.
Q. In terms of -- When you've had a situation
where an officer is working with FBI and investigating
other officers and when that -- that job, whatever
operation it is, is done or it stalls temporarily or
whatever, have you ever recommended that that officer
or those officers be reassigned to Confidents in IAD?
A. I never had that situation happen to me,
so ...

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Q. Did you ever talk with Tina Scahill about
what you should do with Danny and Shannon and whether
they should be moved into IAD?
A. I don't -MR. KING: I'm going to object to the form which I
think was two-part question. If you understand it, you
can answer.
BY THE WITNESS:
A. I don't recall a conversation going to
assigning them to Internal Affairs. We did have
conversations regarding trying to mask them and the
best way of doing that was there was supervision and we
can account for their tour of duty and there was an
agreement between myself, it was a discussion, but is
was an agreement that Scahill would have them detailed
to inspections when she was the chief of
accountability.
BY MR. SMITH:
Q. Did Scahill ever mention that it made sense,
or words to that effect, that would you consider taking
them into -- moving them into IAD?
A. I don't recall any conversation like that.
Q. You ever tell Scahill that you would consider
moving them to IAD?

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Q. Why didn't you recommend or ask that Danny
and Shannon be put into Confidentials at IAD to
continue Operation Brass Tacks at that time when Cuello
and Hilliard spoke to you?
A. Again, that's -- it's their decision.
They're my superiors. Basically, the way they
explained it to me is, they were looking to put people
back in patrol and that Spalding and Echeverria may end
up assigned to patrol.
Q. In terms of -- In terms of are you indicating
you didn't think you could even tell them you thought
one way or the other whether they should be put in
Confidentials and continue to work on
Operation Brass Tacks?
MR. KING: Object to the form of the question.
BY THE WITNESS:
A. Again, I mentioned it earlier. I explained
to them that it was a viable investigation and that
this could conclude in a positive manner.
BY MR. SMITH:
Q. Did you recommend what should be done with
Danny and Shannon at all?
A. They didn't ask me, but I explained to them
that this was still viable.

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A. I don't recall ever having a conversation
like that.
Q. You're aware that Danny and Shannon were
detailed to the police academy for three weeks?
A. You know, again, I don't recall the time
frame, but I know they were sent there for retraining.
Q. Do you know if anyone ever trained them
during that time?
A. That I don't -- I don't recall. I wouldn't
be able to tell you.
Q. Do you have any idea what they were doing
there?
A. I didn't ask. No, I don't.
Q. Did they ever call you and ask you what's
going on with me here?
A. They asked if I could help them and I told
them that I would started making phone calls and trying
to do what I can.
Q. Did they tell you they were doing nothing at
the time, just sitting in front of a desk?
A. No.
Q. Do you know who called you and asked you if
you could help them?
A. I believe it was Shannon.

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Q. In terms of was it before or after that
conversation with Shannon about where they were at that
you had the conversation with Tina Scahill about their
assignment?
A. The conversation was after and it was after
Kirby was able to reverse the transfer to patrol.
Q. How do you know that Kirby reversed the
transfer to patrol?
A. Because I went there to see her and I
explained to her that we should not allow that to
occur. It would not be a good message. We need
officers to come forward when there's misconduct or
corruption and that would be the wrong message to send.
She agreed and she told me she was going to talk to
someone above her to try to change or undo the
transfer.
Q. Did she ask you any questions on how Danny
and Shannon got moved in the first place?
A. I think we had a discussion as to what took
place. From what I recall, I mentioned to Kirby the
fact that I was called in to Interim Hilliard's office
with Bea Cuello on the conversation that took place.
Q. Did you tell Kirby about the perceived
insubordination?

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A. Yes.
Q. How did that occur?
A. Again, Deputy Superintendent Kirby was able
to undo the transfer and, as I mentioned earlier, the
decision was made to -- while nothing was -- no
progress was being made on the investigation to detail
them Office of Accountability under Scahill and that's
where they were detailed to, and during that time frame
eventually the investigation started to take -- to show
progress, I should say.
Q. Were you actually contacted by the FBI to
have them start working again?
A. Yes.
Q. Were you told why they were asked to start
working again?
A. The source. To make contact with the source.
Q. Were you aware that -- then that -- In terms
of when Debra Kirby reversed the prior reassignment to
patrol, were you involved in determining where Shannon
and Danny should be assigned to after that?
A. Yes.
Q. Who else was involved in that?
A. Regarding inspections?
Q. Correct.

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A. Yes.
Q. Did you discuss what that was about?
A. No. It was put as -- The conversation didn't
go well.
Q. Did Kirby tell you anything about what was
happening with Cuello and Hilliard?
A. No.
Q. Did Kirby know that Shannon and Danny were
moved at that time based on what you had heard from
her?
A. Yes, she's -- She's the one that actually
forwarded an e-mail to me with the personal transfer
which listed Spalding and Echeverria being transfer the
out to patrol.
Q. And that was before you even knew they were
being transferred out?
A. Yes.
Q. Did Brass Tacks ever start back up again
after Danny and Shannon were initially removed?
MR. KING: Object to the form.
BY MR. SMITH:
Q. Let's put it this way:
Were they ever reassigned back
to Brass Tacks, Danny and Shannon, in some form?

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A. I believe I had a conversation with Scahill
who, as I mentioned before, was in charge of
inspections. It was under her Office of Accountability
and, obviously, our superior, which is Kirby, who
arranged the detail.
Q. Were Danny or Shannon asked if they wanted to
go to inspections?
A. No.
Q. Was there any discussion at that time with
respect to Danny or Shannon to see if they wanted to go
back to the Narcotics Unit?
A. No.
Q. Did you have any understanding of where Danny
and Shannon wanted to be assigned at that time?
A. As far as I know they wanted to work the
investigation.
Q. You're aware that they were moved to
inspections in approximately July of 2011?
A. You know what; I wouldn't recall the dates,
but I could say that they were detailed to inspections.
Q. Were you ever told that Patrick Smith was
being investigated and was removed from Brass Tacks?
A. I was told that there was an issue and I
think I mentioned it earlier that either it was some

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failure of documenting the use of the informant or
misuse of the informant.
Q. Was the investigation under Smith ever used
to prosecuted Watts, Mohammed or any of his team
members?
A. That, I don't know. That's something I
wouldn't know.
Q. Did the FBI ever admit that -- to you that
their Agent Smith had messed up the investigation and
it was not the fault of Officers Echeverria and
Spalding?
A. No.
Q. Did they ever tell you anything to the effect
of that Agent Smith had messed of the investigation of
Brass Tacks in any way?
A. No.
Q. Did they ever tell you that the investigation
under Patrick Smith and his removal had anything to do
with Danny or Shannon?
A. No.
Q. Did they ever tell that you Danny or Shannon
ever did anything inappropriate while they were working
with the FBI?
A. The only thing I can recall was a situation

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the equipment in it?
A. No.
Q. Did you hear anything about improper
paperwork by Smith regarding the vehicle?
A. No.
Q. Did you ever hear anything about the fact
that the vehicle -- a vehicle was taken away with
equipment in it?
A. No.
Q. Did you ever have a meeting with Rivera?
(Discussion between Mr. Smith and
Shannon Spalding sotto voce.)
BY MR. SMITH:
Q. Did you ever have a meeting with IAD
Commander Klimas in which this incident was brought up
and there was a refusal -- that there was a
determination that Danny and Shannon were going to
refuse to go -- report back to the FBI until the matter
was cleared up?
A. No.
Q. Would you remember any meeting with Klimas
and yourself regarding an issue concerning Shannon and
Danny and the FBI?
A. Again, I'm sure we discussed the missing

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where I believe it was mid -- I don't know if it was
July 2010 Echeverria called me and stated to me that, I
believe it was Agent Smith had questioned him regarding
some kind of equipment. I don't know if it was a
transponder or eavesdropping equipment that was
missing, and at that point in time the conversation or
the discussion got heated and I believe -- I believe it
was Patrick Smith told them that they were no longer to
report to the FBI facility.
Q. Do you remember when that was?
A. I think I mentioned, I don't know if it was
July of 2010 or somewhere in that range.
Q. Was that incident ever cleared up?
A. We -- I think, and again I'm going back here,
from what I could recall, I think there was inquiries
as to whether this was an issue for Echeverria or
Spalding and nothing came of it.
Q. And who did you ask if it was an issue?
A. I don't know if I went through Chester or we
called someone in my office, one of my command staff
called. I don't recall. I can't recall.
Q. Did you learn that Smith did not do the
proper paperwork to allow them to have an FBI vehicle
or equipment and the vehicle was taken away with all

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piece of equipment and the fact that they were told
they could no longer report to the FBI facility. So we
had to make other arrangements and I'm sure we had
conversations regarding that.
Q. Do you remember Tom Chester being present for
that?
A. I wouldn't -- I wouldn't be able to recall.
It's possible. I don't know. I can't remember.
Q. Do you remember that you issued Danny and
Shannon an IAD vehicle when the FBI vehicle was taken
away?
A. Yes.
Q. Did Danny or Shannon ever inform you that
they were being harassed by individuals in Unit 126
including Lieutenant Pasqua?
A. No, they didn't -- They didn't tell me they
were being harassed. What they basically said was they
did not want to be inside in administrative capacity
and they wanted to go back out and they wanted me to
assign a vehicle to them and radios. And I basically
told them that that would compromise them. I told them
they had to take direction from the supervisors there,
and they were having a hard time doing that. And there
was a lot of miscommunication with regards to what they

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were being told to do and their refusal to cooperate.
Q. Did you have any idea what they were doing at
Unit 126, what type of work?
A. Whatever inspections, whatever the
supervisors assign them to.
Q. Did they ask with discuss with you at all
what the actual work was?
A. Administrative work.
Q. In terms of what type of administrative work?
A. No, I didn't get into details.
Q. Did they ever tell you that they went to
Commander Stanley about the retaliation and
inappropriate contact of Lieutenant Pasqua.
MR. KING: Object to the form of the question.
"Inappropriate."
THE COURT REPORTER: Did you answer?
THE WITNESS: I'm sorry. Can you repeat it.
BY MR. SMITH:
Q. I can repeat it.
Did they ever tell you that they went to
defendant -- I mean, went to Adrienne Stanley about the
conduct and harassment of Lieutenant Pasqua at 126?
MR. KING: Same objection to the form. Lack of
foundation.

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A. No.
Q. Did you ever tell them to hang in there?
A. No.
Q. If Shannon or Danny Echeverria had told you
that Pasqua was calling them "Rat" and harassing them
for being individuals who had worked in
police-on-police investigations and that they felt that
they were being harassed and weren't getting treated
fairly in Unit 126, would you have initiated a CR
against Lieutenant Pasqua.
MR. KING: Just object to the form and
hypothetical, but you can answer.
BY THE WITNESS:
A. If that was brought to my attention?
BY MR. SMITH:
Q. Hypothetically speaking.
A. Yes.
Q. Do you think it would be your obligation to
do so?
A. Yes, and I would expect the officers to
document and submit a report regarding the details.
Q. In terms of -- Do you know a Mike Barts?
A. Yes.
Q. Did you know that he was assigned to

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BY THE WITNESS:
A. No.
BY MR. SMITH:
Q. Do you know Lieutenant Pasqua?
A. I know of her.
Q. Was there an occasion where you had to issue
or ask for a CR with respect to her?
A. No.
Q. Did she ever ask for a CR with respect to
you?
A. "She" meaning?
Q. Lieutenant Pasqua.
A. No.
Q. Did you ever have an issue with
Lieutenant Pasqua in terms of that was a negative
situation?
A. No, I had very little contact with Pasqua.
Q. Did you ever tell Shannon or Danny that
Lieutenant Pasqua is nuts?
A. No.
Q. Did you ever tell Shannon and Danny that
Pasqua is nuts and hates you for working with Rivera
because he had a past issue with her and asked for a CR
number?

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investigate a CR with respect to Shannon Spalding?
A. Yes.
Q. Did you know that he was also assigned to
investigate the CR that was initiated because of the
filing of this lawsuit?
A. Again, I don't recall if that's the case or
not. I'd have to ...
Q. Would it surprise you to learn that an
investigator who was assigned to investigate a CR
against for another incident involving the allegations
in a complaint would be assigned also to investigate
the complaint itself?
A. No.
Q. Did you know any of the details of what
Mike Barts did during the investigation of Shannon?
A. No, I wouldn't have details on it.
Q. Would you think it would be appropriate for
an investigator in Internal Affairs tell a police
officer who had a CR that she was under arrest -MR. KING: Object to the form. Calling for
speculation and lack of foundation.
BY MR. SMITH:
Q. -- while investigating a CR?
A. Again, your asking me to speculate on

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something. I can't answer that.
Q. Are you familiar at all with that CR?
A. I don't have details. I wouldn't know
details, no.
Q. Did you ever review that CR?
A. No.
Q. Would you have -- we already mentioned -Would you agree that it was probably around
October 2011 that Danny and Shannon were called back to
assist the FBI with the completion of
Operation Brass Tacks?
A. I would be speculating. I don't know the
exact date.
Q. Would you agree that Danny and Shannon
continue to work with the FBI until the arrest -- with
the case with the FBI until there was arrests and
indictments of Ronald Watts an Kallatt Mohammed?
A. Yes.
Q. Would you have any problem with the date of
February 2012?
A. That sounds about right.
Q. After that time you would agree that Shannon
and Danny weren't sent back to Narcotics or Organized
Crime Division, correct?

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overtime stipend and a vehicle, and I told them that
wouldn't be up to me, that I would take it up the
chain.
Q. Did you ever sit down and talk with them and
say what's going on here? How urgent is the situation
for you to move? Why is it so bad?
A. No.
Q. And Shannon Spalding never ever told you that
it's a hostile work environment and they wanted you to
initiate a CR investigation into what people in 126
were doing with respect to her?
A. No, and again, I would a expected a to-from
detailing the alleged misconduct.
Q. When you took that CR you spoke of regarding
Hernandez and Sergeant Padar when she reported to you,
did you have her do a written report at that time?
A. In that circumstances, no, because she
approached me as advice is the way she put it.
Q. So even -- and if you -- She would have
orally asked you to do a CR against Pasqua,
Lieutenant Pasqua, would you have refused to do a CR.
MR. KING: Just object to the lack of foundation.
THE WITNESS: I'm sorry.
MR. KING: No evidence what the CR would be about.

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A. That's correct.
Q. They returned instead to Unit 126?
A. They were in Unit 126. They were detailed.
Q. Was there any effort at that time to find
another unit for Danny and Shannon?
A. They had asked me to help them. They wanted
to go to an FBI task force and I think I had mentioned
the Fugitive Apprehension Unit which is a sought after
position unit and they were okay with either one. I
told them I would have to check with my superiors and
that's what I did.
Q. Do you recall if Shannon at or about that
time told you that she was experiencing anxiety
attacks?
A. No.
Q. Do you recall if at any point in time Shannon
ever told you that she was experiencing anxiety
attacks?
A. No.
Q. Did you recall having any conversations with
Shannon indicating that she was upset and having real
difficulties being in Unit 126?
A. No. She just wanted to -- They insisted on
an FBI task force and their whole object was to get

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BY MR. SMITH:
Q. If she had said Pasqua was hostile calling
her rats and treating her poorly because of what she
thought of her having investigated a fellow officers,
would you have refused to do a CR if there was no
written report she had created?
A. The fact is that never happened.
Q. I'm asking you hypothetically.
A. Again, you want me to speculate on something
and I wouldn't be able to answer that. You want me to
speculate on something that didn't happen.
Q. So it you might -- You might have done one
anyhow without a written report and you might not have?
MR. KING: Objection to the form. Calling for
speculation and asked and answered already.
BY THE WITNESS:
A. Again, I would have expected the officer to
have a written to-from documenting the details of the
allegations.
BY MR. SMITH:
Q. And the Hernandez incident, did you have
Hernandez do a written report?
A. I had him meet with a supervisor and I took a
statement, obviously, because I was in the field.

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Q. But he didn't do a written report?
A. Again, he met with the investigators and they
took his complaint.
Q. As you sit here today, do you know if
Hernandez did a written report or not?
A. I don't recall. What I recall is I referred
them to my supervisor and he went into Internal Affairs
where the supervisor spoke to him and took his
information and documented it.
Q. Do all CR numbers have written reports that
come from officers?
MR. KING: Object to the lack of foundation, the
form of the question.
BY THE WITNESS:
A. Again, they should.
BY MR. SMITH:
Q. As far as you know, you have been working
IAD for a long time now; do the CRs you've seen, do all
of them are reports from the officer?
A. There is some anonymous complaints that come
in. There's some complaints that came through e-mail
to IPRA.
Q. And some are verbally made, correct?
A. Usually, if they were verbally made to a

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Q. Yes.
A. Yes, I arranged it.
Q. In terms of -- Before you arranged that, did
you receive a call from Chief Tom Bryne telling you
that Danny and Shannon should be sent to Fugitives?
A. No, approached Tom Bryne after the officers
told me they knew him.
Q. And when you approached Tom Bryne, did he
already know of the situation?
A. No.
Q. And Tom Bryne didn't call you first?
A. No.
Q. Were you aware -- Did he make you aware that
Danny and Shannon had talked to him?
A. If he had, he didn't mention it. I wasn't
aware.
Q. And Tom Bryne, he did indicate that he knew
Danny and Shannon?
A. Yes.
Q. Did he indicate that he would be happy to
have them work for him in Fugitives?
A. Yes.
Q. Do you recall an occasion where
Danny Echeverria told you that if you didn't get a CR

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supervisor it's a report, according to the directive,
is generated the supervisor initiates the log.
Q. Isn't it true that if an officer goes to a
supervisor and tells them about improper conduct that
the supervisor's actually mandated to write a written
report, a CR, take the CR?
MR. KING: Just object to the form of the
question. The use of the term "improper conduct."
BY THE WITNESS:
A. That's a separate report. That's the
initiation report.
BY MR. SMITH:
Q. The supervisor, the one who is told about it,
is the one who has to do the initiation report; is that
correct?
A. That's correct.
Q. Did Shannon and Danny ever tell you that when
they were in Unit 126 they would have is sit idly for
an entire shift?
A. No.
Q. You're aware that at some point in time Danny
and Shannon were detailed to the bureau of Detective
Fugitive Apprehension Unit?
A. Was I aware?

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relating to the retaliation that Danny would go to an
outside unit to file a complaint?
A. No.
Q. Did you ever talk to Shannon or Danny about
their assignment -- the work and what it was like when
they were assigned to Fugitive Apprehensions?
A. They enjoyed it. We had a conversation where
they said they were fine. Um, and then at a certain
point, I'm not sure of the time frame, I believe
Echeverria called me and stated they had concerns
because they were getting reassigned to a different
team and they were complaining that the team they were
on was US Marshals team and they were going to a
fugitive -- I'm not sure what they referred to it as, a
fugitive street team. I questioned them about it
because I understood that they were going to a street
team in the first place.
So I told them that I was going to make an
inquiry with Tom Bryne and I subsequently did talk or
speak to chief Bryne and I asked him what was going on
with the movement of Shannon and Echeverria and he
stated that, in essence, they're increasing the size of
the Fugitives or creating additional teams and that
they were going to be part of the a new team. And I

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asked him if it was true whether they were on a -US Marshals team and being moved to to street team. He
said, no it's the same type of team doing the same type
of work. At that point in time I called Echeverria
back and I told him this is the situation, you're not
being moved to a -- you weren't a US Marshals team and
you're not being moved to a street team. You're going
to continue to work the same type of assignments that
you were working on the team that you were on.
At that point in time I asked them if they
knew who the sergeant was that was on a new team and
they gave me his name which was Tommy Mills. I then
told them -- I informed them that I knew him and that
he had worked for me and I told them that I would call
him and put a good word in with the sergeant.
Q. Is that the first time you talked to them
about their work at ...
A. Yes.
Q. At the Fugitives Unit.
Did either Danny or Shannon ever talk to you
about continuing being passed up for deputization with
the marshal?
A. No.
Q. And were you aware that at one point in time

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MR. KING: Object to the form and the lack of
foundation. Calling for speculation.
BY THE WITNESS:
A. Again, you want me to speculate on something
that didn't happen. I don't know.
BY MR. SMITH:
Q. Hypothetically speaking.
A. Repeat it.
Q. Would you agree that if the supervisor within
Fugitives -- or lieutenant or -- and/or the commander
of the Fugitive Branch Unit told the personnel working
in the unit that two rats from IAD were coming to work
here that that would be inappropriate conduct?
MR. KING: Same objections as to form, lack of
foundation and calling for speculation.
BY THE WITNESS:
A. Again, I would be speculating, but basically
in the manner you put it, yes.
BY MR. SMITH:
Q. Isn't it true that you warned Danny and
Shannon that they should be careful because stats in a
unit is a way for supervisors to falsify a case against
an individual or an officer, so that they should
document everything?

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they were reassigned to nighttime fugitive
apprehension?
A. No.
Q. Did Danny or Shannon ever tell you that they
were upset about being put in a nighttime unit?
A. No.
Q. Did Danny and Shannon ever tell you that they
were being mistreated and harassed and retaliated
against in the Fugitive Unit?
A. No.
Q. Specifically did they tell you any complaints
about Sergeant Brynes?
A. No.
Q. Do you know Sergeant Maurice Brynes?
A. I know of him and they -- Obviously, the
conversation I mentioned earlier, Shannon Spalding had
mentioned that that was the sergeant that they had been
working with and they were being moved to, like I
mentioned, a different team and they were upset about
having to move.
Q. You would agree that if a lieutenant or a
commander told their personnel that we got IAD rats
coming to the unit, that would be something that would
be inappropriate?

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A. No.
Q. Do you recall having any conversation of that
effect ever?
A. No.
Q. Did Tom Chester ever call you about Danny and
Shannon's difficulties at Fugitive Apprehension?
A. No, as I mentioned earlier the conversation
where they claimed they were being moved from a
US Marshals team to a street team, during that
conversation apparently he had called Chester and also
pointed that out to him. He then calls me and tells me
to expect a call because they're now complaining that
they were moved from a US Marshal's team to a street
team and shortly, thereafter, like I mentioned,
Echeverria did call me.
Q. Did you tell them that you were calling
Mills, Danny or Shannon, that were you calling Mills to
put in a good word for them?
A. Yes.
Q. Did you tell them that you were a person that
promoted Mills?
A. Yes. I -Well, strike that. If I can correct that.
MR. KING: Go a head.

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BY THE WITNESS:
A. I did not promote him. I nominated him.
BY MR. KING:
Q. But you told Danny and Shannon that you had
helped promote Mills?
A. That I had submitted him for promotion.
Q. And, in fact, you told them that when you
were doing it you said to them, We'll see where his
loyalty lies now?
A. No.
Q. Why did you tell them that you promoted
Mills?
A. Because I wanted to establish the fact
that -- that they realized that I had a good
relationship with the sergeant and that he had also
worked in Internal Affairs.
Q. Why did you think it was important to make
sure that they know that he already worked in
Internal Affairs?
A. Because, obviously, they were concerned that
they were going to be mistreated and they were
complaining that they were being moved from one team to
to another and I told them, you know, Tommy Mills
definitely will not have issues. He's a good person.

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Q. Do you recall telling Shannon and Danny
that -- or Shannon and telling them about your efforts
with Mills and indicating that your hands were tied and
this is their last chance, if you can't make is it here
your careers are over?
A. No.
Q. Do you believe after you spoke to Tom Bryne
that you explained to Bryne why Danny and Shannon were
being kicked off the team? I'm sorry.
Do you recall explaining to Tom Bryne that
Danny and Shannon were being kicked off of the team?
MR. KING: Just object to the form of the
question.
BY THE WITNESS:
A. First of all, it was put to me that they were
being move to a different team, not kicked off. And
like I said, I had a conversation with Tom Bryne. He
explained what was taking place and his explanation was
they were expanding the Fugitives Unit and they were
creating new teams and they were being assigned to a
new team.
BY MR. SMITH:
Q. So you didn't have a conversation with them
saying that they were getting kicked off?

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Q. You told them -A. Good supervisor.
Q. -- you thought there was a chance that he
might not have a problem with them being from IAD when
they complaining about everybody else calling them
Rats, isn't that correct?
MR. KING: Objection to the form. Lack of
foundation. States facts not in evidence. Certainly
misstates this witness' testimony.
BY THE WITNESS:
A. No. Again, I was not even aware that he was
the supervisor on a team that they were going to be
reassigned to until they told me.
BY MR. SMITH:
Q. Were you aware that -- Or did you ever speak
to Shannon or Danny about Shannon's being banned from
Chicago Police Headquarters at Homan square?
A. I'm sorry. Can you repeat that.
Q. Did you ever talk to Shannon or Danny about
the complaints that Shannon was being banned from
Chicago Police Headquarters at Homan Square?
A. Headquarters.
Q. Homan Square, period.
A. No.

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A. No.
Q. And there was no response by Bryne that he
was shocked and surprised that they were getting kicked
off a team?
A. No, he knew exactly why it was taking place.
Q. And you didn't think that -- Did you ever to
Shannon or Danny that things might get worse because
you're going over people's heads?
A. No.
Q. So you never heard -- Did you ever hear
anything about Shannon being told she shouldn't be
around Homan Square?
A. No.
Q. Or a guard house at Homan Square?
A. No.
Q. You're aware that Watts and Mohammed plead
guilty to extorting drug dealers?
A. Yes, the plead guilty.
Q. You're aware that in the plea it was
described that the criminal misconduct went back to at
least 2007?
A. Again, can you repeat that.
Q. Were you aware that in the plea Watts
described that his criminal misconduct went back to at

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least 2007?
A. Again, I don't recall reading that, but it's
possible.
Q. Did you ever talk to Sergeant Mills about
Danny or Shannon after they began to work with him?
A. I believe we may have had a conversation and
he was fine with them.
Q. Anything after that?
A. Afterwards he did call me, um, asking me for
advice and basically what he told me was that an
officer had relayed to him that they had heard or they
had observed Shannon and she was playing what they
believe was a recorded conversation on her phone with
regards to Tommy Mills and, obviously, the allegation
was that Shannon had recorded Tommy Mills.
Q. And what about did you tell him?
A. I basically told him that at that point in
time I don't know exactly where the eavesdropping law
was. I guess it was the eavesdropping laws were being
changed or so and I -- I advised him to call Legal
Affairs for advice.
Q. Did you ask him if he knew who or how
somebody says that they believed Shannon was taping
Sergeant Mills?

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Q. Is notification given in any way to the
subject of the complaint?
A. To the accused?
Q. Yes.
A. I'm sure it is.
Q. Do you know if this was done in this case?
A. That I wouldn't -MR. KING: Object to the form of "this case."
BY MR. SMITH:
Q. In the case of Shannon's CR and the
Tommy Mills complaint?
A. Can you repeat that?
Q. Do you know if Shannon Spalding was given any
notice that Sergeant Mills -- or there was a CR
initiated against her relating to this Sergeant Mills
accusation?
A. I don't recall if it was or not.
Q. Would it surprise you if she wasn't and she
was -- two male officers came to her unit and took her
into a room?
A. Again, you're asking me to speculate as to
something that I -- I don't know or have knowledge of.
Q. I'm asking you as the chief of IAD if it
would surprise you that that happened?

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A. Again, what he told me was there was an
officer who actually -- there was an officer who
actually had told him.
Q. Did he give you the name of the officer?
A. If he did, I don't recall.
Q. Did they do a written report? Did you have
him do a written report?
A. I don't know. I told him to get advice from
Legal Affairs and Tommy Mills apparently initiated a
number, an investigation.
Q. Do you know if he ever did a written report?
A. That I wouldn't be able to tell you.
Q. Did you know if it even met the criteria of a
CR?
A. Again, apparently after seeking advice from
Legal it must have met the criteria and he went
forward, I believe, with the CR.
Q. How long in your experience between the time
the CR was filed and -- a CR is filed and an
investigation initiated, is it usually within IAD or
within -- afterwards is interview done of the subject
of the alleged complaint?
A. Again, I would be speculating. It all is
contingent on the investigation.

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MR. KING: Object to the form and lack of
foundation and calling for speculation.
BY THE WITNESS:
A. Again, I'm speculating and I would -- I would
not know what their motives are as far as going to
what, interview?
BY MR. SMITH:
Q. Do you know if that would be proper
procedure?
A. To -Q. So approach and accuse at their work without
giving notification and take that person, a female,
into -- with two male investigators and take her into a
room at their job location?
MR. KING: Same objection.
BY THE WITNESS:
A. Again, you you want me to speculate. If it's
an allegation of criminal nature, yes, they would do
that.
BY MR. SMITH:
Q. Would that require a probable cause to do
that then?
MR. KING: Same objection. Go ahead.

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BY THE WITNESS:
A. Again, it's not -- no one is being placed
under arrest. They're just being interviewed or
questioned regarding ...
BY MR. SMITH:
Q. You're aware that if somebody is not allowed
to leave they're under arrest?
MR. KING: Objection to the form and calling for a
legal conclusion.
BY MR. SMITH:
Q. Correct.
A. Again, you want me to speculate as to whether
the person was or wasn't allowed to leave.
Q. No, I want you to acknowledge that if two of
your investigators or two people working under you took
somebody into a room and refused to let them leave,
that would have been tantamount to an arrest?
MR. KING: Same objection.
BY THE WITNESS:
A. Again, I would be speculating whether it was
criminal in nature as to what they were asking or
administrative.
BY MR. SMITH:
Q. Are your investigators informed that if they

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earlier, after the lawsuit.
Q. Did you talk about any other allegations that
plaintiffs had made in the lawsuit?
A. No.
Q. Did you talk about the press conference and
all with him?
A. I don't recall. I don't believe so.
Q. Did you see the press conference?
A. Yes.
Q. Did you talk to Debra Kirby about this
lawsuit?
A. I don't recall if I did or not.
Q. Did you talk to Kevin Sedowski about this
lawsuit?
A. No.
Q. Debra Pasqua about this lawsuit?
A. No.
Q. Commander Stanley about this lawsuit?
A. I think we did discuss that, you no, the
lawsuit was filed. I don't believe we got into
details.
Q. How long have you known Debra Kirby?
A. Again, off and on. I would say I knew of
her -- We came on the Police Department together, 1986,

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are going to take somebody -- arrest that they should
give them their Miranda Rights?
A. Again, you're asking me to speculate. If
they are going to arrest them, then, obviously, you
would give them the Miranda Rights. If your conducting
an administrative case or investigation that's totally
separate and apart.
Q. Did anyone ever find out if it's even against
again the law to record an officer while you were on
duty at that time?
A. Apparently and, again, you want me to
speculate, apparently sergeant pills spoke to someone
in Legal and they stated that it was illegal and he
moved forward with the CR.
Q. Did you ever talk to Sergeant Mills again
about at that CR?
A. No.
Q. In terms of this lawsuit, did you ever talk
to James O'Grady about this lawsuit?
A. No.
Q. Did you ever talk to Nick Roti about this
lawsuit?
A. Yes. We discussed, again, that's when he
mentioned the issue and I think we covered that

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but our paths didn't cross until probably 2005 when she
was the Assistant Deputy Superintendent of
Internal Affairs while I was the lieutenant there in
confidential.
Q. Did Nicholas Roti start with you in 1986,
also?
A. I'm not sure if he did. Possibly.
Q. How long have you known him?
A. I'm trying to think about that. It may have
been -- I might have met him years ago when I was in -I'm not sure if it's a specialized unit.
Q. How about James O'Grady, do you remember when
you met him?
A. I met him when he was in Narcotics. He was a
PO and I was a sergeant.
Q. And what -- Were you the sergeant of a team
that he was on?
A. No.
Q. I asked you a question about Len Lewellyn.
Did you ever work with Len Lewellyn?
A. No.
Q. Do you know Maurice Barnes?
A. I know of him from -- I believe he was in
narcotics also as a PO.

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Q. Did you ever talk to him about this lawsuit?
A. No.
Q. Do you know Lieutenant Robert Cesario?
A. Yes.
Q. How long have you known Robert Cesario?
A. Again, I don't know him all that well. I
think we took courses together, college courses.
That's -- That's a few years back.
Q. Did you ever talk to him about this lawsuit?
A. No. This lawsuit.
Q. Do you know Joseph Salemme?
A. Yes.
Q. How long have you known him?
A. Again, I believe he was in Narcotics when I
was there.
Q. Did you ever talk to him about the lawsuit?
A. I don't recall talking to him, no.
Q. Did you talk to Thomas Mills about the
lawsuit?
A. We may have mentioned the fact that there was
a lawsuit filed, but I don't believe we went into
details. I believe at the time we spoke he wasn't part
of the -- he wasn't part of the lawsuit.
Q. And do you recall him telling you that -- Do

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BY MR. SMITH:
Q. Do you see Exhibit No. 3 for identification?
Is a counseling session report. It's actually two
different pages.
Have you ever seen those before?
A. The first time I seen these were at the -- my
counselor's office.
Q. Do you recall ever speaking with either
Kevin Sedowski or, I guess, Adrienne Stanley about a
situation where Danny and Shannon were being given a
counseling session report?
A. I didn't speak to Sedowski. I e-mailed him.
Q. Why did you e-mail him?
A. Um, the day I e-mailed Sedowski, earlier in
that day Echeverria had called me and he informed me
that Lieutenant Sedowski had prepared counseling forms
and wanted to present them to them that morning.
At that point in time, I believe the officers
were involved in the investigation which had restarted.
I was not aware of the counseling forms until
Echeverria pointed it out to me, so I then e-mailed
Sedowski and, in essence, told him to hold off, because
I wanted to have a conversation, obviously, because I
was unaware of what the counseling forms were or what

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you recall him calling you prior to the lawsuit and
talking to you about the treatment of Danny and
Shannon?
A. No.
MR. SMITH: I'm just going to mark this as Exhibit
No. 2 for identification.
(Lieutenant Juan Rivera Exhibit 2
marked.)
BY MR. SMITH:
Q. Do you recognize Exhibit No. 2 for
identification?
A. Yes.
Q. And did you, in fact, sign off on the
overtime slips over Danny and Shannon for
November 21, 2011?
A. Yes.
MR. SMITH: I'm going to show you what's marked,
as well, marked as Exhibit No. 3 for identification.
(Lieutenant Juan Rivera Exhibit 3
marked.).
MR. SMITH: It's a two-page document.
MR. KING: It's two separate pages.
MR. SMITH: Yeah, it's two different.

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the issues were and so I e-mailed him to hold off.
Q. Did you have a conversation with anybody
about them?
A. No.
Q. Did you do anything further in relation to
the issue?
A. No.
Q. So you just sent an e-mail with just to hold
off?
A. Yes.
Q. And you never gave any further instruction on
them?
A. The instruction is we were going to have a
conversation, but it never -- it never came to fruition
and counseling forms were never presented to the
officers.
Q. Did you ever -- Do you know if you sent
that -- signed off -- did -After you signed off on the overtime, did you
give it to anybody?
A. I wouldn't even recall if I did or who -Normally, the officers take it to whoever handles that
either in 126 or 543 -- wherever they were assigned at
that time.

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MR. SMITH: Okay. Thank you.
I'm going to show you what we will mark as
Exhibit 4.
(Lieutenant Juan Rivera Exhibit 4
marked.)
BY MR. SMITH:
Q. Do you recognize Exhibit No. 4 for
identification?
A. I recall the e-mail, yes.
Q. Can you see the date on it?
A. Let's see. Fifth of November. Yes.
Q. Fifth of November of what year, just for the
record?
A. 2010.
Q. Do you have any recollection of what that was
about?
A. No.
Q. Do you have any recollection at all about an
urgent situation that Danny was calling but at that
time?
A. I can't recall every -- no.
MR. SMITH: I'm going to show you what we'll mark
as Rivera Exhibit No. 5 for identification.

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sheet?
A. Yes.
Q. So -A. I acknowledged it, 10-4.
Q. And what did you acknowledge?
A. The fact that they were at the offices there.
Q. Did you contact Mr. Klimas receiving that
e-mail?
MR. KING: Object -- Other than him replying to
the e-mail?
BY MR. SMITH:
Q. Yes. Other than the 104.
A. I don't recall. I know they were there for
one specific reason and that was to determine how we
were going to deal with the fact that they had nowhere
to report.
MR. SMITH: I'm showing you what we'll mark as
Rivera No. 6 for identification.
(Lieutenant Juan Rivera Exhibit 6
marked.)
BY MR. KING:
Q. Do you recognize what we've marked as
Exhibit No. 6 for identification?
A. It's the notice that they were going to be

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(Lieutenant Juan Rivera Exhibit 5
marked.)
BY THE WITNESS:
A. Yes, I recall this.
BY MR. SMITH:
Q. Do you recall -- Can you read the date of
that e-mail?
A. The 27th, July, 2010.
Q. And is this an e-mail that you received or
sent?
A. This was an e-mail I received from
Commander Klimas.
Q. Do you recall what this e-mail was about?
A. If I am correct, it's with regards to the
officers being told they were no longer to report to
the FBI and at that point we were working at trying to
determine how we were going to make arrangements.
Q. Did you contact Robert Klimas after receiving
that e-mail?
MR. KING: You mean -- object to the form. Since,
I believe, they're two separate e-mails on this
exhibit, so ...
BY MR. SMITH:
Q. Are there two separate e-mails on the same

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sent to the academy for retraining and then assigned to
to patrol.
Q. Do you recall getting that notice at the
time?
A. Yeah, I received it.
Q. Did you make any calls to anyone after
receiving that?
A. If I'm not mistaken -- Again, I'm trying to
recall, actually received calls from Spalding and
Echeverria after this came out.
Q. You believe you did receive calls after that
came out?
A. Yes.
Q. Did you already speak of those calls in the
deposition earlier?
Let me ask you -- Let me just ask you:
What were the calls about?
A. They were -- They were upset that they were
going out to the academy for retraining and to patrol
and they wanted me to intervene and help them.
Q. Did you indicate you would?
A. Yes.
Q. And what did you do to help them?
MR. KING: Just object to -- to the extent that

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this has already been asked and answered. And if it
hasn't I withdraw that.
BY THE WITNESS:
A. Again, I told them I was going to look into
it and make calls. I was positive I spoke to Scahill
and, eventually, I think I mentioned it earlier, I went
in to see Kirby sometime after.
BY MR. SMITH:
Q. I think you did. Okay. Thank you.
MR. SMITH: I will show I what we'll mark as
Rivera 7 now.
(Lieutenant Juan Rivera Exhibit 7
marked.)
BY MR. SMITH:
Q. Do you recognize the e-mail that we've marked
as Exhibit No. 7 for identification?
A. Yes.
Q. Do you see this is an exhibit, May 9, 2011
e-mail from Robert Klimas?
A. Correct.
Q. Is that what you're looking at?
A. Yes.
Q. Do you see that you're cc'd on it?
A. Yes.

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(Lieutenant Juan Rivera Exhibit 8
marked.)
BY MR. KING:
Q. Do you recognize the e-mail that appears to
be an e-mail from Debra Kirby to Juan Rivera dated
May 12, 2011 regarding -- it indicates:
"Howard Spalding and Echeverria will not be
released for posttraining until I approve it. I will
be notified before anybody outside of the academy is
noticed. Thanks. Debra Kirby."
Do you recall receiving that e-mail?
A. Yes.
Q. Did you talk with Debra Kirby at all about
this e-mail or the content of it?
A. No.
MR. KING: Just object to the extent the response
calls for testimony that's already been given.
BY THE WITNESS:
A. No. Again, this e-mail was sent out by Kirby
after I went in and spoke to her and told her that we
should not allow the officers to be reassigned to
patrol and, therefore, she put a stop.
BY MR. SMITH:
Q. Anything further you recall about that?

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Q. Do you recall receiving this?
A. Yeah, I recall the -- I recall the e-mail,
yes.
Q. Do you know if anyone did a written synopsis
of what the officers were trying to do?
A. You know, I -- I don't recall and I believe
the commander was asking for it, so the commander might
have knowledge of this, the synopsis.
Q. Do you know if anybody -- Do you know who was
supposed to do the written synopsis?
A. Again, I'm just assuming. It says "Tom."
I'm assuming it's Tom Chester. I'm not 100 percent
sure.
Q. Do you have any recollection of talking to
Robert Klimas concerning a written synopsis on or about
that time?
A. I don't recall.
Q. Do you have any idea why was Robert Klimas
was seeking a written synopsis at that time?
A. I would assume the Superintendent's office
had made the request.
MR. SMITH: Mark this was Exhibit No. 8 for
identification.

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A. That's about it.
MR. SMITH: No. 9. Rivera No. 9 for
identification.
(Lieutenant Juan Rivera Exhibit 9
marked.)
BY MR. SMITH:
Q. Do you see that Exhibit No. 9 for
identification is an e-mail from Karen Konow dated
September 19, 2011.
A. Yes.
Q. To Robert Klimas, Juan Rivera and it reads:
"FYI, the next interview SIS will conduct in
the above case is PO Shannon Spalding. Let me know if
you need any additional info."
Do you see that?
A. Yes.
Q. Do you know what case this is -- Do you know
what case this is referring to?
A. No. I initiated two CRs. I'm not sure which
number this one is. I initiated one for
Shannon Spalding when she came in and made an issue of
Hernandez and Padar incident. And then I also
initiated -- I'm not sure -- I can't tell -- I don't
know what days -- But I was also contacted by her --

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now I understand it's actually her boyfriend,
Hernandez, months later asking me to initiate a number
for retaliation based on the first CR. So I'm not sure
which one this one is. I'd have to research and look
the number up.
Q. Just from my knowledge, what is "SIS"?
A. Special investigations.
Q. But this definitely dealt with something
related to the Hernandez-Padar incidents regardless of
which one or -It's not related to a CR directed at
Shannon Spalding?
A. She, I believe, is a witness.
MR. SMITH: No. 10. Mark that as Rivera No. 10
for identification.
(Lieutenant Juan Rivera Exhibit 10
marked.)
BY MR. SMITH:
Q. Do you recognize what's been marked as
Exhibit No. 10 for identification?
A. Yes.
Q. Do you see the it's from a Cynthia Curry do
you?
A. Uh-huh.

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as Exhibit No. 11 for identification.
(Lieutenant Juan Rivera Exhibit 11
marked.)
BY MR. SMITH:
Q. Do you recognize this to be an e-mail from a
Robert Klimas as that you were cc'd on October 5, 2011?
A. Yes.
Q. It reads that a:
"FBI needs assistance from Shannon Spalding
and Echeverria this afternoon. If possible please have
them contact Sergeant Boehmer for further
instructions."
A. Yes.
Q. Do you have any idea what, in particular,
this was concerning?
A. It involved Brass Tacks. Obviously, the FBI
needed them, if I am not mistaken, to contact the
source.
MR. SMITH: I'm going to show you what we'll mark
as Rivera No. 12 for identification.
(Lieutenant Juan Rivera Exhibit 12
marked.)
BY MR. SMITH:
Q. I think, if I'm not mistaken, the first part

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Q. On October 5, 2011?
A. Yes.
Q. And it reads that:
"Spalding a partner we're looking for you a
few minutes ago. If you need a ride and want Rick to
meet you downstairs, let's us know."
Do you know what -- Do you know if you spoke
to Shannon her partner after receiving this?
A. No, I don't recall if I did or not.
Q. Do you have any idea what this concerned?
A. No. Like I said, Spalding and Echeverria
would try to come on a regular basis to meet me and I
tried to discourage them, because they were doing it in
the open lobby. And then they started coming up to the
Internal Affairs front door which, again, I tried to
discourage.
Q. Do you know who Richard Pakula is?
A. He's a sergeant -- also an administrative
sergeant in Internal Affairs.
Q. Do you know why he would have been cc'd on
this memo?
A. He's administrative sergeant along with the
Cynthia Curry.
MR. SMITH: I'm going to show you what we'll mark

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is -- I will ask you later.
But if you look down at the bottom half that
starts with, "Cynthia Curry," it appears to be
October 14, 2011 to and you were cc'd amongst along
with Klimas, Welsh, Stanley, Mahoney, Pakula and Clark
and it was to Judith Martin and a Renata Adamovitz, and
then it reads:
"The Bureau of Internal Affairs submits the
names indicated below as requested; PO George Flores,
PO Daniel Echeverria, PO Matthew Kerlin,
PO Bridgid Hixson and PO Shannon Spalding."
Do you know what this was about?
A. This personnel was being detailed to the
International Association of Chiefs of Police
Conference.
Q. What would that be for?
A. Just police presence at the conference.
Q. Do you know why certain officers are
requested for that?
A. No, they just -- When there's a need for
officers, the First Deputy's Office looks for personnel
and details them out.
Q. So is this like for security or something?
A. It's possible. I'm not sure exactly what

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they were used for, but they're detailed out and that's
their tour of duty. That's their assignment.
Q. Okay. The top part of it, do you know if
that had -- the one that's from Cynthia Curry to
Judith Martin, do you know if that's just something
related to this assignment be present at headquarters?
A. It sounds as though -- Yeah. Rhodes is, I
believe, a police officer in Internal Affairs that was
also being detailed, but was being -- her -- her detail
was being changed to work the command post.
Q. Were you aware that Adrienne Stanley
called -- called Spalding at an FBI meeting telling her
she was going to Eddy Walsh to have her thrown out of
the unit for going to the FBI?
A. Who?
MR. KING: Object to the form and lack of
foundation.
BY MR. SMITH:
Q. Were you aware that -- Were you ever told
that Adrienne Stanley called Spalding -Turning back to the October 5, 2011 memo from
Klimas to Adrienne Stanley that reads:
"The FBI needs assistance of PO Spalding and
Echeverria this afternoon. Is it possible? Please

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to document it on to-from.
Q. In terms of -- Would you have expected
Tom Chester to document it on to-from if he had been
told by Adrienne Stanley that she was going to go to
Eddy Walsh.
A. No, I would have expected him to initiate a
number if Sergeant Mills received a report from the
officers.
MR. KING: Was it Mills?
BY MR. SMITH:
Q. Tom Chester, not Mills.
A. I'm sorry. Tom Chester.
Q. I'm going to show you what we'll mark as
Rivera No. 13 for identification.
(Lieutenant Juan Rivera Exhibit 13
marked.)
BY MR. SMITH:
Q. This appears to be an e-mail from -- it looks
like it might have something to do with the detail of
headquarters personnel, but it -- the second part is
from Adamovitz to Cuello and yourself as one of about
eight people named there, October 14, 2011, and it
indicates that:
"Attached, please comply with the attached

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have them contact Sergeant Boehmer for further
instructions."
MR. KING: What exhibit is that?
MR. SMITH: I think its -MR. KING: It's this one.
MR. SMITH: Here I can hand you this. It's also
DEFS00994 for identification.
MR. KING: We have that. That's already marked as
Exhibit 11.
BY MR. SMITH:
Q. Were you aware that after Spalding went to
that meeting that Adrienne Stanley indicated that she
was going to call Eddy Walsh to have her thrown out of
the unit for going to the FBI?
MR. KING: Objection to the lack of foundation.
BY MR. SMITH:
Q. Did Shannon and Danny ever tell you that?
A. No.
Q. Did Tom Chester ever tell you that?
A. No.
Q. Did Tom Chester ever tell you that Shannon or
Danny told her that Adrienne Stanley was going to do
that?
A. No. And, again, I would expect the officers

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directive."
Do you know what attached directive this is
referring to? And it looks like it might be that it
had to do with the headquarters, but if you don't know,
I mean, that's ...
A. No, I would be speculating, but I don't know.
MR. SMITH: I'm going to show you what we'll mark
as 14 for identification. DEFS00999 on the bottom.
(Lieutenant Juan Rivera Exhibit 14
marked.)
BY THE WITNESS:
A. Yes.
BY MR. SMITH:
Q. I'm also going to hand you a DEFS00997 and
998, because they may be related to that and I don't
want you to not have information available to you.
Do you see in the Exhibit 14 that it appears
to be a note from originally from Alan Boehmer to
Robert Klimas about Spalding, Echeverria saying that
they need their services tomorrow to find the source
and it's dated October 27, 2011?
A. Yes.
Q. It says:
"We now have a phone for him."

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Do you know what this was about?
A. Other than they're directed by the FBI to
find the source, because they were trying to work the
investigation.
Q. Okay. Thank you.
MR. SMITH: I'm going to show you what we'll mark
as 15.
(Lieutenant Juan Rivera Exhibit 15
marked.)
BY MR. SMITH:
Q. Do you recognize, this appears to be -- I
have two e-mails, one from Adrienne Stanley to
Cynthia Curry which your cc'd on and the second from
Cynthia to Adrienne Stanley which your cc'd on. And
the first one reads:
"Hi Sgt., We have two people who currently do
OPY, Sergeant Janice Barney, PO Jose Flores. I was
having PO Shannon and Echeverria sign up for it, but
they have been in the field for the last month."
Do you recall receiving that e-mail?
A. Um, I know I received it, but -- I mean -Q. Do you know what this concerns?
A. Just from reading it, it's obvious that the
commander wanted to utilize them for Operation Protect

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would have knowledge of?
A. No.
MR. SMITH: Exhibit No. 16.
(Lieutenant Juan Rivera Exhibit 16
marked.)
BY MR. SMITH:
Q. Do you recognize Exhibit No. 16 to be an
e-mail that you sent to Danny Echeverria on
January 27, 2011?
A. Yes.
Q. And were you intending to inform
Danny Echeverria of any positions that were available?
A. Yes, and opportunities.
Q. And what positions in particular were you
trying to notify him about?
A. The Fugitive Apprehension Unit that had just
started.
Q. Did you have any intent to notify him about
the sergeant's applications or detective applications?
A. Specific to the Fugitive.
Q. Did you send anything to the Shannon Spalding
about that?
A. I don't believe so. I really don't recall,
but I don't believe I did.

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Youth.
Q. And the second e-mail on this page appears to
be Commander Stanley:
"The Office of the First Deputy
Superintendent is conducting an audit of members
required to participate in Operation Project Youth for
the calendar years 2012. Members of rank Sergeant or
below in full duty status and assigned to the nonfield
duties on the 2nd Watch are required to participate.
Can you please provide me with the names of whoever
this applies to in the Inspection Division. Our
response is due no later than Thursday the
8th of December, 2011."
Do you recall receiving is that e-mail?
A. I received it, yes.
Q. Do you know if anyone had brought up these
e-mails at the time that you were informed of the
counseling review by Danny Echeverria?
A. No.
Q. Are you aware when somebody is and isn't
eligible for OPY?
A. I'm sorry. Repeat that.
Q. Do you know when somebody is eligible for OPY
and when one somebody isn't; is that something that you

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Q. Did you intentionally not send Shannon one,
or was it more so that you just thought Danny would
pass the word on?
A. Danny Echeverria was usually the one that
would pass the word.
MR. SMITH: Number 17 for identification.
(Lieutenant Juan Rivera Exhibit 17
marked.)
BY MR. SMITH:
Q. Do you recognize that?
A. Yes.
Q. Did you receive that or send that?
Is that from Danny Echeverria to you?
A. I believe that's his response.
Q. Do you know what that response was regarding?
A. Again, they were looking for positions in the
FBI task force because of the overtime stipend, the
overtime extra money and the vehicle, and I already had
the conversation and I told them that wasn't up to me
and I would present it to my superiors.
Q. Did you present it to your superiors?
A. Yes.
Q. What superior?
A. First Deputy Weisinger.

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MR. SMITH: Let's take a two-minute break.
(Recess taken.)
BY MR. SMITH:
Q. Just a question on Nick Roti.
Is it fair to say that other than the
Fugitive Apprehension Division, Nick Roti is in charge
of every other task force within the department?
A. I would be speculating. I'm not sure how
many tasks forces the department has.
Q. Do you know of any other task force other
than Fugitive Apprehensions that Nick Roti is not in
charge of?
A. I have one.
Q. What would that be?
A. Internal Affairs.
Q. Other than Internal Affairs?
A. Again, I -- Speculating, no.
Q. But other than Internal Affairs, are you
aware of any others, personally?
A. I don't have that knowledge.
Q. Did you think back at the time that Shannon
and Danny were asking to be assigned or not to be in
Fugitive Apprehensions or not to be in training or not
to be in investigations, were you aware of any task

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police vehicle on a day off and in uniform going and
making an arrest and then taking a backpack that the
FBI was aware contained $8,600?
A. Again, I'm sure I was briefed, but I don't
recall the facts.
Q. Do you know why after that operation or
surveillance of Ronald Watts was left on the streets -I mean, in his position as a Chicago police officer?
A. Again, that's something that I wouldn't know.
That's -- The FBI was the lead investigative agency and
US Attorney's Office was prosecuting.
Q. When Brass Tacks was postponed for that
period, was there any discussion on your part with any
supervisors to take Ronald Watts off the force or to
strip him of his badge and gun?
MR. KING: Object to the form and use of the term
"postpone."
BY MR. SMITH:
Q. The periods in which Brass Tacks -- When
Shannon and Danny Echeverria were removed from
brass Tacks, during that period, was there any
discussion about taking Ronald Watts off of active duty
in the Chicago Police Department?
A. I don't recall any conversations to that

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force other than Fugitive Apprehension and IAD that
were available that were not supervised by Nick Roti?
MR. KING: Objecting to the form. Compound.
Misstates evidence in the record.
BY THE WITNESS:
A. Again, I'm not familiar enough with all the
other bureaus. I wouldn't be able to give you an
answer.
BY MR. SMITH:
Q. Now, how often during Operation Brass Tacks
would the FBI update you either directly or through
Tom Chester about what was going on?
A. Again, it varied. Depending on what's taking
place with the investigation.
Q. Were you aware or did you become aware that
that there was a surveillance back -- in March of 2010
that there was a surveillance done where Ronald Watts
was seen stealing approximately $8,600 in a backpack in
the area of 11 West 26th Street, Chicago, Illinois?
A. Again, I was aware. I don't have -- You're
giving me details that I don't have. I was aware that
there was an attempt or there was a sting operation
conducted against him.
Q. And were you aware that he was seen driving a

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effect. Again, I would have to refer back to the fact
that the FBI was the lead investigative agency and
US Attorney was the prosecutor. It was their
investigation.
Q. During your briefings, were you aware that
several team members of Ronald Watts through the years
had been suspected of being part of Watts' team that
was extorting drug dealers?
A. Again, I wouldn't have detailed information
on that. That's something, again, that the FBI is the
lead investigative agency and the US Attorney is the
prosecutor, they would, obviously, have that
information.
Q. Were you given the names of active police
officers including current police officers in addition
to Ronald Watts and Kallatt Mohamad?
A. I personally was not given any names, but
again, the FBI was the lead investigative agency.
Q. Don't you, as IAD chief, have authority to
remove a sworn member from the department even if the
FBI is the lead?
A. Do not have the authority. I would have to
seek approval from the superintendent.
Q. And the superintendent could do that?

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A. Yes.

2

Q. Were you ever given the name Alvin Jones by

3 the FBI?
4

A. By the FBI, no. I don't recall the name.

5

Q. Anyone in connection with Brass Tacks ever

6 tell you about Alvin Jones being involved with
7 Ronald Watts?
8

A. Again, I don't recall, so ...

9

Q. Robert Gonzalez?

10

A. Again, I don't recall.

11

Q. Doreen Smith?

12

A. Again, I don't recall that name.

13

Q. Brian Bolton?

14

A. Again, I don't recall.

15

Q. You don't recall any of the names they

16 provided?
17

A. Again, you're saying "provided."

18

Q. Or gave information about?

19

MR. KING: Object to the form of the question.

20

There's been no testimony that any of those

21 names were given to Chief Rivera.
22 BY MR. SMITH:
23

Q. Did you ever get any other names besides

24 Watts and Mohamad? I mean Sergeant Watts and Mohamad?

Page 144

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Q. With regards to Sergeant Watts?
A. Again, I don't recall CRs coming through at
the time, so I can't answer that.
Q. Did IAD conduct its own investigation at all
of officers in relation to Operation Brass Tacks or
Ronald Watts in addition to the FBI?
A. Again, it was a joint investigation with the
FBI as the lead investigative agency and US Attorney as
the prosecutor. We assisted.
Q. Will IAD make any attempts to obtain FBI
information now that the Watts investigation and
Mohammed investigation resulted in convictions to see
what other information existed against other officers?
MR. KING: Objection. Calls for speculation and
certainly irrelevant.
BY THE WITNESS:
A. That was a question that was posed to the FBI
and US Attorney's office and they basically stated
there were no additional targets.
BY MR. SMITH:
Q. Who was that that made -A. I would have to -- I would have to refer to
Commander Klimas that had a conversation, I believe,
with Boehmer.

Page 143

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A. Again, when I was involved the targets were
Watts and Mohamad.
Q. In terms of that were suspects at least, were
you given any other names?
A. Again, I would have to defer to the FBI.
They had the lead on the investigation.
Q. But did they ever apprize you of any other
officers that were suspected for being involved?
A. I'm sure if they suspected them they would
have targeted them. I would have been aware of it.
Q. Did you produce any CRs to the FBI of
instances where Watts had previously been accused of
committing crimes, such as extortion, from drug
dealers?
A. Me personally, no.
Q. Do you know if they were given to the FBI?
A. Again, this operation was already ongoing
when I arrived there, so I would not ...
(Simultaneous speaking.)
BY MR. SMITH:
Q. Did you inform anyone in the FBI of the CR or
CRs that came across your desk while you were working
in IAD back in 2004, 2006?
A. With regards to?

Page 145

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Q. Were you present for the conversation?
A. I'm not sure if I was present for that
conversation. I know that information was relayed back
to me.
Q. By?
A. Commander Klimas.
Q. As a boss in IAD, were you aware of any
criminal allegations against Watts or Mohammed separate
from the Brass Tacks investigation?
A. This all -- Obviously, this investigation
stemmed from information that I was made aware of back
in '04. So is it was open investigation then.
Q. What happened with the separate
investigation?
A. Again, it wasn't a separate investigation.
It's related to the same investigation that was opened
up in 2004 when I was there.
Q. Were any findings made on any of the other -any of the CRs that existed?
MR. KING: Object to the form. Lack of
foundation.
BY THE WITNESS:
A. Again, I couldn't answer that. I wouldn't be
able to answer that.

37 (Pages 142 - 145)
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 Page 146

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MR. SMITH: I think we're almost done.
BY MR. SMITH:
Q. Do you know who Lieutenant Pigott is by any
chance?
A. I know of him, yes.
Q. Did you ever talk to a Lieutenant Pigott
about Danny and Shannon being at the academy?
A. I don't recall if I did or not.
Q. With respect to any other -- any CRs relating
to Watts and Mohamad, are you aware of any action that
was taken against either Watts or Mohamad in any of the
CRs?
MR. KING: Again, object to the form and lack of
foundation.
BY THE WITNESS:
A. Like I said, I wouldn't have any knowledge of
that.
BY MR. SMITH:
Q. Was there any discussion with IAD or with any
supervisors that, we're not going to take action so
that it doesn't interfere with the investigation?
A. It was no -MR. KING: Same objection.

Page 148

1 STATE OF ILLINOIS )
) SS:
2 COUNTY OF C O O K )
3
4
I, CHRISTINE LIUBICICH, a Certified Shorthand
5 Reporter within and for the State of Illinois, do
6 hereby certify:
7
8
That previous to the commencement of the
9 examination of the witness, the witness was duly sworn
10 to testify the whole truth concerning the matters
11 herein;
12
13
That the foregoing deposition was reported
14 stenographically by me, was thereafter reduced to a
15 printed transcript by me, and constitutes a true record
16 of the testimony given and the proceedings had;
17
18
That the said deposition was taken before me
19 at the time and place specified;
20
21
That the reading and signing by the witness
22 of the deposition transcript was agreed upon as stated
23 herein;
24

Page 147

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BY THE WITNESS:
A. There was no such conversation that I was
involved in.
MR. SMITH: I'm going to put an end to it unless
there is a -SHANNON SPAULDING: Okay. No.
MR. SMITH: No more questions.
MR. KING: We don't have any, either.
We'll reserve signature.
THE COURT REPORTER: Are you ordering?
MR. SMITH: Yes.
THE COURT REPORTER: What would you like?
MR. SMITH: Mini electric.
MR. KING: I'll take a copy, regular and mini
electronic.
(Proceedings concluded at
5:09 p.m.)

Page 149

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That I am not a relative or employee or
attorney or counsel, nor a relative or employee of such
attorney or counsel for any of the parties hereto, nor
interested directly or indirectly in the outcome of
this action.
IN WITNESS WHEREOF, I do hereunto set my hand
at Chicago, Illinois, this 22nd day of December, 2014.

<%Signature%>
Certified Shorthand Reporter
State of Illinois

12
13
14 CSR License No. 084-004594.
15
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38 (Pages 146 - 149)
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 Page 150
1

DEPOSITION REVIEW
CERTIFICATION OF WITNESS

1

ASSIGNMENT NO: 1975323
3 CASE NAME: Spalding, Shannon v. City Of Chicago
DATE OF DEPOSITION: 12/4/2014
4 WITNESS' NAME: Lieutenant Juan Rivera
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
Lieutenant Juan Rivera
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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Page 152
ERRATA SHEET
VERITEXT LEGAL SOLUTIONS MIDWEST
ASSIGNMENT NO: 1975323
PAGE/LINE(S) /
CHANGE
/REASON
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________
___________________________________________________

_______________
________________________
20 Date
Lieutenant Juan Rivera
21 SUBSCRIBED AND SWORN TO BEFORE ME THIS ________
22 DAY OF ________________________, 20______ .
23
___________________________________
Notary Public
24
___________________________________
25
Commission Expiration Date
Page 151

1

DEPOSITION REVIEW
CERTIFICATION OF WITNESS

2
ASSIGNMENT NO: 1975323
3 CASE NAME: Spalding, Shannon v. City Of Chicago
DATE OF DEPOSITION: 12/4/2014
4 WITNESS' NAME: Lieutenant Juan Rivera
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
Lieutenant Juan Rivera
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

39 (Pages 150 - 152)
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 Federal Rules of Civil Procedure
Rule 30

(e) Review By the Witness; Changes.
(1) Review; Statement of Changes. On request by the
deponent or a party before the deposition is
completed, the deponent must be allowed 30 days
after being notified by the officer that the
transcript or recording is available in which:
(A) to review the transcript or recording; and
(B) if there are changes in form or substance, to
sign a statement listing the changes and the
reasons for making them.
(2) Changes Indicated in the Officer's Certificate.
The officer must note in the certificate prescribed
by Rule 30(f)(1) whether a review was requested
and, if so, must attach any changes the deponent
makes during the 30-day period.

DISCLAIMER:

THE FOREGOING FEDERAL PROCEDURE RULES

ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.
THE ABOVE RULES ARE CURRENT AS OF SEPTEMBER 1,
2014.

PLEASE REFER TO THE APPLICABLE FEDERAL RULES

OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.