Case: 1:12-cv-O8777 Document 166-2 Filed: 02/02/16 Page 1 of 191 PageID #:909 Exhibit Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 2 of 191 PageID #:910 Page 1 1 2 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 3 4 5 6 7 8 9 10 CHICAGO POLICE OFFICER SHANNON SPALDING and CHICAGO POLICE OFFICER DANIEL ECHEVERRIA, ) ) ) ) Plaintiffs, ) ) vs. ) 12 C 8777 ) CITY OF CHICAGO, et al., ) ) Defendants. ) 11 12 13 Deposition of TINA SKAHILL, taken before 14 Linda M. Benda, C.S.R., Notary Public, in the County of Cook 15 and State of Illinois, at One North LaSalle Street, Suite 16 3040, Chicago, Illinois, on the 5th day of December 2014, at 17 the hour of approximately 9:30 o'clock a.m. 18 19 20 21 22 23 24 Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 3 of 191 PageID #:911 Page 2 1 There were present during the taking of 2 this deposition the following counsel: 3 4 CHRISTOPHER SMITH TRIAL GROUP, by 5 MR. CHRISTOPHER SMITH One North LaSalle Street, Suite 3040 6 Chicago, IL 60602 (312) 432-0400 7 On behalf of the Plaintiffs; 8 9 DRINKER, BIDDLE & REATH, by 10 MR. ALAN S. KING 191 North Wacker Drive, Suite 3700 11 Chicago, IL 60606 (312) 569-1334 12 On behalf of the Defendants. 13 14 15 16 ALSO PRESENT: Daniel Echeverria. 17 18 19 20 21 22 23 24 Page 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 (Witness sworn.) TINA SKAHILL, called as a witness herein, having been first duly sworn, was examined upon oral interrogatories and testified as follows: EXAMINATION by Mr. Smith: Q Good morning. Can you please state your name and spell your name for the court reporter? A Tina Skahill, Tina, T-i-n-a, Skahill, S-k-a-h-i-l-l. Q What is your current occupation? A Retired. Q Have you ever given a deposition before? A Yes. Q And before you retired what was your position? A Chief of the Chicago Police Department. Q How long were you chief of the Chicago Police Department? A I was chief in the Chicago Police Department from 2008 to 2013. Q What was your position in 2008? A In 2008 I was chief of Internal Affairs Division. Q How long were you chief of the Internal Affairs Page 3 1 INDEX 2 3 WITNESS: 4 TINA SKAHILL 5 Examination by Mr. Smith 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 5 1 Division? PAGE 4 2 A Until 2009. 3 Q Until 2009? 4 A Early 2009. 5 Q Where were you transferred to at that point? 6 A I then became chief of the CAPS, chief of CAPS. 7 Q Do you know why you transferred or what was the 8 reason for the transfer? 9 A At the -- it's at the discretion of the 10 superintendent. 11 Q Thank you. In terms of -- you understand you're 12 here on a deposition relating to a lawsuit filed by Shannon 13 Spalding and Daniel Echeverria? 14 A Yes. 15 Q And do you recall when you first met Shannon 16 Spalding and Daniel Echeverria? 17 A I don't know as to the first. I may have seen them 18 before. 19 Q Did you -- when you first -- were you with IAD -- 20 when you were the chief of IAD did you have a time where you 21 actually met with them? 22 A Yes. 23 Q And was that your first significant meeting with 24 either one of them? 2 (Pages 2 - 5) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 4 of 191 PageID #:912 Page 6 Page 8 1 A Yes. 1 A That was my understanding that they were working 2 Q So basically you may have seen them in passing, 2 with the F.B.I. and Chicago Police Department's IAD. 3 hellos and things of that nature up until that time? 3 Q How did Danny and Shannon first come to you? 4 A Yes, possibly. 4 A With Patrick Smith. 5 Q And maybe even more just based on the course of 5 Q And what was your understanding of why Patrick 6 business as a police officer? 6 Smith came to you? 7 A Possibly. 7 8 Q But certainly nothing that raises to the level of a 8 regular basis. 9 memorable occasion where you were either socially with them 9 A Q He needed them to work more closely with him on a Did you learn at that meeting how Shannon and Danny 10 or working closely hand in hand; is that fair to say? 10 had come to Patrick Smith? 11 A That's correct. 11 A I don't recall. 12 Q All right. In terms of do you recall back in 2008 12 Q Did you ever learn that Patrick and -- I mean that 13 meeting with a special agent, Patrick Smith? 13 Danny and Shannon went to the F.B.I. on their off time to 14 A Yes. 14 provide information to the F.B.I.? 15 Q And do you also recall that shortly before that 15 A I never heard that. 16 meeting you were contacted by Shannon and Danny? 16 Q Would there be any records that would show when 17 17 Shannon and Danny started working with the IAD? A I don't specifically recall that, but I do recall 18 meeting with Patrick Smith and Shannon and Danny. 18 19 Q And it was roughly the same time? 19 I'm not sure. A 20 A Yes. 20 21 Q And do you remember at all what happened in your 21 understanding that they were reporting to at IAD in relation Q I wouldn't know now if there would be any records. In terms of was there somebody who it was your 22 first meeting with Danny and Shannon? 22 to this matter? 23 A Yes. 23 24 Q And it was -- was it your understanding that 24 been before I became chief of IAD. A I don't recall specifically because that would have Page 7 Page 9 1 Shannon and Danny had gone and spoken with individuals at 1 Q And who was the chief before you? 2 the F.B.I. concerning a matter that involved Chicago Police 2 A There was no chief. There was an assistant deputy 3 Officers? 3 superintendent, and that was Assistant Deputy Superintendent 4 4 Kirby. A It was my understanding that they had been working 5 with IAD and the F.B.I. on an investigation. 5 6 Q When you first met with them? 6 the first meeting with Patrick Smith had you become head of 7 A Yes. 7 IAD? 8 Q In terms of where did you learn that they were 8 A I became head of IAD in March of 2008. 9 Q When do you think this meeting with Patrick Smith 9 working with IAD at that point in time? 10 A When I became chief of the Internal Affairs Q How long before this meeting with Patrick Smith, 10 was? 11 Division I was briefed on confidential investigations and 11 A Sometime in the summer. 12 with -- that the IAD was conducting. 12 Q Had you ever learned or seen or heard of Danny and 13 Q Who were you briefed by? 13 Shannon -- and/or Shannon working with someone at IAD 14 A I was briefed by then Assistant Deputy 14 between March and that meeting in the summer? 15 Superintendent Kirby. 15 16 16 investigation. Q And did Assistant Deputy Kirby tell you anything A When I was briefed by ADS Kirby about the Watts 17 about Danny and Shannon? 17 18 18 or see any sign that Danny or Shannon were working with IAD A Other than -- overall I don't remember specifics Q Other than coming from Debra Kirby, did you learn 19 but just that investigation on the Watts investigation and a 19 between March and the summer when there was the meeting with 20 myriad of others. 20 Patrick Smith? 21 Q In terms of when Kirby told you about -- Debra 21 A No, I don't recall any other -- 22 Kirby told you about the Watts investigation, are you sure 22 Q So do you believe that Debra Kirby knew that Danny 23 at that point she was telling you that Danny and Shannon 23 and Shannon had gone to the F.B.I. even before Patrick Smith 24 were involved in the investigation? 24 came to meet with you? 3 (Pages 6 - 9) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 5 of 191 PageID #:913 Page 10 1 MR. KING: Just object to the form of the question, 2 misstates the testimony but you can answer. 3 BY MR. SMITH: 4 Q Do you believe that Debra Kirby knew that Danny and 5 Shannon had gone to the F.B.I. before the meeting with you? 6 MR. KING: Same objections, lack of foundation. 7 BY MR. SMITH: 8 Q Did she specifically tell you anything about Danny 9 or Shannon being involved with the F.B.I. before Patrick 10 Smith's meeting with you? Did Debra Kirby tell you anything 11 specifically about Danny or Shannon? 12 MR. KING: Objection to the extent asked and answered 13 but if you remember anything else more specific. 14 THE WITNESS: Nothing other than what I said originally 15 that she briefed me on the Watts investigation when I became 16 chief of IAD and that Danny and Shannon were working with 17 IAD and the F.B.I. on the Watts investigation. 18 BY MR. SMITH: 19 Q If I told you that Danny and Shannon went to the 20 F.B.I. on their off time and were not working with the 21 F.B.I. until they came to see you and Patrick Smith, would 22 that surprise you? 23 A Yes, it would. 24 Q In terms of do you recall ever discussing with Page 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A I don't recall specifically. Q At the meeting what did Patrick Smith tell you was the reason that he needed Shannon and Danny? A He just said he needed them to be more available. Q Did he tell you why he needed them to be more available? A Just to help conclude the Watts investigation, to help the investigation. Q And did he -- do you remember why they -- at that point in time they weren't available enough? A They were in narcotics. They were not assigned to IAD. Q In terms of did you have any idea as to when they were able to work with the F.B.I. if they were assigned to narcotics? A They would be available to work during their working hours. Q Even when -- before the meeting with Patrick Smith? A Yes. Q In terms of how were they supposed to know which location to go to? MR. KING: Just object to the lack of foundation. MR. SMITH: If you know. THE WITNESS: I don't know. Page 11 Page 13 1 anyone from IAD who would have been supervising Danny or 1 BY MR. SMITH: 2 Shannon between March and the meeting with Patrick Smith? 2 3 3 and Shannon being assigned to -- over to the F.B.I., to work A No, they were not assigned to IAD. They were Q All right. So at the meeting did you approve Danny 4 assigned to narcotics. 4 with the F.B.I.? 5 Q In what capacity were they working with IAD? 5 6 A Assisting. 6 misstates the earlier testimony. 7 Q Assisting whom? 7 BY MR. SMITH: 8 A Assisting in the investigation of Sergeant Watts. 8 9 Q Who would have been -- who was involved in the MR. KING: Just object to the form of the question, Q I'm sorry. At the meeting when Patrick Smith asked 9 to make the -- Danny and Shannon available to him what was 10 investigation of Sergeant Watts from IAD? 10 your response? 11 A I don't recall specifically at this time. 11 12 Q And do you know who IAD was working with, what 12 available. MR. KING: Same objection. The testimony was more 13 F.B.I. agents they were working with from the summer of -- I 13 BY MR. SMITH: 14 mean, from March till the summer of when the meeting was? 14 15 A I don't recall. 15 What was your response? 16 Q That was the first time you met Patrick Smith, Q More available, available -- more available to him. 16 A I agreed. 17 correct? 17 Q And so was there any discussion at that meeting 18 A In the summer, yes. 18 about how they were going to be made more available? 19 Q Had you met any other F.B.I. personnel relating to 19 A Yes. 20 the Watts investigation prior to the meeting in the summer? 20 Q What was the plan with respect to that? 21 A I don't recall. 21 A That I thought they could be detailed to 543. 22 Q Did Debra Kirby tell you -- give you the name of 22 Q And why were they going to be detailed to 543? 23 any F.B.I. personnel working with IAD before you met Patrick 23 A That way it wouldn't indicate that they were 24 Smith? 24 assigned to -- that they were working with IAD directly. 4 (Pages 10 - 13) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 6 of 191 PageID #:914 Page 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 16 Q And why was that -- why were you doing that? Why 1 was it important to make sure that it didn't appear that 2 they were working for IAD directly? 3 A Because they were still operating as narcotics 4 officers. 5 Q And in terms of was there -- are there -- were 6 there safety issues that would be raised if it was clear 7 they were working with IAD at that time? 8 A No. The issue was for the integrity of the 9 investigation. 10 Q And how would that protect the integrity of the 11 investigation? 12 A Because they -- their use of confidential 13 informants from their narcotics assignment was going to be 14 utilized. 15 Q Why would detailing them to 543 protect the use of 16 their confidential informants? 17 A Because when they were operating in a district, 18 people saw them operating in a district. They wouldn't know 19 where -- that they were not operating as narcotics. If they 20 were to look they wouldn't know where they were operating 21 from. 22 Q Who wouldn't know where they would be operating 23 from? 24 A Their investigation, their participation in an investigation was the same as any other officer assigned to that investigation. Q I understand that, but I'm asking you did Shannon or Danny express to you a concern about if they were working on a matter like this that they would be assured that their identities would be kept confidential? A They were assured that their -- they were assured that they would receive the same level of confidentiality as all officers assigned to confidential investigations. Q And what level of confidentiality would that be? A A need to know. Only persons who need to know. Q What was your understanding of who needed to know that Danny and Shannon were assigned to work with the F.B.I. through Detail 543? A That depends upon a person's role. It also depends on the information that they seek and the time of that information. Q What was your understanding as to who knew that Danny and Shannon were involved in the Watts investigation immediately after the meeting with Patrick Smith? A Well, I knew and a confidential sergeant would know, confidential lieutenant in IAD would -Q And that would be -- Mr. Chester would be the Page 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A No one would. Q In terms of were they given -- Danny and Shannon given a story to tell people if they were asked what they were doing? A They might have been. Q Were they told that the matter would be -- the fact that they were investigating a police officer would be kept confidential? A It's a confidential -- the Watts investigation was already confidential. Q Were Danny and Shannon assured that their identities as being involved in the Watts investigation and being involved in an investigation of other police officers would be kept confidential? A Any involvement of any personnel in a confidential investigation is confidential. Q During the meeting were safety issues and confidentiality issues discussed, the meeting with Shannon and Danny when Patrick Smith came in? A Confidential -- the confidentiality of the investigation was stressed. Q And did Danny or Shannon specifically ask for assurances that their identity would be kept quiet in terms of being involved in an investigation like this? Page 17 1 sergeant or no? 2 A I can't recall specifically but -- 3 Q Tom Chester, does that ring a bell? 4 A Yes. 5 Q Who would the lieutenant have been? 6 A At that time it would have been Lieutenant West. 7 Q And who else, if anyone? 8 A I needed permission from Deputy Superintendent 9 Brust. 10 Q Anyone else? 11 A And he needed to make the request to the first 12 deputy. 13 Q Who was that? 14 A James Jackson. 15 Q Is that your understanding of who knew at the time 16 of the meeting that they were going to be -- or shortly 17 after the meeting that they were going to be involved? 18 A Well, and then when they worked for -- their 19 commanding officers of their units know that they're going 20 to 543. 21 Q And who would those have been? 22 A You know, Commander Roti and I can't remember who 23 was the chief of organized crime at that time. 24 Q What was -- did you contact Commander Roti to tell 5 (Pages 14 - 17) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 7 of 191 PageID #:915 Page 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 him about Danny and Shannon's reassignment? A You know what? I don't recall. I may have. Q What would you have told him? MR. KING: Object to the form. THE WITNESS: I don't recall. BY MR. SMITH: Q Would you have told him the nature of the investigation? MR. KING: Object to the form of the question. She doesn't recall whether she spoke to him. You're asking a hypothetical. BY MR. SMITH: Q Hypothetically, when you're working as chief in IAD and you had a confidential investigation, would you tell the commander, Roti, that -- the nature or the type of investigation that the confidential officers were working on? MR. KING: Same objections. THE WITNESS: Again it would depend on the investigation, and it also would depend on what information they would need to know. Everything remains fluid. BY MR. SMITH: Q In a situation such as this where there was going to be officers investigating fellow Chicago Police Page 20 1 Patrick Smith told you in that initial meeting? 2 A I don't recall anything else. 3 Q Do you remember anything Shannon Spalding told you 4 in that initial meeting? 5 A No. 6 Q Do you remember anything Danny Echeverria told you 7 in that initial meeting? 8 A No. 9 Q Do you remember assigning Danny and Shannon in -- 10 getting permission to assign Danny and Shannon to Unit 543 11 within days of that meeting? 12 A I don't know if it was within days, but I didn't -- 13 I don't assign. First deputy approves assignments. 14 Q Correct, but in terms of your contacting Brust, 15 that was within days of the meeting with Patrick Smith, 16 correct? 17 A I don't know if it was days but it was shortly 18 thereafter. 19 Q What would you consider shortly thereafter? 20 A That could be within a month or two. 21 Q Did you calendar the -- would you have calendared 22 the issue, or what would have triggered the event to call in 23 a month if you would have waited that long? Why would you 24 wait at all? Page 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Department officers including a sergeant related to 1 extorting narcotics from drug dealers or money, would you 2 have told that to Roti? 3 MR. KING: Objection, lack of foundation, calling for 4 speculation, hypothetical situation. 5 BY MR. SMITH: 6 Q Or would you keep something like that confidential? 7 Again this is hypothetically speaking. 8 A Hypothetically the individual would not need to 9 know a lot of details. 10 Q And you certainly wouldn't want to tip off even 11 Commander Roti of the whereabouts of where the target was,12 the -- who was the target and so on and so forth, correct? 13 A That's correct. 14 Q In terms of when you're in confidentials, would you 15 agree that you do consider that in addition to compromising 16 the investigation you also would not want the targets to 17 learn who the officers were that were investigating them for 18 the safety of the officers in the confidential 19 investigation? 20 A Safety is always paramount for any police officer 21 in any investigation, confidential or otherwise. 22 Q In terms of other than asking to make Danny and 23 Shannon more available, do you remember anything else 24 Page 21 A I don't make the assignment. I make the request. When the request is granted was not up to me. Q So when did you make the request? A Sometime shortly after the meeting. Q That would have been within days, correct? A I don't know. Q Would there be any reason you would have waited? A I don't know. Q Do you recall anything going on that would have caused you to wait? A That was five, six years ago, so I don't recall. Q You have -- do you have any reason to believe that as you sit here today that there was -- let's put it this way. Is it possible that you called immediately after the meeting? A It's possible. Q Did you keep any records relating to that meeting? A Not to my knowledge. I don't recall. Q Would you have made any notation or anything relating to the meeting? A I don't recall keeping anything. Q So when is the first time that there is any indication or notation that Danny Echeverria or Shannon Spalding were informed that they would be joining the 6 (Pages 18 - 21) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 8 of 191 PageID #:916 Page 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 investigation with the F.B.I. in their official capacity as police officers? MR. KING: Just object to the form of the question. THE WITNESS: I don't know when they learned of it. You'd have to ask them. BY MR. SMITH: Q If I told you that they had never been officially assigned in their capacity as police officers until that meeting, would you have any way of showing that that was wrong? MR. KING: Objection. She's already testified to knowing that before the meeting. Object to the form of the question. BY MR. SMITH: Q If I told you that it was their understanding that they had never been officially assigned in their official capacity as police officers to the F.B.I. -- to working with the F.B.I. until after that meeting, would there be any records or anything to establish that was incorrect? A I wouldn't know. Q You are aware that at some point in time Danny and Shannon were assigned to detached services, Unit 543? A Yes. Q And at that time they were to report directly to Page 24 1 or contact with Danny and Shannon during the time they were 2 working in Unit 543 when you were still the head of IAD? 3 A Yes. I would have had some contact probably. 4 Q And what was the nature of that contact? 5 A Status updates on the investigation. 6 Q In terms of those status updates, was there 7 anything that -- during those status updates that made you 8 feel that Danny and Shannon were doing their jobs? 9 A Oh, yes. I thought they were doing their job. 10 Q And in terms of did you hear anyone make any 11 complaints about Danny or Shannon during the time that you 12 were supervising or head of IAD? 13 A No. In their capacity in the investigation, no. 14 Q In any capacity? 15 A No, not to my knowledge. 16 Q Did anyone communicate to you that there was any 17 difficulties with Danny or Shannon while they were in the 18 narcotics unit before being assigned to Unit 543? 19 A I don't recall any complaint. 20 Q And in terms of when Danny and Shannon were working 21 in Unit 543, were you aware that at times during the 22 investigation into the police officers on Watts' team that 23 they were getting information on other narcotics activities? 24 A I don't recall. Page 23 Page 25 1 F.B.I. headquarters on Operation Brass Tax? 1 2 A Yes. 2 shouldn't develop leads for other narcotics arrests and Q In terms of did you ever tell them that they 3 Q At some point in time you no longer were head of 3 busts during the time that they were working on Operation 4 IAD, correct? 4 Brass Tax? 5 A Yes. 5 A No. 6 Q And you were replaced by Juan Rivera? 6 Q In fact, would you encourage -- if they found out 7 A Yes. 7 information about other narcotics activities that wasn't 8 Q And did you brief Juan Rivera in relation to 8 directly involved in Operation Brass Tax but the information 9 Operation Brass Tax? 9 developed through Operation Brass Tax, would you encourage 10 A Yes. 10 them to share it with fellow officers so that a bust could 11 Q Do you recall what you indicated regarding Danny 11 be made? 12 and Shannon's role with Operation Brass Tax? 12 13 A No, I don't recall. 13 calling for speculation. MR. KING: Just objection to the lack of foundation and 14 Q At any point in time did you learn that a -- do you 14 THE WITNESS: If that were to occur I would encourage 15 know who Commander O'Grady is? 15 and request and require that the information be shared. 16 A Yes. 16 BY MR. SMITH: 17 Q Did you ever learn that Commander O'Grady was aware 17 Q Did you ever learn of a time when Danny and Shannon 18 that Danny and Shannon were working on Operation Brass Tax? 18 believed that the fact that they were working on developing 19 A I don't know what Jim O'Grady knew. 19 information of crimes by a fellow sworn officer was leaked 20 Q So it's fair to say that you didn't know -- you 20 outside of the confidential circle? Did you ever become 21 didn't tell Juan Rivera that James O'Grady knew about 21 aware of a time when Danny or Shannon thought the fact that 22 Operation Brass Tax? 22 they were working on an investigation of officers was leaked 23 A I don't know. 23 beyond the confidential circle of individuals? 24 Q And in terms of when -- did you have any meetings 24 MR. KING: Just object to the form and the use of 7 (Pages 22 - 25) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 9 of 191 PageID #:917 Page 26 1 confidential circle. The testimony was on a need to know 2 basis, but you can answer. 3 THE WITNESS: Anybody who was involved in the 4 investigation or had knowledge was on a need to know basis 5 and that knowledge would have been limited. Everybody had 6 different levels of knowledge, and then it would change 7 depending on the time in people's roles as they changed 8 throughout the years. 9 BY MR. SMITH: 10 Q Did you ever learn that Commander O'Grady became 11 somebody who needed to know of Danny and Shannon's 12 involvement in Operation Brass Tax? 13 A I don't know what Commander O'Grady knew or didn't 14 know. 15 Q Did you ever come to know that Ernie Brown became 16 somebody who needed to know about Operation Brass Tax? 17 A I don't know what Ernie Brown knew or didn't know. 18 Q Did you ever come to know that Nick Roti became 19 somebody who needed to know about information concerning 20 Operation Brass Tax? 21 A Other than Commander Roti knowing that Danny and 22 Shannon were being detailed to 543 to assist IAD he would 23 not probably have known particulars of the investigation. 24 Q Was there ever a time where Danny or Shannon came Page 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 about Brass Tax? A Any conversations having to deal with that investigation with -- was prohibited with me, so -- but they were told to talk to Chief Rivera about anything connected with that investigation. Q What did you talk to Shannon and Danny about after you were no longer chief of IAD? A They were assigned to me when I was chief of the Office of Compliance, and they were assigned to detail to Unit 126, which was inspections, so they were under my command. Q Before they were assigned to Unit 126 did you ever speak to them at all? A Yes. Q What did you speak to them about? And I'm talking about after you were no longer chief of IAD. A I received information from them that they were no longer being detailed to 543. Q How did you receive that information? A I don't recall if it was either a text or an E-mail. Q Do you know who it was from? A Either Danny or Shannon. Q And do you recall specifically what the E-mail or Page 27 1 to you with any -- to discuss the possibility that 2 individuals outside -- other than people that were involved 3 or aware of the investigation were finding out about 4 Operation Brass Tax or their involvement in an 5 investigation? 6 A While I was chief of IAD nothing of that sort was 7 brought to my attention. After I was no longer chief of 8 IAD, I was prohibited from any discussions about that 9 confidential investigation. 10 Q So after you were outside of -- did you ever speak 11 with Danny or Shannon after you were no longer chief of IAD? 12 A Yes. 13 Q And did you ever speak to them about their concerns 14 with Operation Brass Tax after you left? 15 MR. KING: Object to the form of the word concerns. 16 THE WITNESS: Any discussions about Operation Brass Tax 17 were completely prohibited, and they were told to talk about 18 anything connected with that investigation with Chief 19 Rivera. 20 BY MR. SMITH: 21 Q And did they follow your orders and do that? 22 A I don't know if they did or not. You'd have to ask 23 them. 24 Q In terms of that they didn't talk to you anymore Page 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 text said? A Just that they thought they were being detailed to the 15th District. Q And did they say anything about being detailed to the 15th District in the text or E-mail? A I don't recall specifically but once they gave me that information, then I requested from then Deputy Superintendent Kirby if they could be detailed to 126 inspections. Q Why did you do that? A Because they then would be under me and Brass Tax was still an ongoing investigation. Q And why did you think that it was important that they were under you rather than being detailed to the 15th District? A Well, if they were there then IAD could still continue and the F.B.I. could still continue to utilize them for that investigation, which was still ongoing. Q And why wouldn't they have been able to do that if they were in the 15th District? A It would have been more difficult. Q Because why? A Logistically. Q When you say logistically, what do you mean by 8 (Pages 26 - 29) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 10 of 191 PageID #:918 Page 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 32 that? 1 A Because their duties would have been patrol duties. 2 They would have been answering calls for service. 3 Q So they couldn't have done both jobs at the same 4 time effectively? 5 A That would have been difficult to answer calls for 6 service. 7 Q Did you have any discussions with either Danny or 8 Shannon about you being brought -- them being brought to 9 Unit 126? 10 A I probably did. I just don't recall specifically, 11 but I know they were in agreement with the -- coming over to12 126. 13 Q Did you ever discuss with them any issues relating 14 to the fact that it might be better to assign them to IAD? 15 A I know they wanted to be assigned to IAD. 16 Q And is it true that you indicated that you thought 17 that would have been a good position for them to be assigned 18 to it as well? 19 A I thought it would have been a good place. 20 Q Did you, in fact, ever indicate that you didn't 21 understand why the chief of IAD, Rivera, wouldn't have 22 assigned them to that position? 23 A The chief does not have discretion as to who is 24 you ever talk with -- at that time with Kirby or Rivera about the possibility of putting them in IAD? A We discussed various places, I'm sure, but we had agreed and specifically discussed about 126, which was under me, and it was agreed that we would pursue -- that they would pursue that request. Q But I'm asking you did you talk to Kirby and Rivera specifically about putting them in -- the possibility of putting them in IAD? A It may have been in discussions about where they could be detailed, but again those assignments were not at the discretion of myself or Deputy Superintendent Kirby or Chief Rivera. We have no authority to assign or detail people anywhere. Q Okay. Understanding that, was there any discussion in terms of sending them to IAD and the reasons why it would be good versus the reasons why it could or couldn't happen? A Our discussion was primarily about 126 and that is where they were eventually detailed to. Q Was there any discussion about IAD? A As I said, I don't recall specifics on that point. Q Do you recall anything Kirby said at all about the issue -MR. KING: Object to form. Page 31 1 assigned to his unit. Assignments are not made by the 2 chief. 3 Q In terms of did you ever talk to them about the 4 fact that you couldn't understand why Rivera wouldn't have 5 made efforts to have them brought to IAD? 6 A I know Chief Rivera was very supportive of their 7 participation in the investigation and so, you know, you'd 8 have to talk to Juan if he was able to bring them over. He 9 may have tried. 10 Q Well, I'm asking you, though, did you ever talk to 11 Danny or Shannon personally and indicate to them that you 12 were surprised that Officer -- that Chief Rivera was not 13 making more efforts to bring them into IAD? 14 A No, I don't recall that. 15 Q Do you recall indicating any information to Danny 16 or Shannon about your disappointment with where they were 17 assigned? 18 A To -- 19 Q The fact that they were being sent to District 15. 20 A Oh, yes. I did not -- again I did not agree that 21 they should go to the 15th District, which is why myself and 22 Chief Rivera and Deputy Superintendent Kirby agreed that 126 23 in inspections would have been better. 24 Q And in terms of did you ever ask in terms of -- did Page 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 BY MR. SMITH: Q Before the agreement to send them to Unit 126 -A No. Q -- do you recall anything Debra Kirby said? A No, I don't. Q Do you recall anything Juan Rivera said before the agreement to send them to 126? A Not specifically, no. Q Do you recall what you said? A No. Q While in Unit 126, did Danny and Shannon report to you at all? A Yes. Q In what way? A Because I was chief of the Office of Compliance and so I was in command, and during the first part of -- what year was that? 2011, I think it was, the commander of inspections was absent for medical reasons, so I was the only exec commanding officer. Q How often would they report to you during that time period when they were with Unit 126? A Not often but at times they did. In fact, one time Danny drove me to a meeting. I had to go on a Sunday, and so he took me there. So it's a small unit so we all worked 9 (Pages 30 - 33) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 11 of 191 PageID #:919 Page 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 36 together. 1 Q So what -- was there any type of regular reporting 2 where they would actually come and meet with you and tell 3 you what they were doing and what their assignments were 4 or -5 A No. That wasn't required at that level. 6 Q Okay. And in terms of how often would you see them 7 physically in terms of just -8 A It's a close office so that could vary. I could 9 see people daily, weekly, regularly going in and out because 10 it's a small unit. 11 Q And in terms of when they came to Unit 126, did you 12 know what their assignment was going to be? 13 A Yes. 14 Q What were they assigned to do? 15 A They were going to be assigned whatever needed to 16 be done in that unit in inspections that was -- primarily 17 responsible for auditing and any other tasks that arose. 18 Q And in terms of -- what tasks needed to be done at 19 that point in time in Unit 126? 20 A Well, one of the things that I requested to be done 21 was in the summer we were tasked with assisting the 22 education and training division in training the entire 23 Bureau of Patrol in in-car camera. 24 before you got there or -A Yes. Q Do you know -- I take it you know Commander Stanley? A Yes. Q And how do you know Commander Stanley? A She was the commanding officer of inspections, and I was her boss but I've known Adrian Stanley for years as well. Q How did you first come to know Adrian Stanley? A Well, when I became a lieutenant I was assigned to the 21st District where she was the commander of the 21st District, and that was in 2001, and I was her CAPS lieutenant and also worked as her watch commander. Q In terms of when did you leave Unit 126? A In August of 2012 I became chief of special functions. Q Were, to your knowledge -A Oh, of 2011. Q August of 2011? A 2011, right. Q To your knowledge, were Danny and Shannon still assigned to Unit 126 when you left? A Yes, to my knowledge. Page 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q Do you know who within 126 was in charge of doing that? A Well, I requested that Danny and Shannon be sent to assist the academy in that training. Q And when would that have been? A Sometime, I think, in the summer of 2011. Q Who was their supervisor at that point in time, their immediate supervisor? A I don't know who their sergeant was at the time. Q How long was that in camera training assignment supposed to last? A Until the Bureau of Patrol was trained. Q Do you know a Lieutenant Pascua? A Yes. Q How do you know Lieutenant Pascua? A She was assigned to inspections and I've known her for many years as well. Q How did you first know her? A I first knew her when she was, I believe, sergeant in the Office of Legal Affairs. Q Do you know about when that was? A Oh, it would have been, I think, either in early 2000s, late 1990s, I think. I'm not sure. Q And Lieutenant Pascua, was she assigned to Unit 126 Page 37 1 Q Do you know who replaced you? 2 A That office was done away with. 3 Q The -- your position at 126 was done away with? 4 A Yes. 5 Q Do you know why that was? 6 A No. 7 Q So how long -- so it was only a short period of 8 time that you were actually supervising Danny and Shannon in 9 inspections? 10 A Yes. 11 Q When I say short period of time, I mean roughly 12 the -- sometime in the beginning of the summer until August 13 approximately? 14 A Yes. 15 Q Were you aware that Danny and Shannon stayed at 16 Unit 126 until -- within 126 until sometime in the spring of 17 2012? 18 A Yes. 19 Q In terms of once you left your position at 126, did 20 you have any contact with Danny or Shannon? 21 A Yes. 22 Q In what way? 23 A They asked me to recommend them for the fugitive 24 apprehension unit. 10 (Pages 34 - 37) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 12 of 191 PageID #:920 Page 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q In between the time you left and -- Unit 126 and the time that you -- they asked you to recommend them for the fugitive unit, did you have any contact with them, phone calls, meetings or anything? A No, not that I recall, no specific meetings or anything, but we see each other all the time, talk, speak. Q Casual conversation, okay. And in terms of when they were in Unit 126 while you were the chief, were you aware of any complaints about them? A No. Q In terms of did you have any problems with their work commitment while they were in Unit 126 under your command? A No, I did not. Q In terms of were you aware of any issues or problems they were having in terms of work at the F.B.I. during that time period? A No, I was not. Q And in terms of as far as you were concerned, were they properly notifying you or people within 126 when they would be working with the F.B.I.? MR. KING: Object to the lack of foundation. THE WITNESS: I don't know if that was an issue or not. I just know that was never brought to my attention. Page 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 recommendation? A Yes. Q What was that? A Basically about their work experience, that I felt their work experience and their character -- they would be good for the fugitive apprehension unit. Q Did you believe that their character was good and appropriate for the fugitive unit? A Yes. Q Did you believe that they had a good work ethic to work in the fugitive apprehension unit? A Yes. Q Did you have any personal complaints with the quality of either Officer Echeverria or Spalding's work? A No, I did not. Q Did you ever have any complaints with them on a personal level? A No. Q Did you perceive Shannon Spalding as any type of a complainer during the time you knew her? A No. Q Did you perceive Danny Echeverria as any type of a complainer during the times you worked with him? A No. Page 39 Page 41 1 BY MR. SMITH: 1 2 2 wanted to be Chicago Police Officers? Q So nobody ever told you that we don't know when Q Did you perceive Danny and Shannon as people who 3 Danny and Shannon are supposed to be with the F.B.I. and 3 A Yes. 4 with us, correct? 4 Q Did you perceive them as people who really enjoyed 5 A Not that I recall. 5 being Chicago Police Officers? 6 Q And in terms of they certainly were allowed to work 6 A Yes. 7 for the F.B.I. during that time period whenever needed? 7 Q Did you ever hear of any complaints about Danny or 8 A It was my understanding that's why they were there. 8 Shannon after you left Unit 126 relating to their work in 9 Q All right. So when they asked you for a 9 Unit 126? 10 recommendation or assistance in going to the -- how did they 10 A Not to my knowledge. I don't recall. 11 approach you relating to their attempt to move from Unit 126 11 Q Did you ever personally -- were you ever personally 12 to the fugitive division? 12 told by any supervisors within the Chicago Police Department 13 13 prior to the time of the filing of this lawsuit that there A I think I remember -- I think Shannon asked me to 14 write a recommendation for the fugitive apprehension unit, 14 was any problems or work-related deficiency by either 15 and I know it was a short window of time that it was needed, 15 Shannon Spalding or Daniel Echeverria? 16 and so I was able to write them up and hand deliver it. 16 A I don't recall it. 17 Q Who did you write up something to? 17 Q How about after the lawsuit was filed, did anyone 18 A I wrote it to Chief Tom Byrne of the detective -- 18 ever complain to you about Danny or Shannon or tell you that 19 Bureau of Detectives and hand delivered the recommendations 19 they were substandard officers? 20 to him. 20 A I don't recall. 21 21 Q In terms of did you actually speak to Tom Byrne Q Did Shannon or Danny tell you any details about why 22 they were receiving the recommendations? 22 about your recommendation? 23 A No, just that they wanted to go there. 23 A Yes. I hand delivered it. 24 Q And in terms of do you recall what you wrote in the 24 Q Did Tom Byrne -- to your knowledge, did Tom Byrne 11 (Pages 38 - 41) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 13 of 191 PageID #:921 Page 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 44 1 already know Shannon and Danny? 2 A I don't know if he did or not. Q Did you have any conversation with Tom Byrne about 3 4 the recommendations? 5 A Other than I hand delivered it, and I thought they 6 would be good candidates for that unit. 7 Q In terms of while they were -- and were you aware that at one point in time Danny and Shannon were sent to the 8 9 academy -- the training division of the academy after they 10 were in Unit 543? 11 A Yes. That's when I got the E-mail or the text 12 message, whichever. Q Were you aware of what they were asked to do at the 13 14 training academy? 15 A No, I wasn't. Q I'm going to show you -- in terms of after you made 16 the recommendation to put them in fugitive apprehensions, 17 did you ever have any conversations with Danny or Shannon 18 19 about their assignment and the work at fugitive 20 apprehensions? 21 A I don't recall. 22 Q Did you have any conversations with them about 23 Brass Tax after they were assigned to the fugitive 24 apprehension division? A I think when it was in the paper. Q Did you talk to anybody about the lawsuit? A Other than the attorney. Q Well, other than the attorney. When you first heard about it. A I don't recall specific -- any specific conversations about it. Q Do you know -- of course you know Juan Rivera, correct? A Yes. Q When did you first meet Juan Rivera? A Juan and I were both made sergeant at the same time. We were in the same sergeants class. Q Is that when you met him? A Yes. Q At least that you know of? A Right, that I know of. Q And I may have already asked you this. When did you first meet Debra Kirby? A For many years. It's many, many years. Q Over 15, over 10 years? A It would probably be over ten years. Q And just -- what year did you start with the Chicago Police Department? Page 43 1 A 1 A 1982. 2 investigation was still ongoing was prohibited. 2 Q Did you do any other law enforcement before then? 3 Did you have any conversations with them about 3 A No. 4 Brass Tax during the time where Watts and Mohammed were -- 4 Q And do you know James O'Grady? 5 after they were already charged and during the time in which 5 A Yes. 6 they were being prosecuted? 6 Q When did you first meet James O'Grady? 7 A I think just in passing them saying it was over. 7 A I don't recall specifically. 8 Q But nothing in terms of details? 8 Q Do you remember being involved in any meetings with 9 A No, no. 10 Q And then in terms of while they were with the Q Any conversations about Brass Tax when that Page 45 9 James O'Grady relating to Shannon or Danny's assignment? 10 A I don't recall. 11 fugitive apprehension unit did you have any conversations of 11 Q Do you recall being involved -- and you knew 12 any significance during the time period that they were 12 Nicholas Roti. How long did you know Nicholas Roti for? 13 there? 13 A A number of years. 14 A No, not that I recall. 14 Q More than ten? 15 Q Did they -- did you contact them on a regular basis 15 A Possibly. 16 even after they were at fugitive apprehensions? 16 Q Do you remember Nicholas being involved in any 17 A No. 17 meetings where Nicholas Roti was present concerning the 18 Q Did they contact you on a regular basis? 18 assignment of Shannon or Danny? 19 A No. 19 A Not that I can recall offhand. 20 Q Would you ever ask them questions about whether or 20 Q Do you know Sergeant Maurice Barnes by any chance? 21 not they were having problems because they had been involved 21 A I may but I can't recall. 22 in investigating fellow officers? 22 Q Okay. Do you know Lieutenant Robert Cesario? 23 A I don't recall that. 23 A I do but I don't know how long I've known him. 24 Q When did you first hear about the lawsuit, if ever? 24 Q Do you know what way you came to know him? 12 (Pages 42 - 45) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 14 of 191 PageID #:922 Page 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A No. Some people I'm familiar with because I was at the training academy for six years and so people came through there, so -Q Joseph Salemme, S-a-l-e-m-m-e? A Yes, I know him. Q Do you know him socially? A No. Q In terms of do you consider yourself social friends with Juan Rivera? A No, no. Q How about Debra Kirby? A No, not socially, friends, colleagues but not socially. Q Friends through work? A Friends through work, yes. Q James O'Grady, social friend? A No. Q Friends through work? A Just acquaintance. Q Nick Roti? A Again more of an acquaintance. Q Deborah Pascua, would you consider that a friend through work or -A More of an acquaintance. Page 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 they were somewhere else at the time of the meeting? A I don't recall. Q A time due slip, do you know what a time due slip is? A I know what a time due slip is but -Q Were you aware that they had called and asked for a meeting the day before you met with Patrick Smith? A I don't recall. Q And that they were told to come in for a meeting the next day after they called? A I don't recall. Q Do you know how it was that the meeting with Patrick Smith was set up? A No, I don't recall. Q Do you recall that Patrick Smith -- at all how the fact that Patrick Smith came in separate from Danny and Shannon? A I don't recall who came in first or -Q Do you remember having a discussion with Patrick Smith before or at least separate from Danny and Shannon? A I don't remember. Q In terms of when you met with -- first met with Danny and Shannon, they never used the term Brass Tax, correct? Page 47 1 Q What about Adrian Stanley? 2 A More of a friend. 3 Q So that would be more of a friend? 4 A More of a friend, right, relationship with 5 Commander Stanley. 6 Q Do you know a Thomas Mills? 7 A I don't recall. 8 Q Obviously you've met a lot of people over the 9 course of -- I'm not even going to say how many years but -10 if we could take a couple minute break. I don't think it's 11 going to be much longer. Maybe my guess at this point is 12 ten minutes more. 13 (Brief recess was taken.) 14 BY MR. SMITH: 15 Q I'm going to take you back to the meeting where you 16 first met with Patrick Smith and you first talked with 17 Shannon and Danny about the investigation. How was Shannon 18 and Danny's appearance to meet with you arranged? 19 A You know, I don't recall specifically. 20 Q Were you aware that Danny and Shannon called and 21 made an appointment with you? 22 A That's quite possible. I just don't recall. 23 Q And were you aware that Danny and Shannon would 24 have put in a slip for their time to come in reflecting that Page 49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A I don't recall. Q Okay. Is it fair to say that if you got a message from an officer, even an officer you didn't know and -- when you were the head of IAD, if they had requested a meeting with you that was confidential that you would have honored that and most likely arranged for a meeting? MR. KING: Objection to the form and lack of foundation, calls for a hypothetical. You can answer it. THE WITNESS: Hypothetically speaking it's probable. BY MR. SMITH: Q Because you understand as chief of IAD if somebody has something confidential, it may well be something that needs to be private and protected information? A If an officer -- even if I wasn't head of IAD, if a member wants to talk to me in private, I normally honor that request with a supervisor present. Q And do you know who Barb West is? A Yes. Q Who was she when you were the chief of IAD? A When I was chief of IAD she was my lieutenant over at confidential investigations. Q And at times would she tell you if somebody was requesting a meeting? A She could but -- 13 (Pages 46 - 49) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 15 of 191 PageID #:923 Page 50 1 Q Taking you to the point in time where you were Page 52 1 Q Were you aware that it was an -- over a ten year 2 involved in helping Danny and Shannon get reassigned to your 2 investigation? 3 Unit 126 at the time, do you recall finding out that they 3 A I don't recall specifically. 4 were sent from the -- to the academy before being sent to 4 Q When you were being briefed about -- were you 5 your unit? 5 briefed at all from the F.B.I. about what was going on in 6 6 the investigation? A Yes. They told me, I believe, in the E-mail or 7 text message. I knew that they were at the academy and were 7 8 leaving there possibly to go to 15th. 8 confidential investigations including the Watts 9 Q And do you recall that they were taken off Brass A I would meet monthly with the F.B.I. to discuss all 9 investigation. 10 Tax abruptly at that time? 10 11 11 by the F.B.I., did they tell you that they were A All I know was that they were at the academy and Q And when you were briefed by the investigation -- 12 were possibly being detailed to the 15th District. 12 investigating the entire Watts team? 13 13 Q Do you have any idea why they were taken off Brass A Anything prior -- anything leading from the 14 Tax at that time? 14 investigation was -- so all of it, I mean, Watts and any of 15 A No. 15 his people who worked with him. That's always understood. 16 Q Were you aware that -- do you know who Jill Stevens 16 17 is? Q Were they giving you names of some of the people 17 that were underneath him that they suspected of wrongdoing? 18 A A sergeant, I believe. 18 A Well, we know Mohammed was arrested with him. 19 Q Were you aware that at the time that they were 19 Q Were they telling you in terms of during the 20 being taken out of Detail 543 that Jill Stevens asked for 20 investigation the names of other officers who, for instance, 21 documents and a statement relating to the nature of what 21 were identified by informants or arrestees of indicating 22 Danny and Shannon were doing in 543? 22 that other officers on his team were actively involved in 23 A I never spoke to Jill Stevens. 23 extortion and things of that nature? 24 Q Were you aware that Juan Rivera was contacted by 24 A I don't recall any specifics of that nature. Page 51 1 Danny Echeverria about the move to -- being taken off Brass 2 Tax and being sent to the academy? 3 MR. KING: Just object to the -- I'll withdraw it. Go 4 ahead. 5 THE WITNESS: I wasn't present in any conversation 6 between Danny and Chief Rivera. 7 BY MR. SMITH: 8 Q Were you at any meeting where -- with either Debra 9 Kirby or Juan Rivera or Beatrice Cuello relating to their 10 move, Danny and Shannon's being taken off Brass Tax and 11 being sent to the academy? 12 A No. 13 Q Did you learn that Patrick Smith was considered at 14 one point in time a rogue agent or an agent who was having 15 problems in terms of with the F.B.I. itself? 16 A Danny and Shannon told me that Patrick Smith was no 17 longer a member of the F.B.I. 18 Q When was that? 19 A I don't remember exactly when. 20 Q In terms of when you were briefed about the -- when 21 you first came to IAD you were briefed about the Watts 22 investigation, how long was it your belief that the Watts 23 investigation had been going on for? 24 A I don't recall but at least prior to 2008. Page 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q Do you recall any specifics of what they told you Watts was doing? A Just what he was arrested for. Q And -A I went to the federal complaint. Q Do you know what he was federally charged with? A Just as far as extortion and stealing money and so forth. Q Were you aware that the initial developments and surveillance and the stings where Watts was seen doing illegal things wasn't used in that investigation, that a subsequent sting was used? A I can't say. Q So as you sit here today do you remember any of the details about how -- what you were being told during the time you were chief of IAD of how Watts was operating in terms of the criminal activity he was doing? A I don't recall specifics of those discussions. Q Do you remember anything about the extent of how big his organization was that was working with him? A No, I don't recall. Q Has your opinion in terms of Danny and Shannon being good police officers changed in any way at this time? A No. 14 (Pages 50 - 53) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 16 of 191 PageID #:924 Page 54 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. SMITH: Nothing further. MR. KING: No questions. We'll reserve. MR. SMITH: We'll order it. MR. KING: I'll take a copy. DEPONENT FURTHER SAITH NOT. Page 56 1 DEPOSITION REVIEW CERTIFICATION OF WITNESS 2 ASSIGNMENT NO: 1975326 3 CASE NAME: Spaulding v. City Of Chicago DATE OF DEPOSITION: 12/5/2014 4 WITNESS' NAME: Skahill 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 Tina Skahill 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 22 23 24 25 Page 55 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 57 1 STATE OF ILLINOIS ) ) ss: COUNTY OF C O O K ) 2 3 I, Linda M. Benda, C.S.R., Notary Public, do hereby certify that I reported in shorthand the testimony held at the deposition of Tina Skahill on December 5, 2014, and that this transcript is a true and accurate transcription of my shorthand notes so taken, to the best of my ability, and contains all of the proceedings given at said deposition. 4 5 6 7 8 9 ASSIGNMENT NO: 1975326 CASE NAME: Spaulding v. City Of Chicago DATE OF DEPOSITION: 12/5/2014 WITNESS' NAME: Skahill In accordance with the Rules of Civil Procedure, I have read the entire transcript of my testimony or it has been read to me. I have listed my changes on the attached Errata Sheet, listing page and line numbers as well as the reason(s) for the change(s). I request that these changes be entered as part of the record of my testimony. 10 11 12 13 <%Signature%> Linda M. Benda No. 084-003550 DEPOSITION REVIEW CERTIFICATION OF WITNESS I have executed the Errata Sheet, as well as this Certificate, and request and authorize that both be appended to the transcript of my testimony and be incorporated therein. _______________ ________________________ Date Tina Skahill 14 15 16 17 18 19 20 21 22 23 Sworn to and subscribed before me, a Notary Public in and for the State and County, the referenced witness did personally appear and acknowledge that: They have read the transcript; They have listed all of their corrections in the appended Errata Sheet; They signed the foregoing Sworn Statement; and Their execution of this Statement is of their free act and deed. I have affixed my name and official seal this ______ day of_____________________, 20____. ___________________________________ Notary Public 24 25 ___________________________________ Commission Expiration Date 15 (Pages 54 - 57) Veritext Legal Solutions www.veritext.com 888-391-3376 Case: 1:12-cv-08777 Document #: 166-2 Filed: 02/02/16 Page 17 of 191 PageID #:925 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Page 58 ERRATA SHEET VERITEXT LEGAL SOLUTIONS MIDWEST ASSIGNMENT NO: 1975326 PAGE/LINE(S) / CHANGE /REASON ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ _______________ ________________________ 20 Date Tina Skahill 21 SUBSCRIBED AND SWORN TO BEFORE ME THIS ________ 22 DAY OF ________________________, 20______ . 23 ___________________________________ Notary Public 24 ___________________________________ 25 Commission Expiration Date 16 (Page 58) Veritext Legal Solutions www.veritext.com 888-391-3376