IN THE UNITED STATES DISTRICT OURT FOR THE NORTHERN DISTRIC II..LINOIS EASTERN DIVISION SHANNON SPALDING AND DANIEL ECHEVERRIA . Plaintiff, ya City of Chicago, et a1. 3 Judge Fienerman Defendants. Magistrate Judge Sheila Finnegan AFFIDAVIT OF JANET HANNA 1, Of?cer Janet Hanna, being ?rst duly sworn on oath, under penalties of perjury as provided by law, depose and state as follows: 1. I began working for the Chicago Police Department on May 31, 1994. 2. In March of 2012, Lieutenant Cesario Cesario?) informed the administrative assistants, myself and Of?cer Coleen Dougan (?Officer Dougan?) included, that two new of?cers were coming who were supposedly rats?, and to be very leery of them. 3. The following day, I met the two new of?cers: Shannon Spalding (?Shannon?) and Daniel Echeverria (?Danny?). 4. The same day, It Cesario walked over with Shannon and Danny. After Lt. Cesario walked away, I said to Shannon and Danny, ?So you two are the IAD rats?? 5. Shannon and Danny were assigned to the Fugitive Apprehension Unit 6. My responsibilities include giving out assignments within the FAU. SPALDING 000927 7. Shortly after their assignment. 1 ('esario ordered me to give Shannon and Danny only dead-end cases that would not lead to arrest or officer activity. 8. Lt. Cesario picked the cases I was to assign to Shannon and Danny. 9. Commander Salemme (?Cmdr. Salemme?) and Sergeant Barnes (?Sgt. Barnes?) were aware of these assignments because they were copied on the emails which noti?ed of?cers of, and documented the assignments. 10. Eventually, Lt. Cesario stopped picking the assignments for Shannon and Danny because he trusted me to follow his orders and not give them cases which would result in arrest. 11. Sometime a?er, I assigned Shannon a high-pro?le homicide case. 12. When Lt. Cesario saw the e-mail containing the assignment, he immediately entered my of?ce yelling about the fact I assigned Shannon the homicide case. Sgt. Barnes later pulled the assignment from Shannon. 13. On or around June 25, 2012, I was working overtime in the FAU in Homan Square, when I overheard Shannon say to Danny, ?God, what do I have to do to get back on days?? 14. Upon hearing this, I asked Shannon why she was complaining, because I was told by Cmdr. Salemme and Lt. Cesario that Danny had requested to work third watch due to family reasons. 15. Shannon responded to this by saying, ?What are you talking about? We did not request this.? 16. I informed Shannon and Danny that while they were still working days, Lt. Cesario came to me and gave me a ?le containing documents and ordered me to type SPALDING 000928 'bsm *Iefcmim 025s of ?17: dunnerxs?z ?102? $12 ,1 7, 3.63; ant/'1 U, the third waif-,2: rim to 52mm rem/ma, an: 42: m: fire swim. of staying on ?371. 3r gaing with fanny, and ?521,753 mom fr, 9. 32m warns; ?mr parka,- Damzy. {typed it. fir: ioz'rr, a off'mm? Avg/m, 17. A: that time, firm-w?; an! Emmy infamy/1 ma they nor/er rape-saw the 35 third 13. Sfm?y thaca?a, in km 2012, I was amide Lt. Ccsm'io?s of?ce, Wham I (Na-heard Cam's in a meeting ?daring Mi?s, Barnes, Mason, Stack, Na?ax, 323m, andtonatwm'kwith?aanatz?. 19. ka? goiitxrepmmin ardent: blazaffmm?ity, even when not a rice scene of 28. Howe-1a, Shannon and Dam were i. Left 05 of web police 22. we Palm an 0566: in the PAU, renamed to 19:2 533:: rim: of. She beg: ye?ing zfnar Leaning she received a a :25: when 333-6 was not pram: for any af?ne activity since she was eff work. 22. 5:335}- !cu?iy for a? to aims: how the other officers put a 22:25 E: ?337. 2? fair: the mam ?knew 331213 carried [her] for the a Eeh?x Batista W'an to Of?ce: and said, ?Shut the 9:6; 61? the CR 52-3256 will be the Bees: 0; year W. Ia. Eye's keep talking about it SPAR-.0913 900929 we?re going to get ?red or go to prison.? Officer. Batista by saying, ?Once we write a report, you have to stick to the facts. You can?r deviate from the report.? 24. Sgt. Mills was present for this conversation. 25. Around July of 2012, I was in a meeting with Lt. Cesario when he received a phone call. After he hung up the phone, he said to me, ?Commander O?Grady from Narcotics just informed me that Shannon Spalding is banned from the building and. prohibited from entei'ing Homan Square or she?ll be arrested.? 26. Detective, Kevin Cullhane came into my of?ce and. asked me for a list of of?cers who still needed access to the databases and ?Leads 2000?. I provided. him with the list and informed him that two of?cers, Shannon and Danny, had repeatedly requested access to the databases. Cullhane informed me that he was Speci?cally instructed to not give them access to these databases. 27. On November 1, 2012, Lt. Cesario walked into the Administrative of?ce and said, ?Shannon and Danny ?led a lawsuit and they?ll be on the news tonight. Make sure you watch it.? 28. The following day, everyone was talking about the lawsuit. At one point Of?cer Dougan said to me, ?Oh, we are going to get in trouble.? 29. One of my responsibilities included collecting Request for Overtime fonns. Initially, of?cers who wanted overtime hours could ?ll out a form and submit it to me requesting to work on the Violence Reduction Initiative 30. One day, Lt. Cesario told me that if 1 received a VRI form from Shannon or Danny, to toss it out and pretend like I had never received it. I followed his orders on SPALDING 000930 at least two occasions and pretended to never receive Shannon or Danny"; requests for overtime. 31. Months later, I had an argument with Lt (Eu-sand this: practice because I did not feel comfortable doing it. I informed l.t. Ce'mrio that was revising the form submission practice by having of?cers individually e-mail their overtime requests to me. This new practice created a record for submitted overtime requests, and showed the time each request was made. 32. Lt. Cesario came to me and requested a printout of cases Danny had been assigned, and informed me that we were reassigning those cases. 33. A couple months later, Cesario entered my office and began yelling at me and Officer Aisha Sultana, saying, ?Who told you to reassign Danny?s cases? He hasn?t been working on them at all!? I responded, ?You ordered us to take the cases away and reassign them.? 34. One day, Shannon informed me that while she and Danny were working VRI cases under Sgt. Mills, they were reprimanded by Sgt. Mills for working on one of Danny?s regularly-assigned cases at the same time. I informed her that this was odd because Sgt. Mills is aware that nearly all of?cers work their regularly-assigned cases at the same time they work and that Mills signs off on the paperwork submitted by the of?cers doing it. 35. After Shannon and Danny were moved back to the day shift, Lt. Cesar-i0 came into my office screaming, ?How the fuck did these two motherfuckers get back on days?! Who the fuck do they know? They?re messing with the wrong people.? SPALDING 000931 headquarters at 35?h Street and Michigan Avenue to a statement about a CR ?led with me as a witness. 37. When I reported to the IAD of?ce, I was met by Sgt. Muscalino and another of?cer, who escorted me to a room. They read the complaint to me and I learned that Of?cer Dougan ?led the CR Number, alleging that Shannon Spalding and I were in a hallway and Shannon was playing for me a recording from her phone and the voice Of?cer Dougan? heard was Mills. 38. After Sgt. Muscalino and the officer began the questioning process, I repeatedly denied that the alleged conversation took place. Sgt. Muscalino repeatedly asked me whether I was sure. I repeated that the complaint was untrue, that the alleged conversation never happened, and that at no time ever did Shannon play for me any recording from her phone. FURTHER AFFIANT SAYETH NOT.. Under penalties as provided by law pursuant to 735 ILCS 5/ 1-109, I certify that the statements set forth herein are true and correct. if? MW Date SPALDING 000932