CHARGES Police Officer Janet Mondragon, Star Number 4364, is charged with violating the following rules contained in Article of the Rules and Regulations of the Chicago Police Department, which were in full force and effect on the date of the alleged Violations: Rule 2: Rule 3: Rule 6: Rule 11: Rule 14: Any action or conduct which impedes the Department?s efforts to achieve its policy and goals or brings discredit upon the Department. Any failure to promote the Department?s efforts to implement its policy or accomplish its goals. Disobedience of an order or directive, whether written or oral. Incompetency or inefficiency in the performance of duty. Making a false report, written or oral. SPECIFICATIONS 1. Officer Mondragon, Star Number 4364, is charged with violating Rule 2, ?Any action or conduct which impedes the Department?s efforts to achieve its policy and goals or brings discredit upon the Department,? in one or more of the following instances: Count I: Count II: On or about October 20, 2014, Officer Mondragon made one or more false, misleading, inaccurate, and/ or inconsistent statements to a member(s) of the Department who responded to and/ or investigated the events surrounding the fatal shooting of Laquan McDonald on or about October 20, 2014, at or about 21:57 hours, at or around the 4100 block of S. Pulaski Road, Chicago, Illinois. Said false, misleading, inaccurate, and/ or inconsistent statements included that Officer Mondragon looked down while putting her gearshift in park, and only heard but did not see the shot(s) that were fired at McDonald, or words to that effect; and/ or Officer Mondragon did not see any shot(s) being fired by Officer Van Dyke, or words to that effect; and/ or Officer Mondragon did not see who was firing a gun, or words to that effect. On or about October 21, 2014, Officer Mondragon made one or more false, misleading, inaccurate, and/ or inconsistent statements to the Independent Police Review Authority (IPRA) which responded to and/ or investigated the events surrounding the fatal shooting of Laquan McDonald on or about October 20, 2014, at or about 21:57 hours, at or around the 4100 block of S. Pulaski Road, Chicago, Illinois. Count Said false, misleading, inaccurate, and/ or inconsistent statements included that Officer Mondragon did not see who was ?ring a gun, or words to that effect; and/ or Officer Mondragon provided a true and accurate account of the shooting to IPRA, or words to that effect. On or about October 20, 2014, Officer Mondragon failed to visually inspect the in?car video system equipment on her assigned vehicle for damage; and/ or failed to obtain the audio recorder from her in?car video system and/ or ensure it was securely attached to her person; and/ or failed to follow the start?up procedures for the in?car video system as trained and/ or ensure the system was working properly; and/ or failed to audibly record events with her in?car video system; and/ or failed to notify her supervisor about the audio component?s status. Officer Mondragon, Star Number 4364, is charged with violating Rule 3, ?Any failure to promote the Department?s efforts to implement its policy or accomplish its goals,? in one or more of the following instances: Count I: Count II: On or about October 20, 2014, Officer Mondragon made one or more false, misleading, inaccurate, and/ or inconsistent statements to a member(s) of the Department who responded to and/ or investigated the events surrounding the fatal shooting of Laquan McDonald on or about October 20, 2014, at or about 21:57 hours, at or around the 4100 block of S. Pulaski Road, Chicago, Illinois. Said false, misleading, inaccurate, and/ or inconsistent statements included that Officer Mondragon looked down while putting her gearshift in park, and only heard but did not see the shot(s) that were fired at McDonald, or words to that effect; and/ or Officer Mondragon did not see any shot(s) being fired by Officer Van Dyke, or words to that effect; and/ or Officer Mondragon did not see who was firing a gun, or words to that effect. On or about October 21, 2014, Officer Mondragon made one or more false, misleading, inaccurate, and/ or inconsistent statements to the Independent Police Review Authority (IPRA) which responded to and/ or investigated the events surrounding the fatal shooting of Laquan McDonald on or about October 20, 2014, at or about 21:57 hours, at or around the 4100 block of S. Pulaski Road, Chicago, Illinois. Said false, misleading, inaccurate, and/ or inconsistent statements included that Officer Mondragon did not see who was firing a gun, or Count HI: words to that effect; and/ or Of?cer Mondragon provided a true and accurate account of the shooting to IPRA, or words to that effect. On or about October 20, 2014, Of?cer Mondragon failed to visually inspect the in?car video system equipment on her assigned vehicle for damage; and/ or failed to obtain the audio recorder from her in?car video system and/ or ensure it was securely attached to her person; and/ or failed to follow the start?up procedures for the in?car video system as trained and/ or ensure the system was working properly; and/ or failed to audiny record events with her in?car video system; and/ or failed to notify her supervisor about the audio component?s status. 3. Of?cer Mondragon, Star Number 4364, is charged with violating Rule 6, ?Disobedience of an order or directive, whether written or oral,? in the following instance: Count I: On or about OctOber 20, 2014, Of?cer Mondragon failed to visually inspect the in?car video system equipment on her assigned vehicle for damage; and/ or failed to obtain the audio recorder from her in?car video system and/ or ensure it was securely attached to her person; and/ or failed to follow the start?up procedures for the in?car video system as trained and/ or ensure the system was working properly; and/ or failed to audibly record events with her in?car video system; and/ or failed to notify her supervisor about the audio component?s status, in violation of Special Order 803?05 (effective February 23, 2012 through February 24, 2016). 4. Of?cer Mondragon, Star Number 4364, is charged with violating Rule 11, ?lncompetency or inef?ciency in the performance of duty,? in the following instance: Count I: On or about October 20, 2014, Of?cer Mondragon failed to visually inspect the in?car video system equipment on her assigned vehicle for damage; and/ or failed to obtain the audio recorder from her in?car video system and/ or ensure it was securely attached to her person; and/ or failed to follow the start?up procedures for the in?car video system as trained and/ or ensure the system was working properly; and/ or failed to audibly record events with her in?car video system; and/ or failed to notify her supervisor about the audio component?s status. 5. Of?cer Mondragon, Star Number 4364, is charged with violating Rule 14, ?Making a false report, written or oral,? in one or more of the following instances: Count I: Count II: On or about October 20, 2014, Of?cer Mondragon made one or more false statements to a member(s) of the Department who responded to and/ or investigated the events surrounding the fatal shooting of Laquan McDonald on or about October 20, 2014, at or about 21:57 hours, at or around the 4100 block of S. Pulaski Road, Chicago, Illinois. Said false statements included that Of?cer Mondragon was looking down while putting her gearshift in park during the shooting, or words to that effect; and/ or Of?cer Mondragon did not see shots being ?red by Of?cer Van Dyke, or words to that effect; and/ or Of?cer Mondragon did not see who was firing a gun, or words to that effect; and/ or Of?cer Mondragon did not see McDonald fall to the ground, or words to that effect, thereby making a false statement, written or oral. On or about October 21, 2014, Of?cer Mondragon made one or more false statements to the Independent Police Review Authority which responded to and/ or investigated the events surrounding the fatal shooting of Laquan McDonald on or about October 20, 2014, at or about 21:57 hours, at or around the 4100 block of S. Pulaski Road, Chicago, Illinois. Said false statements included that Of?cer Mondragon did not see who was ?ring a gun, or words to that effect; and/ or Of?cer Mondragon provided a true and accurate account of the shooting, or words to that effect, thereby making a false statement, written or oral. Based on the foregoing charges and speci?cations, the Superintendent recommends that Police Of?cer Janet Mondragon, Star Number 4364, be discharged from the Chicago Police Department. EDDIE Superintendent of Police AS TO 2995 r' f, F. ELICIA V. MANNO GREEN BERG TRAURIG LLP Special Assistant Corporation Counsel FILED Mazam AUGBOZBIG CHICAGO BOARD