IN THE CIRCUIT COURT OF COOK CO CRIMINAL DIVISION PEOPLE OF THE STATE OF ILLINOIS, V. Respondent, WILLIAM NEGRON and ROBERTO ALMODOVAR REYNALDO ANSWERS TO INTERROGATORIES Defendant Reynaldo Guevara, by and through his attorneys, James G. Sotos, Jeffrey N. Given, Elizabeth A. Ekl and Joseph M. Polick of The Sotos Law Firm, RC, and in response to Petitioner. x: No. 94 CR 238%?- I The Honorable JudQeiJgIHGS/Linn Petitioners? Interrogatories to Reynaldo Guevara, states as follows: 1. ANSWER: 2. ANSWER: 3. ANSWER: 4. ANSWER: INTERROGATORIES Are you Reynaldo Guevara? Yes. Are you willing to testify about your activities as a Chicago Police Of?cer? Please refer to my answers below regarding speci?c questions about my activities as a Chicago Police Officer. On May 10, 1991, did you come in contact with David Velasquez? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On May 10, 1991, did you grab Mr. Velasquez? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 5. vehicle. ANSWER: 6. ANSWER: 7. On that same date, did you place Mr. Velasquez in the back seat of your police On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did Mr. Velasquez enter your police car unwillingly? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did you have any justi?cation for detaining Mr. Velasquez in the back seat of your police vehicle? ANSWER: 8. headquarters? ANSWER: . 9. ANSWER: 10. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did you drive Mr. Velasquez to the parking lot of Area 5 police On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did you question Mr. Velasquez about a murder? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did Mr. Velasquez initially tell you that he did not know anything about a murder? 'Oii'the advice o'f'c'd?tisel?, ?assert the" "rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 11. On that same date, after Mr. Velasquez told you he knew nothing about the murder, did you drive him to a location near the corner of North and Keeler in the City of Chicago? ANSWER: 12. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did you tell Mr. Velasquez that the location near North and Keller was where Junito was murdered? ANSWER: 13. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did Mr. Velasquez again tell you that he knew nothing about the murder after you told him about Junito being killed? ANSWER: 14. ANSWER: 15. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On that same date, did yo then drive Mr. Velasquez to Kedzie and Cortez? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you drive Mr. Velasquez to Kedzie and Cortez knowing it was an area controlled by the Latin Kings? ANSWER: 16. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you drive Mr? 'V?el'as'quezto the Latin?Kingrco'ntrolle?d area knowing Mr: Velasquez was in a rival gang? ANSWER: 17. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell the assembled Latin Kings at Kedzie and Cortez that Mr. Velasquez was the person who killed Junito, a high ranking Latin King? ANSWER: 18. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you observe gang members threatening Mr. Velasquez?s life after you made that announcement? ANSWER: 19. On the advice of counsel, I assert the rights guaranteed to rhe by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten to leave Mr. Velasquez at Kedzie and Cortez if he did not cooperate with your investigation? ANSWER: 20. ANSWER: 21. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you bring Mr. Velasquez back to Area 5 from Kedzie and Cortez? On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth? Amendment of the United States Constitution, and therefore decline to answer at this time. Did you strike Mr. Velasquez in order to coerce him to provide a false statement about who killed unito? ANSWER: On the advice 'of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 22. Did you use physical force against Mr. Velasquez to coerce him to provide a false statement about who killed unito?? ANSWER: 23. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you hang Mr. Velasquez by his handcuffs to coerce him to provide a false statement about who killed Junito? ANSWER: 24. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you provide facts about the murder of unito to Mr. Velasquez before Mr. Velasquez mentioned any of those facts to you? ANSWER: 25. prosecutor? ANSWER: 26. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you coach Mr. Velasquez about how to provide a false statement to the On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you engage in the above?mentioned acts of misconduct toward Mr. Velasquez, including physically abusing him and feeding him false information, with your partner Ernest Halverson? ANSWER: 27. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you never physically abuse Mr. Velasquez? ANSWER: 28. ANSWER: 29. ANSWER: 30. or 1994?? ANSWER: 31. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsify your police reports describing your contact with Mr. Velasquez? On the advice of Counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Were you assigned to investigate the Merkes/Rodriguez murders? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. As part of that investigation, did you Speak with Kennelly Saez on September 1St On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did Kennelly Saez tell you- that all he could remember of the rear passenger was that he had a skinny face? ANSWER: 32. correct? ANSWER: 33. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Kennelly Saez did not tell you that the rear passenger had a rectangle face, On the adVice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely t?snfy'mar you did "not ?Show any photographs to Kenneliy Saez before he viewed line-up containing Mr. Almodovar and Mr. Negron? ANSWER: 34. injuries? ANSWER: 35. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time.? Did you visit Jackie Grande while she was at the hospital recovering from her On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you show Jackie Grande photographs of William Negron and Roberto Almodovar at the hospital? ANSWER: 36. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell-Jackie Grande that William Negron and Roberto Almodovar were the people who committed this crime while she was at the hOSpital? ANSWER: 37. photo arrays? ANSWER: 38. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you did not tell Jackie Grande whom to pick out of the On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you drive Jackie Grande to Kennelly Saez?s house before any line-ups in this case took place? ANSWER or; the advice'o'f ?'ouris'?m assert the "rights?guai'ante?ed?to? me by Amendment of the United States Constitution, and therefore decline to answer at this time. 39. Did you and Jackie Grande speak to Kennelly Saez outside in front of his building? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 40. At that time, did you show Saez photographs of Negron and Almodovar? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 41. Did you tell Saez that Negron and Almodovar were the people who committed the Rodriguez/Merkes murders? ANSWER: On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 42. Did Jackie Grande tell Saez in your presence in front of Saez?s building that Negron and Almodovar were the ones who committed these murders? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 43. Did you drive Saez and Grande to Area 5 from Saez?s house? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the i?h Amendment of the United States Constitution, and therefore decline to answer at this time. 44. Did you tell Saez not to mention the fact that he had shown you photographs prior to the line-up? ANSWER: the of counsel; assert the to me by the ?Fifth? Amendment of the United States Constitution, and therefore decline to answer at this time. 45. Did you falsify your police reports in this case to omit mention that you told Grande who supposedly committed the murders before she identi?ed anyone? ANSWER: 46. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsify your police reports in this case to omit mention that you told Saez who supposedly committed the murders before he identi?ed anyone? ANSWER: 47. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you did not tell Grande who supposedly committed the murders before she identi?ed anyone? ANSWER: 48. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you did not tell Saez who supposedly committed the murders before he identi?ed anyone? ANSWER: 49. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you did not show any photographs to Saez before he made an identi?cation? ANSWER: 50'; On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this'time. Did you" intentionally frame William N'egro'n?and Roberto A'lm'od?ovartfor murder? ANSWER: 51-. ANSWER: 52. ANSWER: 53. ANSWER: 54. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you question Gloria Bordoy on December 13, 1995? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you interrogate Ms. Bordoy about a homicide investigation? On the advice of counsel, I-assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Prior to interrogating Ms. Bordoy, did you place her in handcuffs? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Prior to interrogating Ms. Bordoy, did you place her in handcuffs and transport her to the police station? ANSWER: 55. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Prior to interrogating Ms. Bordoy, did you place her in handcuffs and transport her to the police station despite having no legal basis for detaining her? ANSWER: 56. ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did Ms. Bordoy tell you that she knew nothing about that crime? O?thdadvice 6f counselil'assei?t to me by the Fifth? Amendment of the. United States Constitution, and therefore decline to answer at this time. 10 57. Did you call Ms. Bordoy a liar? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 58. Did you tell Ms. Bordoy that if she did not agree to implicate herself in the crime, you would have DCFS take her children away from her? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 59. Did you call Ms. Bordoy a bitch during your interrogation of her? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 60. Did you accuse Ms. Bordoy of committing the murder during your interrogation of her? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 61. Did you wear a gold ring with a carved face of an Indian in December 1995? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 62. Did you lie to Ms. Bordoy that Nelson Rivera had signed a confession when in fact you knew he had not? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. ll 63. shooting? ANSWER: 64. ANSWER: 65. ANSWER: 66. ANSWER: 67. Did Ms. Bordoy repeatedly tell you that she had no involvement whatsoever in the On the advice of counsel, I asselt the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did Ms. Bordoy consistently tell you what she was doing the night of the murder? On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Ms. Bordoy during her interrogation that you felt like hitting her? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten to hit Ms. Bordoy during her interrogation? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten to hit Ms. Bordoy and threaten to have her children taken away if an effort to obtain a false inculpatory statement from her? ANSWER: 68. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten Ms. Bordoy that she would have her child in prison if she did not 000perate with you? ANSWER: 69. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you investigate the murder of Salvador Ruvulcaba? l2 ANSWER: 70. May 14, 1993? ANSWER: 71. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. As apart of that investigation, did you go to the scene of the Ruvulcaba murder on On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you use physical force against Robert Bouto while he was being questioned at Area 5 on May 14, 1993? ANSWER: 72. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you detain Carl Richmond at Area 5 detective headquarters folloWing the Ruvulcaba murder against his will? ANSWER: 73. 1993? ANSWER: 74. on the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you have no justi?cation for detaining Carl Richmond at Area 5 on May 14, On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten Mr. Richmond that he would be falsely charged with a crime if he left Area 5 before viewing a line?up on May 14, 1993? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitutiomand therefore decline to answer at this time. 13 75. Did you have Mr. Richmond and other witnesses to the Ruvulcaba murder, including Rey Lozarda and Frank Escobar, sit in the same room while Robert Bouto was being placed in line?ups in a different room at Area 5? ANSWER: 76. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Mr. Richmond, Rey Lozarda, and Frank Escobar to pick out Bouto as the perpetrator of the Ruvulcaba murder? ANSWER: 77. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Mr. Richmond, Rey Lozarda, and Frank Escobar which position Bouto was in in (sic) the line-up? ANSWER: 78. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you have the people who viewed Bouto?s line-up, including Mr. Richmond, Rey Lozarda, and Frank Escobar, con?rm to each other that they had picked Bouto as the perpetrator of the Ruvulcaba murder? ANSWER: 79. ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Mr. Richmond that you had a lot of pull with beat of?cers? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. - l4 80. Did you tell Mr. Richmond that you could make his life very uncomfortable if he did not cooperate with you? ANSWER: 81. ANSWER: 82. On the advice of ecunsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Francisco Vicente to falsely implicate Robert Bouto in a murder? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you feed facts about the Ruvulcaba murder to Francisco Vicento so that he could in turn falsely implicate Robert Bouto? ANSWER: 83. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you investigate a murder of Orlando Garola. that occurred near Spaulding and Division in Chicago on or about July 29, 1988? ANSWER: 84. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Wilfredo Rosario to falsely claim that he witnessed the murder of Orlando Garola on July 29, 1988 near Spaulding and Division? ANSWER: 8'5. ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Wilfredo Rosario to falsely claim that he heard 5-7 shots ?red? On the advice ofcounsel, I assert the rights guaranteed ~to meby the Fifth? Amendment of the United States Constitution, and therefore decline to answer at this time. 15 86. unlawfully? ANSWER: 87. Did you question Mr. Rosario while he was under arrest for possessing a handgun On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. When you questioned Mr. Rosario about the Garola murder, were you aware that . he was under a threat of death from the Latin King street gang for cooperating with police in another investigation? ANSWER: 88. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten to put Mr. Rosario in Cook County jail unless he cooperated with your investigation into the Garola murder? ANSWER: 89. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Mr. Rosario to falsely claim that Xavier Arcos was involved in the Garola murder? ANSWER: 90. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Censtitution, and therefore decline to answer at this time. Did you tell Mr. Rosario to fabricate an account implicating Xavier Arcos in the Garola murder? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 16 91. Did you tell Mr. Rosario to fabricate an account making Mr. Arcos appear to be the main perpetrator in the Garola murder? ANSWER: On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 92. Did you testify falsely when you denied coercing Mr. Rosario to implicate Mr. Arcos? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 93. Did you falsify police reports in connection with the Garola murder investigation to hide your misconduct? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 94. Did you investigate the murder of Marlon Wade that occurred on September 30, 1989, near the corner of Sheridan and Broadway in Chicago? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 95. As part of that investigation, did you question a teenager named Virgilio Muniz? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 96. Did Mr. Muniz tell you repeatedly that he did not know who committed the murder? 17 ANSWER: 97. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you threaten Mr. Muniz that if he did not cooperate in your investigation you would falsely charge him with the Wade murder? ANSWER: 98. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you Mr. Muniz a photograph of Manuel Rivera and tell Mr. Muniz to falsely identify Manuel Rivera as the perpetrator of the Wade murder? ANSWER: 99. ANSWER: 100. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you pressure Mr. Muniz to falsely identify Manuel Rivera as the perpetrator? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you did not coerce Mr. Muniz to falsely implicate Rivera in the Wade murder? ANSWER: 101. On the advice of counsel, I assert the rights guaranteed to me by the Fifth. Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsify your police reports regarding the Wade murder investigation to hide your misconduct in getting Mr. Muniz to falsely implicate Rivera? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 18 102. 1989? ANSWER: 103. Did you investigate the murder of Alvin Casteneda that occurred on April 23, On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. As part of the Casteneda murder investigation, did you question a witness named Virgilio Calderon Muniz? ANSWER: 104. Area 5 ANSWER: 105. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you take Virgilio Calderon Muniz from his mother?s home and bring him to On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you have Virgilio Calderon Muniz View a line?up as apart of the Casteneda murder investigation? ANSWER: 106. Victor Vera? ANSWER: 107. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at . this time. Before he viewed the line?up, did you show Virgilio Calderon Muniz photos of On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to ansWer at this time. Before he 'viewed the line-up, did you tell Virgilio Calderon Muniz that you wanted Victor Vera off the street? 19 ANSWER: 108. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Before he viewed the line-up, did you tell Virgilio Calderon Muniz to falsely identify Victor Vera as the perpetrator of the murder? ANSWER: 109. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Virgilio Calderon Muniz that if he did not falsely identify Victor Vera, you would give Virgilio Calderon Muniz trouble every time you saw him? ANSWER: 110. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. When you spoke to Virgilio Calderon Muniz, did you know he was in a rival gang from Victor Vera? ANSWER: 111. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsely testify that you did not coerce Virgilio Calderon Muniz to falsely implicate Vera in the Casteneda murder? ANSWER: 112. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsify your police reports regarding the Casteneda- murder investigation to hide your misconduct in getting Mr. Muniz to falsely implicate Vera? ANSWER: On the advtee of counsel; lessen the rights guaranteed?to me by the Fifth? Amendment of the United States Constitution, and therefore decline to answer at this time. 20 113. 1993? ANSWER: 114. June 1993? ANSWER: 115. Did you investigate the murder of Rodrigo Vargas that occurred in February On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. As part of that investigation, did you question a man named Francisco Vicente in On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you approach Vicente and tell him facts about the Vargas murder before Vicente told any of those facts to you? ANSWER: 116. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you Vicente photographs of the crime scene before ViCente told you he knew anything about the Vargas murder? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 21 117. Did you tell Vicente that the perpetrators of the Vargas murder were Armando Serrano, Jorge Pacheco, and Jose Montanez before Vincente told you he knew anything about the Vargas murder? ANSWER: 118. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Vicente that you wanted him to falsely claim that he witnessed the Vargas murder and that Montanez, Serrano, and Pacheco were perpetrators? ANSWER: 119. ANSWER: 120. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did Vicente refuse to falsely claim that he was present for the Vargas murder? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you then try to get Vincente to falsely claim that Montanez, Serrano, and Pacheco gave him the murder weapon and told him about the crime shortly after it occurred? ANSWER: 121. ANSWER: 122. On the advice of counsel, I assert the rights' guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. DidVicente again refuse to adOpt this false story? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. - Did you then coach Vicente to tell "'a'fabi?icated story and Pacheco came to him after the Vargas murder. and admitted their involvement in the crime? 22 ANSWER: 123. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you strike Vicente in order to coerce him to falsely implicate Montanez, Serrano, and Pacheco? ANSWER: 124'. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you strike Vicente in the back of his head in order to coerce him to falsely implicate Montanez, Serrano, and Pacheco? ANSWER: 125. rights guaranteed to me by the Fifth :onstitution, and therefore decline to answer at On the advice of counsel, I ass, Amendment of the United Stat this time. Did you use physical force agai- ?Vicente in to coerce [sic] him to falsely implicate Montanez, Serrano, and Pacheco? ANSWER: 126. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did your partner, Halvorsen, tell Vicente in your presence that the pending charges against him would be dismissed if he falsely implicated Montanez, Serrano, and Pacheco. ANSWER: 127. Montanez, Serrano, and Pacheco proceeded? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States (institution, and therefore decline to answer at this time. Did you give Vicente money he asked for it while the case against ?23 ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 128. Did you allow Vicente to have private visits with his ex-wife while he was incarcerated in exchange for his cooperation on the Vargas murder investigation? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 129. As a further part of the Vargas murder investigation, did you question the victim?s widow, Wilda Vargas? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 130. Did you attempt to have Wilda identify a car supposedly driven by the perpetrators of the Vargas murder? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 131. Did you drive Wilda around the near west side of Chicago to see if she could identify that car? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 132. Did you bring Wilda to a location where Jose Montanez?s car was parked? ANSWER: On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 24 133. Did you falsely tell Wilda that the bullet holes then-existing in Montanez?s car Were forensically matched to the shots that were ?red in the course of the Vargas murder? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 134. After being told that the bullet holes in Montanez?s car matched evidence from the crime scene, did Wilda then say that Montanez?s car looked like the one that she had seen at a gas station the night before the Vargas murder? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 135. Also in the Vargas murder investigation, did you use force against Timothy Rankins to get him to falsely implicate Montanez, Serrano, and Pacheco? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 136. Did you use force against Rankins knowing that he knew nothing about the Vargas murder? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 137. Did you feed Rankins facts about the Vargas murder before Rankins told you any of those facts? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 25 138. Did you falsely testify that you did not commit any misconduct in getting Vicente and Wilda Vargas to falsely implicate Montanez, Serrano, and Pacheco in the Vargas murder? ANSWER: 139. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you falsify your police reports regarding the Vargas murder investigation to hide your misconduct in getting Vicente, Rankins, and Wilda Vargas to falsely implicate Montanez, Serrano, and Pacheco? ANSWER: 140. ANSWER: 141. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at - this time. Did you investigate the Noel Andujar murder in May 1995?? On the advice of counsel, I assert the rights gUaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. As part of your investigation of the Andujarmurder, did you question a witness named Jose Melendez? ANSWER: 142. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you tell Melendez to falsely implicate Thomas Sierra as the perpetrator of the Anduj ar murder? ANSWER: 143. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did ?Y6?'i?'x7?'s?t?igat'? ?the? murder of R1 eard?e'Fernan'dez on Septembe??e?; 26 ANSWER: 144. ANSWER: 145. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. During that investigation, did you question a man named Sam Perez? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. On September 11, 1989, did you tell Sam Perez that you did not care which Cobra gang member killed Fernandez, but that you preferred that certain Cobras would be identi?ed? ANSWER: 146. On the advice of counsel, I assert the rights guaranteed to me by the'Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you show Sam Perez photos of the Cobras that you wanted him to falsely implicate in the Fernandez murder? ANSWER: 147. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Did you show Sam Perez a photo of Juan Johnson and tell him that you wanted him to falsely implicate Johnson in the Fernandez murder? ANSWER: 148. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and ?therefore decline to answer at this time. Did you know Perez and Johnson were enemies when you showed Perez ohnson?s photo and told him that you wanted Perez to identify Johnson as the perpetrator of the Fernandez murder? I ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 27 149. Did you investigate the shooting death of Oscar Arman that occurred on July 1, 1997. ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 150. As part of that investigation, did you detain Robert Ruiz for questioning without probable cause to do so? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Arnendment of the United States Constitution, and therefore decline to answer at this time. 151. As part of the Arman murder investigation, did you detain Robert Ruiz for questioning without probable cause to do so on multiple occasions? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 152. As part of the Arman murder investigation, did you detain Robert Ruiz for questioning without probable cause to do so in multiple occasions for the purpose of intimidating Ruiz into falsely implicating Conception and Freddy Santiago? ANSWER: On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 153. Robert Ruiz never told you that he cOuld identify the perpetrators of the Arman homicide, is that correct? ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth. Amendment of the United States Constitution, and therefore decline to answer at 28 154. You held Ruiz at the police station numerous times between July 1 and July 6 in order to pressure him to falsely identify the Santiago brothers in a murder, correct? ANSWER: 155. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. You told Robert Ruiz to falsely implicate Conception and Freddy Santiago in the Arman homicide, correct? ANSWER: 156. On the advice of counsel, 1 assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. You engineered having Robert Ruiz being arrested for not appearing in court, even though he had no obligation to appear in court and had no pending charges, correct? ANSWER: 157. ANSWER: 158. On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. You had Robert Ruiz placed on home monitoring so that [sic] Objection, this interrogatory as drafted cannot be responded to. In your career as a detective, including in 1994, did you have practice of manipulating witnesses to falsely implicate suSpects? ANSWER: 159. ANSWER: On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution,- and therefore decline to answer at this time. Did you conform to that practice in investigating the Merkes/Rodriguez murders? On the advice of counsel, I assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at irne 29 160. Why are you asserting the Fifth Amendment rather than providing truthful answers to these questions? ANSWER: On the advice of counsel, I object that the answer to this question seeks information protected by the attorney-client privilege, and I also assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. 161. Do you believe that if you testify truthfully in this proceeding you will be charged with perjury for previously testifying that you did not commit misconduct in the Merkes/Rodriguez murder investigation. ANSWER: On the advice of counsel, I object that the answer to this question seeks information protected by the attorney-client privilege, and I also assert the rights guaranteed to me by the Fifth Amendment of the United States Constitution, and therefore decline to answer at this time. Dated: November 23, 2016 I, Reynaldo Guevara, under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, 735 ILCS 5/ 1?109, do hereby certify that the statements set fOrth in Reynaldo Guevara?s Answers to Interrogatories are true and correct. eynaldo Guevara Dated: j?l/jvt/ ZS, 20/? 30 PROOF OF SERVICE Under penalties as provided by law, pursuant to 28 U.S.C.A. 1746, Tonet Ballard, a non-attorney, states that a true and correct copy of Reynaldo Guevara?s Answers to William Negron and Roberto Almodovar Interrogatories was sent on November 23, 2016 via Federal EXpress to Assistant State?s Attorney Celeste Stack, c/o Cook County State?s Attorney?s Of?ce, Leighton Criminal Courts Building, 2650 South California, Suite 12 40, Chicago Illinois WW -- TonerBallard 3]