U.S. Department of Justice
Civil Rights Division

CEL:EG:LG:pjc
DJ 207-23-13

Special Litigation Section - PHB
950 Pennsylvania Ave, NW
Washington DC 20530

November 14, 2016

VIA ELECTRONIC MAIL
Heather Jackson
Allan T. Slagel
Taft Stettinius & Hollister LLP
111 E. Wacker Drive, Suite 2900
Chicago, IL 606601-3713
Brent Gurney
WilmerHale
1875 Pennsylvania Avenue, NW
Washington, D.C. 20006
Re:

Chicago Police Department Investigation pursuant to 42 U.S.C. § 14141 – Seventh
Document Request

Dear Ms. Jackson and Messrs. Slagel and Gurney:
Attached is the seventh document request related to the investigation of the Chicago Police
Department by the Special Litigation Section of the Civil Rights Division of the United States
Department of Justice and the United States Attorney’s Office of the Northern District of Illinois.
Please do not hesitate to contact us if you have any questions or concerns.
Very truly yours,
s/ Lynda Garcia
Lynda Garcia
Trial Attorney
Encl.

 UNITED STATES DEPARTMENT OF JUSTICE
SEVENTH REQUEST FOR DOCUMENTS AND INFORMATION
November 14, 2016
DEFINITIONS
1.

“CPD” means the City of Chicago Police Department and any of its departments,
divisions, sections, employees, agents, attorneys, and contractors.
INSTRUCTIONS

1.

Please provide the responsive information by November 21, 2016.

2.

Please provide supplementary responses if you obtain additional or different information
or documents.

3.

All information is requested in electronic format. Upon receipt of this request,
please schedule a conference call between the parties’ Information Technology
professionals to determine the appropriate format for production.

4.

If any request to identify documents calls for the production of privileged or workproduct materials and such privilege or work product is asserted, please provide the
following information in a privilege log:
a. the reason for withholding the identification of the document;
b. a statement of the basis for the claim of privilege, work product, or other grounds for
nondisclosure;
c. a brief description of the document, including the subject matter; date; number of
pages and attachments; the names of its authors and their employment and titles; the
names of each recipient, including persons who were shown the document or had
access to or custody of the document, together with an identification of each such
person; and
d. the custodian.

5.

If the answer to a request is “none” or “unknown,” the words “none” or “unknown”
should be written and supplied as the reply to each such request. If the requested
information has never existed, so state.

6.

If any responsive document has been lost, discarded, or destroyed, identify each such
document and provide the date or approximate date it was lost, discarded, or destroyed;
the circumstances and manner in which it was lost, discarded, or destroyed; the reason(s)
for disposing of the document if discarded or destroyed; the identity of all persons
authorizing or having knowledge of the circumstances surrounding the disposal of the
document; the identity of the person(s) who lost, discarded, or destroyed the document;

 and the identity of all persons having knowledge of the contents of the document that was
lost, discarded, or destroyed.
REQUESTS
114.

Data for all arrests made by CPD members from July 1, 2014 to December 31, 2015.
Please include the data in CLEAR tables titled “arrest,” 1 “arrest_charges,” 2 and
“offender.” 3

115.

Data for all stops, including but not limited to pedestrian and vehicle stops, made by CPD
members from July 1, 2014 to December 31, 2015. Please include the data in CLEAR
tables titled “contact_cards” 4 and “contact_traffic_stops.” 5

1

The CLEAR description of the “arrest” table indicates that this table includes information of the “[m]ain record of
arrest - each Arrest record represents the arrest of one individual.”
2
The CLEAR description of the “arrest_charges” table indicates that this table includes information of the “[a]rrest
charges - there are multiple charges per arrest.”
3
The CLEAR description of the “offender” table indicates that this table includes “personally identifying
information for each arrestee including physical description, name, birthdate, DL#, etc.”
4
The CLEAR description of the “contact_cards” table indicates that it is the “[m]ain record for a contact card or
traffic safety stop.”
5
The CLEAR description of the “contact_traffic_stops” table indicates that it “[s]tores additional fields relating to
contact cards of source Traffic Stop.”