Transcript of the Testimony of EDDIE T. JOHNSON Date: August 21, 2017 Case: KING VS. EVANS TOOMEY REPORTING 312-853-0648 toomeyrep@sbcglobal.net www.toomeyreporting.com EDDIE T. JOHNSON August 21, 2017 Page 1 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION RITA KING, Plaintiff, vs. GLENN EVANS, et al., Defendants. ) ) ) ) ) ) ) ) ) No. 13 C 1937 This is the VIDEOTAPED deposition of EDDIE T. JOHNSON, called by the Plaintiff for examination, taken pursuant to the Federal Rules of Civil Procedure for the United States District Courts pertaining to the taking of depositions, taken before PEGGY A. ANDERSON, a Certified Shorthand Reporter of the State of Illinois, at 3510 South Michigan Avenue, Chicago, Illinois, on August 21st, 2017 at 1:30 p.m. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 2 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 P P E A R A N C E S: THE LAW OFFICES OF: THOMAS G. MORRISSEY BY: MR. PATRICK MORRISSEY MR. THOMAS G. MORRISSEY 10150 South Western Avenue Chicago, Illinois 60643 (773) 233-7900 patrickmorrissey1920@gmail.com On behalf of the Plaintiff; THE LAW OFFICES OF: CITY OF CHICAGO FEDERAL CIVIL RIGHTS LITIGATION DIVISION BY: MS. TIFFANY Y. HARRIS 30 North LaSalle Street Suite 900 Chicago, Illinois 60602 (312) 744-7684 tiffany.harris@cityofchicago.org On behalf of the individual Defendants: Glenn Evans, D.T. Clifford, R.A. Sutton, K.L. Rodgers, Wilfredo Lapitan, and Lloyd Gray; THE LAW OFFICES OF: HICKEY, O'CONNOR & BATTLE, LLP BY: MR. KENNETH BATTLE MR. WILLIAM BAZAREK 20 North Clark Street Suite 1600 Chicago, Illinois 60602 (312) 422-9400 kbattle@hoblawfirm.com wbazarek@hoblawfirm.com On behalf of the Defendant, Glenn Evans; TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 3 1 2 A P P E A R A N C E S: 4 THE LAW OFFICES OF: CITY OF CHICAGO FEDERAL CIVIL RIGHTS LITIGATION DIVISION 5 BY: 3 6 7 8 MS. STEFFANIE N. GARRETT 30 North LaSalle Street Suite 900 Chicago, Illinois 60602 (312) 744-6959 steffanie.garrett@cityofchicago.org On behalf of the Defendant, City of Chicago; 9 11 THE LAW OFFICES OF: CHICAGO POLICE DEPARTMENT OFFICE OF THE SUPERINTENDENT 12 BY: 10 13 14 15 16 17 18 MS. CHARISE K. VALENTE 3510 South Michigan Avenue Chicago, Illinois 60653 (312) 745-6115 charise.valente@chicagopolice.org On behalf of the Witness, Superintendent Eddie T. Johnson; ALSO PRESENT Milo Savich, Videographer 19 20 21 22 23 24 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 I N D E X 1 2 3 4 5 WITNESS EDDIE T. JOHNSON DIRECT EXAMINATION BY MR. MORRISSEY: Page 4 PAGE 7-103 6 C E R T I F I E D 7 8 9 10 Q U E S T I O N S LINE PAGE 3 36 11 12 E X H I B I T S 13 14 15 16 17 18 19 20 21 22 23 24 MARKED JOHNSON JOHNSON JOHNSON JOHNSON JOHNSON JOHNSON JOHNSON EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT NO. NO. NO. NO. NO. NO. NO. 18 27 33 31 11 7 1 ****** TOOMEY REPORTING 312-853-0648 PAGE 7 39 44 49 58 67 75 EDDIE T. JOHNSON August 21, 2017 Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 THE VIDEOGRAPHER: August 21st, 2017. Today's date is We are going on the video record at 1:30 p.m. We are present at the Chicago Police Department headquarters, 3510 South Michigan Avenue, Chicago, Illinois 60653 for the purpose of taking a videotaped deposition of Superintendent Johnson. The party on whose behalf the deposition is being taken is the Plaintiff, and the party at whose instance the deposition is being recorded on an audiovisual device is the Plaintiff. This case is instituted in the United States District Court, Northern District of Illinois, Eastern Division. The case number is 13 C 1937, and the case is entitled King versus Evans. My name is Milo Savich, and I am the legal video specialist from Liticorp, 1919 North Milwaukee Avenue, Chicago, Illinois 60647. The court reporter is Peggy Anderson from Toomey Reporting. TOOMEY REPORTING 312-853-0648 I will now EDDIE T. JOHNSON August 21, 2017 Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ask the attorneys to introduce themselves starting with Plaintiff's counsel first. MR. MORRISSEY: Good afternoon. MR. MORRISSEY: My name is Patrick name is Tom Morrissey. Morrissey. MR. BATTLE: My Do you want us to start? My name is Kenneth Battle. Defendant Glenn Evans. I represent MR. BAZAREK: William E. Bazarek for MS. VALENTE: Charise Valente, MS. GARRETT: Steffanie Garrett on Defendant Glenn Evans. General Counsel, CPD. behalf of the City of Chicago. MS. HARRIS: Tiffany Harris on behalf of Defendants Clifford, Sutton, Rodgers and Dixon. THE VIDEOGRAPHER: The reporter will now please swear in the witness, and we may then proceed. (WHEREUPON, the witness was first duly sworn.) TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 7 1 2 3 4 5 6 WHEREUPON: called as a witness herein, having been first duly sworn, was examined and testified as follows: D I R E C T 7 8 9 10 11 12 13 14 15 EDDIE T. JOHNSON, BY MR. THOMAS MORRISSEY: Q Good afternoon. A Eddie T. Johnson. name for the record? Q the Chicago Police Department? A Superintendent of Chicago Police Department. (WHEREUPON, Plaintiff's Exhibit No. 18 was marked 17 19 20 21 22 23 24 Will you state your What is your current position with 16 18 E X A M I N A T I O N BY MR. MORRISSEY: Q for identification.) I'm going to show you what -- I will show you what has been marked as Plaintiff's Exhibit Number 18. It's a two-page document -- actually, it's a three-page document, and it has your name on it as -- with your resume. I ask you to take a look at that TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 8 1 2 3 4 5 6 7 8 document for a moment, and does that look -Did you prepare this document? A Q 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Is there any information on that document which is inaccurate? MS. HARRIS: Counsel, do you have an MR. BATTLE: You can use this one. extra copy? I do not have one. MS. HARRIS: 9 10 It looks like I did. short? Are you going to be Do you all have one? MS. GARRETT: share. MR. BATTLE: BY THE WITNESS: It's okay. We can Oh, okay. A No, it looks like it's correct. Q Is there anything now you would like A Superintendent of the Chicago Police Q When did you become superintendent? BY MR. MORRISSEY: to -- to add to that resume? Department. A 2016. Q I was officially sworn in 13 April of Prior to that appointment, what was TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 your position? A Q I was the chief of patrol. During the period from March of 2008 to August of 2011, were you the commander of the 6th District? A Yes. A It's located on the south side of Q Where is the 6th District located? Chicago, 78th and South Halsted. Q What were your responsibilities at A As the commander of the district, I the 6th District during that period of time? was responsible for the day-to-day operations of police personnel in the district. Q During that period of time, was there a lieutenant by the name of Glenn Evans that worked at the 6th District? A Q Yes. Was he within your leadership group at the 6th District? A Q Yes. How many lieutenants did you have in the 6th District during that period of time? A If I had to guess, it probably TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 fluctuated anywhere from six to seven. Q Page 10 When you were not present in the building at 78th and Halsted, at times, would Glenn Evans be the watch commander? A Q At times, yes. And what responsibilities would Glenn Evans have if he was the watch commander in the 6th District? A As watch commander, he would be responsible for the operations of the personnel in the district during his tour of duty. Q Did you -- In April of 2011, did you work a normal rotation as the commander in the 6th District? A Q In April of 2011, yes. What were your normal hours of work at that time? A I really didn't have normal hours. would start typically -- A typical day for me I back then would have been about a 9:00 or 10:00 a.m. start, and I typically wouldn't go home until about 11:00 or 12:00 o'clock at night. Q In the early morning hours in the 6th TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 District, was there a time period when the prisoners that were locked up in the lockup would be taken to court? MS. GARRETT: timeframe. Objection, form as to BY MR. MORRISSEY: Q In April of 2011. Q Sure, sure. A Okay. Can you repeat the question? At some point in the morning hours, was there a period of time when most of the arrestees that were in the lockup in the 6th District were removed from the lockup and taken to court for court hearings? A Q that be? Typically, yes. And in April of 2011, what time would A My best guess would be probably Q Would it be faay that at sometime between maybe 5:00 a.m. and 7:00 a.m. or about 10:00 a.m. in the morning in April of 2011, that the lockup should be relatively empty? MS. GARRETT: foundation. Objection, form, TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 BY THE WITNESS: A different. It depends. You know, every day was It could be. It could not be. BY MR. MORRISSEY: Q How many lockups did you have in the A One main lockup. 6th District back in April of 2011? Q How many cells did you have, holding cells, did you have in the lockup? A If my memory serves me correctly, maybe about ten holding cells. could be wrong. I could -- I Q Were each of the holding cells A To the best of my knowledge, yes. approximately the same size? Q Approximately how many arrestees could be held in each of the holding cells in the lockup in the 6th District? A I mean, if you had to -- We had a what we call a bullpen that would hold quite a few people at one time. The individual cells, I think, was designed for maybe two people. Q How large was the large holding cell or bullpen? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 Page 13 I couldn't give you the dimensions, but I guess -- I don't know. guess. I really couldn't Q Approximately the size of this A Probably a little smaller. A So maybe about 3/4ths the size of conference room? Q So would you say about -- this -- this conference room. Q So approximately 12 by 16? Q Now, in your experience as the A I suppose. commander in the 6th District, were there times of the day traditionally when the lockup would be most active? A district. The 6th District was a very active So at all times of the day, officers would bring in arrestees. say it fluctuated. time. So I really wouldn't It -- It was busy all the Q In the 6th District, was the building A About ten years old. relatively new back in 2011? I think that building was finished in maybe 1998, so it was TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 14 about ten years old. Q When one -- the public entered the 6th District, was there a vestibule or an area where the desk sergeant worked? A Yes. A It was fairly large, fairly large Q area. How large an area was that? So probably three times as long as this conference room. It was a huge area. Q Does the 6th District encompass the A Some of Englewood. Englewood community? The boundaries to the south would be 75th Street. So Englewood would be on the west side of the Dan Ryan Expressway. So we did have from the Dan Ryan to roughly Western Avenue to the west end of the district. Q In the 6th District in April of 2011, were there a fair number of homeless people, to your knowledge? MS. GARRETT: Objection -- MR. BATTLE: Objection to relevance. MS. GARRETT: Objection, relevance, MS. HARRIS: Objection, speculation. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 15 1 2 3 4 5 6 7 8 9 10 11 12 speculation and foundation. BY THE WITNESS: A to time, yes. BY MR. MORRISSEY: Q 15 16 17 18 19 20 21 22 23 24 In the winter months when it was extremely cold in the 6th District, were there times when you as the commander would allow the homeless to remain in the entryway to the building in the 6th District? A Objection, relevance, foundation. MR. BATTLE: MS. HARRIS: 13 14 I would see homeless people from time BY THE WITNESS: A I'll join. I'll join. Police stations are typically warming centers for homeless people. So we would routinely have homeless people sleep inside the building when it was cold at night, yeah. BY MR. MORRISSEY: Q Now, part of your duties as the commander in the 6th District was to periodically inspect the front area of the 6th District where the homeless people at times would congregate, be allowed to congregate? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 As commander? A No, that would be more the Q Page 16 Yeah. responsibility of a watch commander. Q And my -- my focus on this, Glenn Evans testified in his IPRA statement that, at times, Rita King would be present in the vestibule of the 6th District because she was homeless. Do you have any personal knowledge -- Prior to April of 2011, do you have any personal knowledge of a woman by the name of Rita King? MR. BATTLE: I'm just going to object to the extent it mischaracterizes his testimony, form and foundation. BY THE WITNESS: A No, no personal knowledge. Q Did you ever participate in an arrest BY MR. MORRISSEY: or processing of Ms. King while you were the commander of the 6th District? A Q No, not that I recall. At some point in your career, you TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 became a deputy chief of Area Central, correct? A Q Correct. And that -- You were in that position for what period of time? A Let's see, I was promoted to deputy chief in, I believe, August of 2012, and I held the deputy chief position until December of 2015; but specifically Area Central, I served as deputy chief of Area 4 until about February of 2013, and that's when I became deputy chief of Area Central. Q If we look back at your resume, it has down here you were deputy chief of Area Central from February of 2012 to April of 2014; would that be accurate? A Q Yes. Was the third district one of the districts you supervised as the deputy chief of Area Central? A Q Yes. Was commander -- Was Glenn Evans during that period of time a commander of the third district? A Not for the entire time but for a TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 18 period of time, yes. Q And part of your duties would have been to supervise then Commander Evans when he was the commander of the 3rd District? A Q Yes. Prior to becoming the commander of the 6th District in March of 2008, had you ever worked with Glenn Evans? A Q Yes. On -- In what capacity prior to March of 2008 did you work with Glenn Evans? A We were patrolman together in the 6th District, so that was probably somewhere between -- starting in 1988, and we made sergeant at the same time in 1998. I believe it was September '98, somewhere around there. Yeah, so we made sergeant in August of 1998. So we probably worked in the same district, in the 6th District, as patrolmen for roughly ten years. Q Did you ever work in a beat car with A I don't recall us ever being Glenn Evans when you were in the 6th District? partners, I'm sure, because we typically -TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 back then, you did work with different people. We may have worked in a squad car together, but I -- I really don't recall that. He was never my regular partner; but there may have been an occasion or two where we actually worked in the car together, but I don't recall that. Q When you were a patrol officer with Glenn Evans, did you work at times the same shift? A Q Yes. At times, did you socialize with him when you were a patrol officer after work? A No, I don't ever recall ever being at Q Did you ever go to a retirement party A Not with him, no. a social function with Glenn Evans. with Glenn Evans? Q Well, did you ever go to a retirement party when Glenn -- Glenn Evans was -A Was also there? A Could be. Q Yeah. I don't recall ever being at a retirement party at the same time, but it's -- we probably did. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 20 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 Did you consider yourself a friend of Glenn Evans when you were both patrolman in the 6th District for ten years? A I mean, we were acquaintances. don't know how you define friends. I If you define friends as hanging out together and going over to each other's houses, then no, we didn't do things like that. I knew Glenn from work. We may have ran into each other at a retirement party. I can't recall if we did, but we didn't hang out together as patrolmen. Q During that ten years when you were both patrolmen in the 6th District, did you ever talk to other fellow patrol officers about Glenn Evans? MS. GARRETT: BY THE WITNESS: A this: Objection, form. Not that I recall, but I can tell you If someone in the district made a good arrest or something like that, we would often talk about it; but I don't specifically remember talking about Glenn Evans, though. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 21 1 2 3 4 5 6 7 8 9 BY MR. MORRISSEY: Q District back when you were -- you and Evans were patrol officers was known as an aggressive police officer, would the other police officers in the district also know that reputation? 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. BATTLE: Objection, vague as to MS. HARRIS: Join. aggressive definition. MS. GARRETT: 10 11 If a patrol officer in the 6th BY THE WITNESS: A I'll join. It depends on what -- what you call aggressive. You know, we talked about officers being good officers, aggressive in that they were good officers. terminology. So that's how we used that BY MR. MORRISSEY: Q When you were a patrol officer in the 6th District, what did you consider to be a good officer? A Someone who was fair with the public, enforced the laws the way we're supposed to -- to enforce them, someone that did their job and did it in a fair respectful way. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 22 1 Q Did you have an opinion when you were 2 a patrol officer with Glenn Evans whether or 3 not he fell into that category as a good 4 officer? 5 6 7 A I thought Glenn was a good dedicated Q At that time did you know that -- Let officer, yeah. 8 me give you a preliminary question. 9 know what a CR is? 10 A Yes. 11 Q What is a CR? 12 13 14 A Do you That's a complaint against a police officer for a litany of allegations. Q Back when you were a patrol officer, 15 was the organization that reviewed citizen 16 complaints the Office of Professional 17 Standards? 18 A Yes, OPS. 19 Q When you were a patrol officer with 20 Glenn Evans, did you -- were you aware of the 21 fact that Glenn Evans had numerous CR 22 complaints against him as a patrol officer? 23 A No. 24 Q Did you have any knowledge in regards -TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 23 1 2 3 4 5 6 7 when you were a patrol officer in regards to Glenn Evans' reputation as being a person that had numerous civilian complaints against him? MR. BATTLE: foundation as to "reputation" as well as being argumentative. MS. GARRETT: MS. HARRIS: 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Objection to form, BY THE WITNESS: I'll join. I'll join. A No. Q In the 6th District in April of 2011, BY MR. MORRISSEY: was there an area of that building which was used to process arrestees? A Yes. A On the first floor. Q Q Where was that area located? Where in relation to the lockup area was the area that was used to process arrestees? A Q Adjacent to it, so right next to it. To the best of your recollection, how many rooms were there to process arrestees in the 6th District? And all of my questions are TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 geared toward April of 2011. A So the processing area wasn't really split up into rooms. cubicles. It was split up more into So there might have been like ten computer stations inside that processing room area, and that's where officers would do their paperwork for the arrestee. Q Can you describe the dimensions of A Oh, crap. that processing room? Little, little -- probably a little longer than this room but not quite as wide, and the -- the computer terminals -Q So at least 20 feet long? Q Were there desks or booths where the A Yeah, something like that. Yeah. officer would communicate with the arrestee? A The officer would typically sit on one side of a -- It's kind of a booth setup. It's kind of hard to describe it, but the -the arrestee would sit on the -- on one side and the officer would sit on the other side where the computer equipment was. So they would have the offender sitting on the other side handcuffed most of TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 the time, and the officer could see them but they would be split because we had equipment that you really wouldn't want arrestees being able to get ahold of. Q You mentioned that -- Was there a policy -- Did you have a policy or procedure that when an arrestee was brought into the building at the 6th District that they would remain handcuffed? A Well, I think that's a safety issue for the officers. So when you -- You don't take them out of handcuffs typically until you're getting ready to turn them over to the lockup keeper. Q As the commander in the 6th District, before an arrestee was brought into the building at the 6th District, were they thoroughly searched? A Well, by our -- That's governed by our general orders. the city. So that's universal around So we would search an arrestee as thoroughly as we could before we would bring them into the building. Q So the arrestee, back in April of TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2011, would be thoroughly searched to see if the person was carrying any weapon or contraband? MR. BATTLE: Objection, mischaracterizes his testimony. MS. GARRETT: BY THE WITNESS: Join in the objection. A They should be. Q When they're brought into the BY MR. MORRISSEY: processing room, you mentioned they're handcuffed. Is it -- At times, were the -- were the handcuffs attached to any type of ring or permanent device? MS. GARRETT: That's vague. Objection, form. We're not talking about any particular incidents. BY THE WITNESS: A there. It's speculative. Yeah, there were handcuff rings back BY MR. MORRISSEY: Q So for each of the positions where an arrestee was processed in the processing room, it was possible to have the arrestee restrained TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 27 1 2 3 4 5 6 7 8 9 10 11 12 to a ring? A Q 15 16 17 18 19 20 21 22 23 24 Are there times in the 6th District where the arrestee -- the identity of the arrestee is known -- MS. GARRETT: Objection. BY MR. MORRISSEY: Q -- prior to the exchange of maybe their identification? MS. GARRETT: foundation, vague. MR. BATTLE: MS. HARRIS: 13 14 To the best of my recollection, yes. Objection, form, Join. I'll join and add speculation as well. BY THE WITNESS: A When an officer makes an arrest, you may have the occasion to know somebody prior to making that arrest, yeah. BY MR. MORRISSEY: Q In the processing room, does the arresting officer prepare like an arrest report and the case report if it's a domestic disturbance? A If the person is being arrested, yes, TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 28 they would. Q And it's normally the arresting officers that complete the paperwork or the computer entries for the person that they arrest? A Q Normally, yes. After the arrest report and the case report are prepared, is there a normal procedure where the person is brought into another area to be processed? A Yes, after the paperwork is completed by the arresting officer, then that officer would typically turn the person over to the lockup keeper; and that's the person that would hold -- detain them inside the lockup facility. Q Can you describe the lockup facility A So the processing area is where they for me in the 6th District? would generate the paperwork, and then there's a door that they would go through where the actual lockup is housed; and back there are where you would find the actual detention cells. Q Is the large holding cell also back TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 in the lockup? A Q Correct. In April of 2011, approximately how many officers or detention aides worked in the lockup at the 6th District? MS. GARRETT: Objection, form, officers or detention aides. BY MR. MORRISSEY: Q Let me ask a preliminary question. Were there detention aides that worked in the 6th District in April of 2011? A aides. I don't know if there were detention There would have been a lockup keeper or a detention aide. Now which one was back there, I couldn't tell you. Q In the morning hours between 8:00 a.m. and, let's say, noon in April of 2011, would you have more than one lockup keeper? A During all shifts, there would be more than one back there; but now lockup keeper and detention aide is actually the same thing. We just -- One is sworn and one is not sworn. So at any given time, you're going to have at least two or three back there. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Q are not arrestees allowed back in the lockup area? A Q 17 18 19 20 21 22 23 24 No. Prior to placing an arrestee in a cell or the holding bullpen, was there a process generally that was followed in the lockup -- MR. BATTLE: BY MR. MORRISSEY: Q Objection -- -- in April of 2011? MR. BATTLE: Just renew my objection MS. HARRIS: I'll join. to incomplete hypothetical. MS. GARRETT: 15 16 Are members of the general public who BY THE WITNESS: Join. A Can you repeat the question? Q Sure. BY MR. MORRISSEY: When an arrestee in April of 2011 was brought into the lockup by the arresting officer -A Okay. A So once that -- that person is Q -- what happened in the lockup? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 brought into the lockup, then the lockup Page 31 keeper -- So the sworn officer or the detention aide would then take custody of that person, and they will start the booking process, which included fingerprinting the individual and putting them in a detention cell. Q Under the normal procedures in April of 2011, did the arresting officers normally accompany the arrestee into the lockup? A It's a case-by-case basis. Q If the arresting officers didn't they would. Sometimes they wouldn't. Sometimes bring them into -- bring the arrestee into the lockup, who would? A there. They would always bring them in They just wouldn't stay back there. maybe I wasn't clear on that. would take them back there. So So the arresting Sometimes they would stay with the lockup personnel until the booking process was completed, and sometimes they would not. Q When you were a commander in the 6th District, were there times when arrestees who were were brought TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 32 1 2 3 4 into the 6th District? 7 8 9 10 11 12 13 Objection, incomplete MS. HARRIS: I'll join. hypothetical. MS. GARRETT: 5 6 MR. BATTLE: and form. MS. HARRIS: as well. THE WITNESS: question. 16 17 18 19 20 21 22 23 24 And I'll join in those Okay. MR. MORRISSEY: repeat the question? Repeat the Peggy, do you want to (WHEREUPON, the record was read as requested.) 14 15 Objection, foundation BY THE WITNESS: A I can't say that I have personal knowledge of that, but I would guess that, yes, that that would happen from time to time. BY MR. MORRISSEY: Q In addition, were there times when arrestees were brought into the 6th District that might have been high on street drugs? MS. GARRETT: foundation, form. Same objection, TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 33 MR. BATTLE: 1 MS. HARRIS: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 19 20 21 22 23 24 Join. Same objections, speculation as well. BY THE WITNESS: A Again, I don't have any personal recollection of that, but I'm sure just the nature of what we do, I'm sure, at times that that occurred. BY MR. MORRISSEY: Q When you were the commander of the 6th District, were there times, to your knowledge, when an arrestee in the lockup area was unwilling or unable to be fingerprinted? A Again, I don't have any personal recollection of that, but I'm sure that happened from time to time. Q If a prisoner was and was brought into the lockup and was uncooperative in being fingerprinted, what were the options of the arresting officer and the lockup keeper? MR. BATTLE: Objection, incomplete hypothetical, form, foundation, speculation. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 34 MS. GARRETT: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 those. MS. HARRIS: of those as well. Join as to all of And I'll join as to all BY THE WITNESS: A Well, options would be to let the person sit back there until they decided to cooperate and be fingerprinted because that would extend the time that they would actually have to be back there. You know, I have seen occasions where we went and asked a judge to order the person to be fingerprinted, so those were options. BY MR. MORRISSEY: Q In the lockup area, you mentioned that one option was to allow an uncooperative arrestee to sit back there until they agreed to be fingerprinted, correct? A Q Correct. Where in the lockup area would an uncooperative arrestee who didn't want to be fingerprinted be placed? A Put them in the same detention cell we put a person that had been printed. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Q So one of the ten detention cells in A Correct. the 6th District? Q April of 2011 in regards to what -- the names of the arrestees that were in the detention cells? A Was there rosters? A Yes, I'm sure there was. Q Q 20 21 22 23 24 (Indicating.) To your knowledge, does the -- do the -- does the police department keep records of what cell or holding cell an arrestee was placed in in the lockup? MR. BATTLE: now or in 2011? Are you talking about MR. MORRISSEY: MS. GARRETT: 18 19 Now, were there records maintained in In 2011. Are you talking about the 6th District or in general? MR. MORRISSEY: the 6th District. Well, I'll ask for BY MR. MORRISSEY: Q In April of 2011, did the 6th District keep records in regards to what cell TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 an arrestee was placed in? A Q Best of my knowledge, yes. **** And to your knowledge, does the superintendent of the Chicago Police Department maintain those records for a period of time? MS. GARRETT: Objection, that's beyond the scope of this deposition. don't need to answer that question. MR. MORRISSEY: BY MR. MORRISSEY: Q You We'll certify it. As the commander of the 6th District, were you familiar with the term command channel review? A Yes. A So when a complaint is made against a Q What is the command channel review? police officer, it's investigated either by what was called OPS at the time or by a department member. Whichever way it's investigated, at the conclusion of that investigation, the investigating person makes a recommendation and then they send it up the accused person's chain of command, which starts with the district command or the unit TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 37 commander. Q In April of 2011, was IPRA in A Oh, crap. Q Did the same process whether it was existence? I don't recall if it was. I really don't recall whether it was IPRA or not. called OPS or IPRA in April of 2011 take place in regards to a CR that was reviewed by one of those organizations? A Q To the best of my knowledge, yes. Now, as commander of the 6th District, were you aware of any CRs that were brought -- by CRs, I mean civilian complaints which were brought against Glenn Evans, a lieutenant under your command? MS. GARRETT: April of 2011? Are we talking about in MR. MORRISSEY: 2011. Prior to April of BY THE WITNESS: A Not that I recall, no. Q To your knowledge, when there's a BY MR. MORRISSEY: TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 command channel review of a CR, does the police department's CLEAR system keep a record of the commander that reviewed the CR complaint and the finding by either IPRA or OPS? MS. GARRETT: Objection, form. timeframe are we talking about? MR. MORRISSEY: 2011. What Prior to April of BY THE WITNESS: A Would the commander -- Repeat that. Q Sure. BY MR. MORRISSEY: A What is the CLEAR system? It's a computerized database that the Chicago Police Department utilizes to track information. Q Is part of the information maintained in CLEAR information in regards to command channel review of CRs against a police officer? A Yes, that's maintained in that Q Would your memory be refreshed if we system. looked at several CLEAR records in regards to CR files against Glenn Evans, which you reviewed as commander of the 6th District? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 39 MS. GARRETT: 1 2 3 4 foundation. 6 7 8 9 10 11 12 13 14 15 16 I don't even know what that question means. MR. BATTLE: MS. HARRIS: 5 well. Q 21 22 23 24 I'll join in that as When you were a commander in the 6th District and Glenn Evans worked under you, were you aware of any citizen complaints against Glenn Evans in regards to excessive force? MR. BATTLE: Objection, asked and answered to the extent of any CRs. BY THE WITNESS: A Not that I can specifically recall. (WHEREUPON, Plaintiff's Exhibit No. 27 was marked 18 20 I'll join. BY MR. MORRISSEY: 17 19 Objection, form, BY MR. MORRISSEY: Q for identification.) I'm showing you what has been marked as Plaintiff's Exhibit Number 27. in under CLEAR as 1006219. It's logged I would ask you to take a look at this document for a moment. MR. MORRISSEY: (Document tendered.) TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 40 MS. GARRETT: 1 MR. MORRISSEY: 2 copies of this one. 3 MR. BATTLE: 4 MR. MORRISSEY: 6 7 8 9 10 BY MR. MORRISSEY: 13 16 17 18 19 20 21 22 23 24 I got a lot. Q Have you had an opportunity to look A Yes. Q On page 1 of Exhibit 27, does your name appear? A Q 14 15 You got at Exhibit Number 27? 11 12 We got a lot of No problem. enough of that one? 5 Thank you, Counsel. Yes. Why does your name appear on page 1 of Exhibit 27? A I was the first person it appears in the command channel review being the district commander of that district. Q What were your responsibilities in A My responsibility -- responsibility regards to this civilian complaint by -- by -by would be to review the packet and determine whether or not I concurred or not concurred TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 with the investigating person's recommendation. Q If we look at page 4, does it reflect the allegations that against Mr. Glenn Evans? brought A Page 4? Q And part of the allegations were that allegations. Yes, it reflects the Glenn Evans punched , placed hold, pushed , Tasered in a choke against the wall and failed to provide any medical attention, correct? A Q Correct. Did you make a recommendation in regards to A ' CR complaint? I don't believe I made a recommendation. I believe I concurred with the investigator's recommendation. Q If we look at page 11 of Exhibit 27, A Yes. there's the investigation report? Q Do you know a Deputy Chief Tina Skahill, S-k-a-h-i-l-l? A Yes. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 42 Q 1 2 3 4 Mr. Glenn Evans, did it go up to the deputy chief? A Q 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 After you reviewed the CR against Yes. And initially, did IPRA return a finding against Glenn Evans? yes. A As far as I can determine from this, Q And the deputy chief of the Chicago A Some of this wording is blotted out, Police Department didn't concur, correct? but from the best I can tell -MS. GARRETT: BY MR. MORRISSEY: Q Don't guess. Well, I'm going to show you a better -- perhaps a better copy of it. The -- I believe part of that was probably redacted by maybe the defense lawyers, but I'm going to show you our notebook, which has the investigation report of page -- page 11. MS. GARRETT: Just so the record is clear, none of this was redacted. confidential stamp. MR. MORRISSEY: It's a Well, apparently, TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 that makes it difficult for the witness to see it. BY MR. MORRISSEY: Q Take a moment to look at the document that isn't marked confidential. MS. GARRETT: So the record is clear, it's still marked confidential. It's just not printed out with confidential coverings and letters. BY THE WITNESS: A All right. So in reading the clearer version, apparently Deputy Chief Skahill asked that the case be returned to address some concerns that was raised by her; but in this particular document, it doesn't specify what her concern was. BY MR. MORRISSEY: Q Did you participate in the -- You participated in the command channel review in regards to A Q Correct. complaint? Did -- Did you agree with either IPRA or OPS' finding against Glenn Evans? A Yes. And if you look, the request by TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 9 10 11 12 13 Deputy Chief Skahill was made in 2007. District until 2008. 18 19 20 21 22 23 24 So she had made that request prior to me becoming the commander. I have no idea what -- what her concern was. Q So But you eventually weighed in on ' complaint against Commander Evans or Glenn Evans? A Correct. A Do you want this back? Q Q Do you mind if we -Thanks. (WHEREUPON, Plaintiff's Exhibit No. 33 was marked for identification.) 15 17 I didn't become deputy -- or commander of the 6th 14 16 Page 44 BY MR. MORRISSEY: Q I'm going to show you what's been marked as Plaintiff's Exhibit Number 33. a 33-page document. document. I'm sorry. MR. MORRISSEY: It's It's a 15-page And I think we don't -- We don't have any further copies. If you want to take a break, we can make a copy. MR. BATTLE: If you can identify it TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 for the record, I think that's fine. MR. MORRISSEY: Sure. Plaintiff's Exhibit 33. MS. GARRETT: It's No, he means actually identify the document. MR. MORRISSEY: It's logged in as 1020192, and it's Bates Stamped King FCL -FCRL 003520. BY MR. MORRISSEY: Q Do you need some time to review that? MS. GARRETT: BY THE WITNESS: Yes. A Okay. Q Have you had an opportunity to review A Yes. BY MR. MORRISSEY: Exhibit 33? Q A Q That was a civilian complaint by , correct? Correct. And it was filed or presented to IPRA on September 22nd, 2008 if you look at page 11 of Group Exhibit 33. MS. GARRETT: Counsel, this document TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 is really difficult to read. same reasons. It's for the The way that you printed out the confidentiality mark cuts off most of the narrative. MR. MORRISSEY: Well, it's the way the -- the City presented it to Plaintiff's counsel. We can pull it up on the -- on the computer if that makes it easier for the deponent to read. BY MR. MORRISSEY: Q A question? Do you understand my question? Yes. Oh, can you repeat that MS. GARRETT: Yeah, he's going to pull up the actual document, though, so you can read it. BY MR. MORRISSEY: Q Superintendent Johnson, I'm -- I'm presenting you with our notebook document, Exhibit 33, page 11, for you to look at. A Q That's much better. Go ahead. In looking at the allegations, does it reflect that on September 19th, 2008 -- I'm sorry, September 19th, 2008 at approximately TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 47 1 2345 hours that there are allegation against 2 Glenn Evans who was a lieutenant under you at 3 that time? MR. BATTLE: 4 whether that document reflects that? 5 6 BY THE WITNESS: A 7 8 Yes. BY MR. MORRISSEY: Q 9 10 You're just asking him You were the -- You were Lieutenant Evans' commanding officer at that time? 11 A Yes. 12 Q And the allegations in this civilian 13 complaint were that Glenn Evans shot dog without justification, choked a 14 15 person by the name of 16 threw , , against a fence and grabbed by the hair and threw her to the 17 18 ground, directed profanities at 19 punched 20 that accurate? and kicked 21 A Yes. 22 Q If we look at the first page of (sic), ; is 23 Exhibit 33, were you -- did you review this 24 allegation? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 A Q 18 19 20 21 22 24 Yes. That's because you were the commanding officer? A Q That's correct. Did you interview Glenn Evans after receiving these allegations from IPRA? A Q No. Did you as the commanding officer take any action to discipline Glenn Evans in regards to these -- MR. BATTLE: That assumes that discipline was warranted. BY MR. MORRISSEY: Q -- allegations. MS. HARRIS: MS. GARRETT: 16 17 Page 48 I'll join as well. Join. form and foundation. Objection as to BY THE WITNESS: A No. Q Were these allegations sustained? Q Did you review the investigation that BY MR. MORRISSEY: A TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 49 1 2 3 4 5 6 IPRA did in regards to A Q Yes. Did you find any fault with IPRA's investigation of this person's complaints? A No. (WHEREUPON, Plaintiff's Exhibit No. 31 was marked 7 8 9 10 11 12 13 BY MR. MORRISSEY: Q 16 17 18 19 20 21 22 23 24 for identification.) I'm going to show you what is marked as Plaintiff's Exhibit Number 31. complaints brought by MR. BATTLE: BY MR. MORRISSEY: Q It's -- You said 30 or 31? MR. MORRISSEY: 14 15 ' complaints? It's Exhibit 31. -- in regards to an incident on May 24th, 2008. I ask you to take a look at -- at that document for a moment. A Q Okay. Were you part of the command channel review of this complaint by A Q Yes. And you're aware that ? complained that Glenn Evans pointed a gun at TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 50 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 him, pulled his hair without justification, arrested MS. GARRETT: for burglary? Counsel, if you're reading off a specific page, I would ask that you reference it. MR. MORRISSEY: BY MR. MORRISSEY: Q Page 1. Entered and searched vehicle without a warrant and threatened to shoot A Yes. A Yes. Q Q ' ' dog? Are those among the allegations? And that was -- Those allegations, again, were in May of 2008? A Q Yes. And did you make a recommendation based upon your review of those allegations? A I didn't make a recommendation. I, Q And what was the finding by the IPRA again, concurred with the investigating person. person? A TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 51 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 When did you make those -- When did A It looks like I -- February of 2009. you review it? Q If we looked to the right of the first page, it says: IPRA OTS case, what does that mean, where two levels of CCR concur with the findings. This case should be forwarded to implementation action. A Q I'm not sure. When you were the deputy chief of Area Central, did you review or through a command channel review of any complaints brought by citizens against Glenn Evans? A I can't recall any specific ones, but Q When you were a commander of the 6th I probably did. District, did Glenn Evans have a reputation of being an aggressive police officer? MR. BATTLE: Objection, asked and answered, form, foundation as to reputation. MS. GARRETT: MS. HARRIS: I'll join. I'll join as well. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 BY THE WITNESS: A being a good aggressive officer. BY MR. MORRISSEY: Q 18 19 20 21 22 23 24 As his commanding officer, would you receive quarterly reports from the police department if an officer had sustained allegations against him? A Q Yes. As a commanding officer, if you found that a police officer had repeat instances of using excessive force against citizens, could you recommend that he go to a behavioral intervention program? MS. GARRETT: MR. BATTLE: 16 17 Yeah, he -- he had a reputation as as well. Objection, form, vague. Incomplete hypothetical BY MR. MORRISSEY: Q Let me ask a preliminary question. What is the -- In April of 2011, what was the behavior -- behavior intervention program for the Chicago Police Department? A The behavior intervention program is a program designed to flag what could be TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 considered problematic behavior in an effort to correct it. Q How does that differ from what's A Personnel concern could be considered called a personnel concerns? more disciplinary than the behavior intervention system. Q in his or her district for using excessive force against citizens? MS. GARRETT: foundation. 17 18 19 20 21 22 23 24 Objection, form, What timeframe are we talking about? MR. MORRISSEY: MS. HARRIS: 15 16 Can a commander flag a police officer April of 2011. I'll agree with those objections, concur, join. BY THE WITNESS: A Sustained allegations of excessive force, yes. BY MR. MORRISSEY: Q If IPRA had not sustained allegations of excessive force against a patrol officer but the commanding officer felt that there was some credibility to the complaints, could the TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 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 commanding officer refer the patrol officer to a behavior intervention program? MR. BATTLE: Objection to the extent it's an incomplete hypothetical. MS. GARRETT: I'll join in the objection, also as to form, foundation, vagueness. MS. HARRIS: objections. I'll join all of the BY THE WITNESS: A In certain situations and instances, I suppose a commander could, yes. BY MR. MORRISSEY: Q Under what circumstances where there were repeated allegations of excessive force by an officer could a commander refer that officer to a behavior intervention program even though the complaints were not sustained by OPS or IPRA? MS. GARRETT: Objection, form, compound, speculative, vague, hypothetical. MR. BATTLE: MS. HARRIS: Join. I'll join. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 BY THE WITNESS: A 22 23 24 I suppose if you were to look at narratives of excessive force complaints and those narratives were similar, you would take some corrective action. BY MR. MORRISSEY: Q Would that include referring the A Yes. person to a behavior intervention program? Q Would that include -- possibly include the Personnel Concerns Program by the police department? A Q It could, yes. In regards to Glenn Evans, when you reviewed each and every one of those IPRA referrals through the command channel review, did you go back and look at other allegations brought against Lieutenant Evans? MS. GARRETT: MR. BATTLE: 20 21 Page 55 BY THE WITNESS: A Objection, form. Join. If you're asking me did I compare them, no, I didn't. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 56 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. MORRISSEY: Q When you were a commanding officer, did you -- Well, strike that. In the -- As a commanding officer, did you have the ability to pull up in the CLEAR system CRs that were brought -- charges which were brought against one of your patrol officers? A No. The only time you could review it is when it was in your queue for command channel review. Q After that, it's gone. So when -- when -- The three examples that we have just discussed, when you were asked to review an IPRA or OPS finding in regards to an allegation against Glenn Evans, in any of those cases, did you pull up in the CLEAR system information in regards to prior CRs brought against Glenn Evans? MS. GARRETT: Objection. testified he couldn't. MR. BATTLE: BY THE WITNESS: He just Join. A No, I wouldn't have had that ability. Q You testified that when you were BY MR. MORRISSEY: TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 57 1 2 3 4 5 6 7 8 9 10 11 12 doing a command channel review, you had the ability to look in the CLEAR system to see whether there were other prior CRs against a police officer? A another CR, but you wouldn't be able to see the details of that CR. Q prior claims of excessive force brought against one of his officers? MS. GARRETT: MR. BATTLE: MS. HARRIS: 14 16 17 18 19 20 21 22 23 24 In April of 2011, what information was available to a commanding officer about 13 15 You might be able to see if there is BY MR. MORRISSEY: Q A Objection, form, vague. Join. I'll join. Do you understand the question? Yeah. The only thing that I would have had would be like a quarterly report that came from internal affairs and it -- the only thing that it would have is a list of CR allegations, but it wouldn't go into detail. So I didn't have anything where I could put all of them next to each other and look at them like that. There was nothing TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 available at that time. MS. GARRETT: 2 3 We're going to take a break right now. MR. MORRISSEY: 4 5 Page 58 Sure. What time is it? 6 MS. GARRETT: It's 2:33. 7 THE VIDEOGRAPHER: Okay. The time is 8 2:34 p.m., and we are going off the video 9 record. 10 (WHEREUPON, a short 11 break was had.) THE VIDEOGRAPHER: 12 13 14 15 16 17 18 19 and we are back on the video record. BY MR. MORRISSEY: Q Superintendent, prior to today's deposition, what documents did you look at? A I looked at some documents that came. It was correspondence between Sharon Fairley, IPRA administrative director, and myself. (WHEREUPON, Plaintiff's 20 Exhibit No. 11 was marked 21 22 23 24 The time is 2:50 p.m., BY MR. MORRISSEY: Q for identification.) Showing you what has been marked as TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 59 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Plaintiff's Exhibit Number 11. exhibit, page 1 through 14. A Q It's a group Okay. Did you look at Exhibit Number 11 prior to today's deposition? A Q Yes. In addition to Exhibit 11, did you look at any other documents? A Q No. If we turn to Exhibit 11 for a moment, page 7, there's a letter from a Ms. Fairley to you, correct? letter? A Correct. A Correct. Q Q It's a three-page And that's dated May 6th, 2016? And it's in regards to Officer Sutton, Officer Clifford and Glenn Evans, correct? A Q Correct. Why would you receive a letter in regards to an IPRA recommendation in regards to Evans and the two other officers? A If IPRA and myself don't agree on a TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 60 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 disciplinary recommendation, then we will meet and discuss it and see if we can come to a resolution in that way. Q When you received this letter from Ms. Fairley from IPRA, what did you look at in reviewing the allegations by Ms. King against Glenn Evans and the two other officers? A I was given the investigator's Q Were you given the IPRA file in recommendations in their investigation. regards to Ms. King's allegations against Glenn Evans and the two other officers? A Q The complete file, no. Were you given the statement that Glenn Evans gave to the IPRA investigator? A If it's contained in the -- in the Q And prior to responding -- You IPRA investigator's summary, then yes. responded to Ms. Fairley in regards to Glenn Evans on May 13th, 2016? 5 and 6, correct? A Q It's Exhibit 11, page Yes. Both you and Ms. Fairley mention in the body of your letters that Glenn Evans TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 61 1 didn't have any sustained CRs against him 2 during his career; isn't that correct? 3 A MR. BAZAREK: 4 5 THE REPORTER: MR. BAZAREK: THE REPORTER: MR. BAZAREK: MR. MORRISSEY: 15 stands. 16 you'd like. 18 19 I'm objecting. It does It's what? Say it Have him repeat the Well, the record You can read it -- read it back if Do you want to read back that -- BY THE WITNESS: A So it indicates he didn't have any sustained allegations in his disciplinary 20 history. 21 BY MR. MORRISSEY: 22 What did question, so I can make the objection. 14 17 I'm sorry. again. 12 13 You're not say career. 10 11 I object. you say? 8 9 Yes. saying career? 6 7 Okay, right here. Q When you, as the superintendent, 23 responded to Ms. Fairley in May of 2016, did 24 you or your staff look at the total number of TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 62 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 CRs that had been filed or brought by citizens in regards to Glenn Evans' conduct as a police officer? A I can't speak to my staff; but me, personally, every incident stands on its own merits. So I don't compare what happened with another incident. Q As superintendent, in May of 2016, were you aware that over 100 citizens complaints have been brought against Glenn Evans in regards to misconduct as a police officer? A Q No. Did you do anything to check with IPRA or OPS or any other agency within the police department to determine how many complaints had been filed in regards to Glenn Evans' conduct as a Chicago police officer? MR. BATTLE: Objection and foundation to the extent he said he did not review the prior CRs. MS. GARRETT: BY THE WITNESS: A No. Join in the objection. Again, when I review the TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 63 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 from IPRA, that investigation stands on its own merits. BY MR. MORRISSEY: Q When IPRA said that there hadn't been any sustained allegations against Glenn Evans, were they speaking of a five-year-look-back period or longer? MS. GARRETT: foundation. MR. BATTLE: BY THE WITNESS: A Objection, form, And speculation. That would be a question IPRA would have to answer. BY MR. MORRISSEY: Q When you said that there were no sustained allegations in regards to Glenn Evans' conduct as a police officer, did you look only at a five-year period of time or did you look at his entire career? A I believe per the FOP contract, we go Q Why as a superintendent of police, back five years. when you reviewed this file for IPRA in May of 2016, why didn't you go back more than five TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 64 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 years to determine whether Glenn Evans had a history of using excessive force against citizens? MS. GARRETT: answered, form. MR. BATTLE: BY THE WITNESS: A Objection, asked and I will join it. Again, each incident, each complaint, when it's reviewed by IPRA and they give me the recommendations, that investigation stands on its own merits and that's what I review. BY MR. MORRISSEY: Q As Glenn Evans' commanding officer in the 6th District and as his deputy chief for several years after he became a commander, you personally are aware of other citizen complaints filed in regards to Glenn Evans' conduct; is that fair to say? A Q Yes. As either a commander or a deputy chief for the Chicago Police Department, do you personally know of any other officer or lieutenant or commander in the Chicago Police TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 65 1 2 3 4 5 Department that had more allegations of excessive force than Glenn Evans? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. BATTLE: Yep, I'll join it. MS. HARRIS: I'll join it as well. MR. MORRISSEY: 7 9 Objection, form, foundation and beyond the scope. 6 8 MS. GARRETT: scope. It is not beyond the The Judge specifically said during the hearing that his state of mind is on the table in regards to this deposition. So I think it -- it is appropriate, the question. MS. GARRETT: question is. It's not what the The question had nothing to do with his state of mind, and any other allegations against any other officers are beyond the scope of this deposition. BY MR. MORRISSEY: Q When you reviewed Ms. King's allegation as part of the command channel review in 2016, was Glenn Evans still with the police force? A Yes. Glenn Evans has never been separated from the police department. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 66 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 Was there ever a finding, a sustained finding, against Glenn Evans in regards to Ms. King's allegations? A Yes. IPRA did sustain the findings. Q Did -- To your knowledge, was Glenn A From this particular incident? What we disagreed with was the recommendations. Evans ever disciplined? Q Yes, the incident that Rita King brought in regards to Glenn Evans? A Q I'm not aware. Do you still consider Glenn Evans to be a good police officer? A Q Yes. You mentioned that you reviewed part of the IPRA file in regards to Rita King's allegations, correct? A Not the IPRA file. I reviewed the Q Did you review the statement that summary that the investigator forwards on. Glenn Evans gave to IPRA? MR. BATTLE: answered. MS. GARRETT: Objection, asked and Join in that objection. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 67 1 2 3 4 5 BY THE WITNESS: A If it was contained in the summary that I was given, then yes; if it wasn't, then no. (WHEREUPON, Evans Exhibit No. 7 was marked for 6 7 8 9 10 11 12 BY MR. MORRISSEY: Q 15 16 17 18 19 20 21 22 23 24 I'm going to show you what has been marked for identification purposes exhibit -what is it -- Exhibit Number 7. MR. BATTLE: 7? MR. MORRISSEY: 13 14 identification.) BY MR. MORRISSEY: Q 7. It's a statement that Glenn Evans gave to Rita (sic) Franko on November 7th, 2013 and it's 43-page document. I will ask you as part of your command channel review -MS. GARRETT: Counsel, do you have another copy of that? MR. PATRICK MORRISSEY: tendered.) BY MR. MORRISSEY: Q (Document -- did you review the statement that TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 68 1 2 3 4 5 6 7 8 9 Glenn Evans made? A Q This particular document, no. What documents did you review in preparing this response to Ms. Fairley? MS. GARRETT: answered. MR. BATTLE: BY THE WITNESS: Objection, asked and Asked and answered. 10 11 12 13 1 15 16 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 69 1 MR. BATTLE: 14 15 16 17 18 19 20 21 22 23 24 Commander, before you answer that question, I'd just like to log an objection to foundation to the extent this is Ms. Fairley's letter. written by Ms. Fairley. It was She's not here to testify as to this letter, and Superintendent Johnson would only be just reading it and acknowledging what it says in writing. BY MR. MORRISSEY: Q Go ahead, Commander. Do you see the portion of the -TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 70 1 2 3 Ms. Fairley's letter that I read from? A Yes. 18 19 20 21 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 71 1 15 16 17 18 19 20 21 22 23 24 Q As the commander then in April of 2011, there were available facilities in the 6th District to have removed Ms. King from the area and allowed her to wait to be fingerprinted? MR. BATTLE: Objection to the extent you're saying "available facilities." vague. MR. MORRISSEY: question. It's Let me rephrase the TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 72 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. MORRISSEY: Q In the 6th District in April of 2011, there were holding cells in the lockup where Lieutenant Evans could have placed Ms. King until she was willing to cooperate in the fingerprinting process? A In the 6th District, no, because it would have been inappropriate to put a female arrestee in the back in the holding cells with male arrestees. So we wouldn't have done that in the 6th District. female arrestees. Q It isn't set up for In the processing room, there were rings where Ms. King could have been restrained pending the time she was fingerprinted in April of 2011? A There were rings in there, but I don't think that would have been an appropriate solution to it either for the same reasons. Q In the 6th District when you were -- when -- as commander, a female is brought into the station under arrest and due to the fact she was either high or mentally disabled, where in the 6th District could you hold a prisoner TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 pending the fingerprinting? MS. GARRETT: speculative. Objection, form, vague, MR. MORRISSEY: question. Let me rephrase the BY MR. MORRISSEY: Q In the 6th District in April of 2011, were there areas in the 6th District where an uncooperative arrestee could be restrained pending fingerprinting and photographing? MR. BATTLE: form. Objection to vague and Uncooperative as to male or female? I believe there's a differentiation that you need to flush out. MR. MORRISSEY: BY MR. MORRISSEY: All right. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 74 1 l 5 11 12 13 14 15 16 17 18 19 20 21 22 23 24 l BY MR. MORRISSEY: Q Do you know what time Ms. King came A No. into the 6th District? Q Would the arrest report reflect the time that she was brought into the 6th District? MS. GARRETT: speculative. MR. BATTLE: BY THE WITNESS: A Objection, form, Join. The arrest report will reflect the time that she was arrested. In terms of when she was actually taken into lockup, I'm not -TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 I'm not sure on that. (WHEREUPON, Evans Exhibit No. 1 was marked for 3 identification.) 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 75 BY MR. MORRISSEY: Q I'm showing you what's -- Showing you Exhibit 1, which is the arrest report for Rita King on April 11, two thousand- -- April 10th, 2011. Does that reflect the time of the arrest? MS. GARRETT: his document. Objection. This is not He can only testify to what's on a document that he didn't author. BY MR. MORRISSEY: Q Superintendent, is that an arrest report that was filled out by the arresting officer for Rita King on April 10th, 2011? MS. GARRETT: form. Objection, foundation, He doesn't know. MS. HARRIS: MS. GARRETT: computer screen. I'll join in that. It's a document on your We don't even have copies for people around the table. original. TOOMEY REPORTING 312-853-0648 Never mind an EDDIE T. JOHNSON August 21, 2017 Page 76 MR. MORRISSEY: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 We'll take five minutes to print it out if there's any question. BY THE WITNESS: A It's indicating an arrest date of 10 April 2011, and a time of 0745. BY MR. MORRISSEY: Q If we look further on that document, does it reflect the time -- will it reflect the time Ms. King was brought into the lockup? MS. GARRETT: foundation. Objection, form, It's not his document. MS. HARRIS: Join. MR. MORRISSEY: It's a document that was tendered in discovery. It's the Chicago Police Department's record of Rita King's arrest. MS. GARRETT: objection. I stand on my MR. MORRISSEY: And if we want to take five minutes -- We're doing this at the convenience of the Superintendent. If you want to take five minutes, we'll print it out and we'll attach it to the TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 deposition. BY MR. MORRISSEY: Q Showing you page 4 of Exhibit Number 1, does it show -- does that arrest report show the time Ms. King was brought into the lockup area? MS. GARRETT: Same objections. The document is going to say what it says. This witness has no personal knowledge of it. MS. HARRIS: BY THE WITNESS: A Join. It's indicating received in lockup at 10 April 2011 at 10:28. BY MR. MORRISSEY: Q Between the time of arrest and the time she was brought into the lockup, would it be fair to say that Ms. King was in the processing room in the 6th District? MS. GARRETT: foundation. knowledge. Objection, form, The witness has no personal He's also -- already testified he was not there at the time. MR. BATTLE: Join. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 78 MS. HARRIS: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 add speculation. BY THE WITNESS: A I wouldn't know. Q As the commander in the 6th District, BY MR. MORRISSEY: are there times when arrestees spend one or two hours in the processing room before being booked in the -- MS. GARRETT: BY MR. MORRISSEY: Q 20 21 22 23 24 Objection. -- in the lockup? MS. GARRETT: speculative. Objection, form, MR. BATTLE: Join as to speculation MS. HARRIS: I'll join as well. and incomplete hypothetical. MS. GARRETT: 18 19 I'll join in that and timeframe. And we don't know the BY MR. MORRISSEY: Q A You can answer. I would say, in general, there are times when arrestees will spend more time than others in the processing room, yes. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 24 Q Is it your testimony that one of the options if Ms. King was uncooperative in the lockup area as far as being fingerprinted that she could not have been brought back into the processing room and held until such time as she was willing to be fingerprinted? MS. GARRETT: Objection, form. That's a double negative. the question is. MS. HARRIS: BY MR. MORRISSEY: I'm unclear what I'll join in that. Q Do you understand the question? Q Sure. A Can you repeat it? At some point in time when Ms. King was in the lockup area prior to being fingerprinted, you stated that there was an option that Commander Evans or Lieutenant Evans could have removed her -- Strike that. MS. GARRETT: Objection, asked and TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 80 1 2 answered. MR. BATTLE: MS. HARRIS: 3 4 5 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 BY THE WITNESS: I'll join. I'll join as well. BY MR. MORRISSEY: Q is there any other place in the 6th District wherein Ms. King could have been held until she was more cooperative to be fingerprinted? A No. Again, the 6th District wasn't designed for female -- for detention of female arrestees. Q You used the word "detention." Was Ms. King being held while she was -- her arrest report was being processed? A Q She was being processed, yeah. And she would have been -- part of the processing is filling out the arrest report and case report? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 A 1 Q 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 81 Correct. Part of the processing is being fingerprinted? yes. A That's part of the booking process, Q And part of the process is being A Yes. photographed? Q During that process of being fingerprinted, it's your -- it's your statement that you couldn't be held in any other spot in the 6th District? MS. GARRETT: BY THE WITNESS: A Objection, form. Again, 6th District wasn't designed to hold female arrestees in that manner. Once you're fingerprinted and photographed in the 6th District, you would be immediately transported to Area South to that holding facility. BY MR. MORRISSEY: Q In the 6th District in April of 2011, why were females processed in the 6th District if there were no detention cells? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 A 15 16 17 18 19 20 actually house arrestees. Most of them are designed for just male arrestees because the incident of female arrestees is not that great. 23 24 All female arrestees are housed at area facilities. Q MR. BATTLE: Objection to the extent of form and foundation. letter that he authored. This is not a This is a letter that was authored by Sharon Fairley. He does not know whether it's accurate or not unless you're asking him whether or not it says what you say it says. MS. GARRETT: MS. HARRIS: 21 22 So, in Chicago, the way that it works is we have detention facilities where we 13 14 Page 82 Join in the objection. I'll join in that objection as well. BY MR. MORRISSEY: Q TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 83 1 MR. BATTLE: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Same objection to the extent he does not know that it's accurate or not. says. He just knows what the record MS. GARRETT: Join in the objection and the date is 2016, not 2011. MR. MORRISSEY: Thank you. MS. HARRIS: I'm sorry. 2011 (sic). And I will join in those objections as well. BY MR. MORRISSEY: Q Do you see that in her letter? Q It's page -- It's Group 11, Exhibit A Which page? 11, page 8. A Oh, yes. 24 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 84 1 , 6 7 8 9 13 1 15 16 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 85 1 ? 2 MR. BATTLE: 3 4 5 6 extent that it's an incomplete hypothetical. 9 10 11 12 13 14 15 16 17 18 19 20 21 Go ahead. MS. GARRETT: MS. HARRIS: 7 8 I'll just object to the well. MS. GARRETT: BY THE WITNESS: A Join in the objection. I'll agree with that as Foundation, speculative. That's difficult for me to answer unless I was actually there. BY MR. MORRISSEY: Q Well, let me ask you something: an arrestee be fingerprinted MS. GARRETT: BY THE WITNESS: A Objection, form. They could be, but it's highly unusual that we would do that. BY MR. MORRISSEY: Q TOOMEY REPORTING 312-853-0648 Can ? EDDIE T. JOHNSON August 21, 2017 Page 86 1 MR. BATTLE: 4 5 6 answered. MS. GARRETT: MS. HARRIS: 7 8 9 10 well. Objection, asked and Join in the objection. I'll join in that as BY THE WITNESS: 11 12 13 16 17 18 19 20 21 22 23 24 BY MR. MORRISSEY: Q So as a commanding officer -- You were the commanding officer in the 6th District in April of 2011. When there was an uncooperative person in the lockup, as far as being fingerprinted, what was the procedure in the 6th District. MR. BATTLE: Objection, incomplete hypothetical, foundation. TOOMEY REPORTING 312-853-0648 That's vague. EDDIE T. JOHNSON August 21, 2017 Page 87 1 We have no details related to that 2 question. MS. GARRETT: 3 4 5 BY MR. MORRISSEY: Q 8 9 10 I'll give you -MS. HARRIS: 6 7 Join in that objection. Join in that as well. BY MR. MORRISSEY: Q Assuming at or about 10:30 on April 11th, 2011 a female is brought into the lockup, she's uncooperative, noncombative, and refuses to 12 be fingerprinted, what were the procedures in 13 place under you as the commander? 14 MR. BATTLE: Another objection, 15 incomplete hypothetical, and it assumes 16 facts that are not in evidence in this 17 case. 18 19 20 THE REPORTER: Counsel, can you repeat? MR. BATTLE: I'm sorry. Another 21 objection, incomplete hypothetical and it 22 assumes facts not in evidence in this case. 23 MS. GARRETT: Join in the objection. 24 MS. HARRIS: I'll join the objection. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 88 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 THE WITNESS: A As commander, I didn't have a policy. We are governed by general orders. Those are our guidelines, so that's citywide, not a commander's policy. BY MR. MORRISSEY: Q As the commander in 2011 in the 6th District, what were the procedures given those -- given that hypothetical? MR. BATTLE: Same objection to the incomplete hypothetical. MS. GARRETT: Join in the objection. It's speculative as to form and it's different than the facts in this case. MS. HARRIS: I'll join in those objections as well. BY THE WITNESS: A Given those factors that you put in there, watch commanders have to assess each incident on its own merit. So it would -- it would -- As I said before, one option would be to just let her sit in a holding facility until such time she cooperated. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 89 1 2 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 BY MR. MORRISSEY: Q A Which one are you -- Which exhibit are you looking at? BY MR. MORRISSEY: Q A I'm looking at Glenn Evans. Pardon me? MS. HARRIS: number, Counsel? What's the Bates stamp MR. MORRISSEY: MS. HARRIS: Of her letter? There should be a Bates stamp letter on each page. MR. MORRISSEY: through 12. Is that it? MS. HARRIS: number? Her letter is page 11 Do you have the FCRL MR. MORRISSEY: No, I'm sorry. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 90 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 BY MR. MORRISSEY: Q 19 MR. BATTLE: BY MR. MORRISSEY: Q I'm sorry. His letter? Looking at Ms. Fairley's letter of May 6th, 2016 -MS. HARRIS: So you're looking at Plaintiff's Exhibit 11, page 7, FCRL 010522. MR. MORRISSEY: Actually, I'm looking at page 8, the top of the page. BY THE WITNESS: A Okay. MR. BATTLE: Just for clarity's sake, MS. HARRIS: I believe so. are we on FCRL 10523? MR. MORRISSEY: 17 18 Looking at your letter of May 6th -- BY MR. MORRISSEY: Correct. Q 22 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 91 1 4 8 A 9 10 Okay. f 18 l 23 i "i i What was the question again? i l 30 30 i l " if TOOMEY REPORTING 312-853-0648 i l i l EDDIE T. JOHNSON August 21, 2017 Page 92 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 A of me. Q And when was that? I don't have that document in front How many years did it take for IPRA to make a recommendation, to your knowledge, in regards to Rita King's complaint? A I'm not sure. A If it was more than five years, then Q Was it more than five years? they would have been past the statute for the expiration on excessive force. within that five years. Q So it had to be Is that the reason why, in the end, Glenn Evans was not disciplined at all in regards to Rita King's allegations -MR. BATTLE: Are you asking about IPRA's discipline? BY MR. MORRISSEY: Q years? -- because it was more than five MR. MORRISSEY: superintendent. MR. BATTLE: I'm asking as a You're asking him to TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 93 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 interpret IPRA's policies. BY MR. MORRISSEY: Q 21 22 23 24 MR. BATTLE: Okay. I want to object to the extent he's asking him to interpret IPRA's policy. MR. MORRISSEY: Mr. Battle -- MR. BATTLE: BY MR. MORRISSEY: Q I'm not asking, Okay. I'm asking, to your knowledge, the reason why Glenn Evans has not been disciplined is because it took more than five years for IPRA to review the allegations by Rita King? MS. GARRETT: I'm going to object as to form, foundation and assuming facts not in evidence. MR. BATTLE: MS. HARRIS: 19 20 No, I'm asking you as superintendent. objection. I will join. I will join in that BY THE WITNESS: A No, to -- I'm not sure. Q Did you have any follow-up BY MR. MORRISSEY: TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 94 1 2 3 4 6 7 8 9 10 11 12 13 19 conversation with Ms. Fairley after your letter of May 13th, 2016? A I don't recall if we actually had any Q If we look at Exhibit 11, page 10, conversation, was there communications from Ms. Fairley to you in regards to Glenn Evans? A Q Yes. It states here that you met with Ms. Fairley on May -- May 23rd; is that correct? A Yes. Q TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 95 1 3 8 10 11 12 13 1 15 16 18 19 20 21 22 23 24 Q In order to terminate somebody from the police department, do you have to go to the police board? A Q Yes. Was this matter brought to the police board for Glenn Evans' termination? A I don't recall. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 96 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 Anything that would refresh your A Yes. Q Was there a letter -- Is it part of memory? that it? If we had a document, yes. Is the procedure to go to the police board to have Ms. Fairley write a letter to the executive director of the Chicago Police board? MS. GARRETT: vagueness. Objection, form, BY THE WITNESS: A I'm not sure what Ms. Fairley's protocol is. BY MR. MORRISSEY: Q If we look at Group Exhibit 11 page 11 and 12, it apparently is a letter from Ms. Fairley to Max Capron (sic), C-a-p-r-o -A Q Caproni. -- -n-i, executive director of the Chicago Police board? A Q Yes. Do you know whether or not it ever went to the police board? A I don't recall. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 97 1 2 3 5 6 7 8 9 10 11 12 16 17 18 MR. MORRISSEY: We're going to take a five-minute break. THE VIDEOGRAPHER: Okay, the time is 19 3:35 p.m. This is the end of Tape 1, and 20 we're going off the video record. 21 (WHEREUPON, a short 22 break was had.) 23 24 THE VIDEOGRAPHER: The time is 3:43 p.m. This is the beginning of Tape 2, and we're TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 98 1 2 3 4 5 6 7 8 9 10 11 back on the video record. BY MR. MORRISSEY: Q the 6th District when Rita King was uncooperative but noncombative in the lockup, why was Glenn Evans' decision to use pain compliance control techniques wrong? MS. GARRETT: 14 15 16 17 18 19 20 21 22 23 24 Objection, form of the question, assumes facts not in evidence. That's not his testimony. MR. BATTLE: MS. HARRIS: 12 13 On April 10th, 2011 in the lockup in BY THE WITNESS: A Join. I'll join with that. Just based on what I know, if she was uncooperative and she was already in custody, in my opinion, we could have just waited until she became more cooperative. BY MR. MORRISSEY: Q Is that the reason why you agreed that Glenn Evans should be disciplined? MR. BATTLE: disciplined? That he should be what, MR. MORRISSEY: MR. BATTLE: Disciplined. I'm sorry. TOOMEY REPORTING 312-853-0648 I didn't EDDIE T. JOHNSON August 21, 2017 Page 99 1 2 3 4 5 hear you. BY THE WITNESS: A Yes. BY MR. MORRISSEY: 8 9 10 11 12 13 1 15 16 18 21 22 23 24 MR. BATTLE: Objection, assumes facts MS. GARRETT: Join in the objection. not in evidence. MS. HARRIS: Join. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 100 1 2 4 5 6 7 8 9 10 11 12 13 24 BY THE WITNESS: BY MR. MORRISSEY: Q Can -- Prior to going to the police board, can a member of the Chicago Police Department be disciplined for more than 30 days without going to the police board? MS. GARRETT: BY THE WITNESS: A Objection, form. I don't believe so. BY MR. MORRISSEY: A . TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 101 1 3 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q To your knowledge, was Sutton and Clifford disciplined? MS. HARRIS: Objection, speculation, MS. GARRETT: Join in the objection. foundation. Go ahead. BY THE WITNESS: A I'm not aware of it. Q How would you find out as a BY MR. MORRISSEY: superintendent whether or not Evans, Sutton and Clifford received any discipline in regards to their contact with Rita King on April 10th, 2011? A As superintendent, I would probably confer with the chief of internal affairs and ask him to review it for me. Q To your knowledge, Glenn Evans is still working for the police department? TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 A Q 20 21 22 23 24 Still receiving a salary from the police department? A Q Yes. Still receiving a salary for a lieutenant in the police department? A Q Yes. Did you as a deputy or a superintendent of police, did you ever recommend Glenn Evans for a promotion? A Q No. Could you have transferred Glenn Evans as a lieutenant from the 6th District as a commander? MR. BATTLE: vague. Objection, incomplete, Transfer him where? MR. MORRISSEY: MS. GARRETT: 18 19 To my knowledge, yes. Page 102 timeframe? BY MR. MORRISSEY: Q To another district. Objection, form, what What specifics? During the time you were a commander of the 6th District, did you have the ability to have a lieutenant transferred? A No. That's a contractual issue. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 103 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 MR. MORRISSEY: Superintendent. Thank you, I appreciate it. THE WITNESS: MS. GARRETT: signature. Thank you, all. We will reserve THE VIDEOGRAPHER: follow-up questions? MR. BATTLE: No No questions. THE VIDEOGRAPHER: 3:49 p.m. Okay. Okay. The time is This is the end of Tape 2. also the end of the deposition of It's Superintendent Johnson, and we are going off the record. Johnson. Thank you, Superintendent THE WITNESS: Thank you all. FURTHER DEPONENT SAITH NOT.... 19 20 21 22 23 24 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 104 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION RITA KING, Plaintiff, vs. GLENN EVANS, et al., Defendants. ) ) ) ) ) ) ) ) ) No. 13 C 1937 I, EDDIE T. JOHNSON, being first sworn, on oath, say that I am the deponent the aforesaid deposition, that I have read foregoing transcript of my deposition, consisting of pages 1-104 inclusive, taken the aforesaid time and place and that the foregoing is a true and correct transcript my testimony so given. duly in the at of ____________________________ EDDIE T. JOHNSON SUBSCRIBED AND SWORN TO me before this ________ day of ___________________, A.D. 2017. _________________________ Notary Public 24 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 105 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 STATE OF ILLINOIS ) ) COUNTY OF C O O K ) ss: I, Peggy A. Anderson, a Certified Shorthand Reporter in the State of Illinois do hereby certify: That previous to the commencement of the examination of the witness, the witness was duly sworn to testify the whole truth concerning the matters herein; That the foregoing deposition transcript was reported stenographically by me, was thereafter reduced to typewriting under my personal direction, and constitutes a true record of the testimony given and the proceedings had; That the said deposition was taken before me at the time and place specified; That the said deposition was adjourned as stated herein; That I am not a relative or employee or attorney or counsel, nor a relative or employee of such attorney or counsel for any of the parties hereto, nor interested directly or indirectly in the outcome of this action. TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 Page 106 1 2 3 4 IN WITNESS WHEREOF, I do hereunto set my hand at Chicago, Illinois, this 3rd day of October, 2017. 5 6 7 8 9 10 11 ______________________________________ Peggy A. Anderson Certified Shorthand Reporter License No. 084-003813 12 13 14 15 16 17 18 19 20 21 22 23 24 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 A A.D 104:21 a.m 10:21 11:18,18,20 29:16 ability 56:4 56:22 57:2 102:22 able 25:4 57:5,6 95:7 accompany 31:9 accuracy 90:24 accurate 17:15 47:20 82:12,17 83:5 94:22 95:1 accused 36:23 acknowled... 69:21 acquaintan... 20:4 action 48:9 51:8 55:5 105:24 actions 97:14 active 13:15 13:16 actual 28:21 28:22 46:15 add 8:18 27:13 78:2 addition 32:20 59:7 additional 95:8 address 43:13 Adjacent 23:21 adjourned 105:19 administra... 58:19 admission 68:18 affairs 57:19 101:21 aforesaid 104:11,14 afternoon 6:3 7:8 agency 62:15 aggressive 21:4,8,13 21:14 51:18 52:3 agree 43:22 53:15 59:24 70:21 85:7 86:12 91:10 91:15 94:4 agreed 34:17 98:19 ahead 46:21 69:22 85:5 101:10 ahold 25:4 aide 29:14,21 31:3 aides 29:4,7 29:10,13 al 1:6 104:6 allegation 47:1,24 56:14 65:20 allegations 22:13 41:3 41:6,7 46:22 47:12 48:6,14,21 50:12,14,18 52:8 53:18 53:21 54:15 55:17 57:21 60:6,11 61:19 63:5 63:16 65:1 65:16 66:3 66:17 92:16 93:14 97:7 allow 15:8 34:16 allowed 15:24 30:2 70:10 71:18 Anderson 1:14 5:24 105:3 106:8 answer 36:8 63:13 69:15 78:21 85:11 answered 39:13 51:20 64:5 66:23 68:6,7 80:1 86:5 apparently 42:24 43:12 95:11 96:16 appear 40:12 40:14 appears 40:16 appointment 8:24 appreciate 103:2 appropriate 65:11 72:18 approxima... 12:14,16 13:4,10 29:3 46:24 April 8:22 10:12,15 11:7,15,20 12:6 14:18 16:11 17:14 23:12 24:1 25:24 29:3 29:11,17 30:11,19 31:7 35:5 35:23 37:2 37:8,18,19 38:7 52:20 53:14 57:8 71:8,15 72:2,15 73:7 75:8,8 75:17 76:6 77:14 81:22 86:19 87:8 98:3 100:14 100:16 101:18 area 14:3,6,8 14:9 15:22 17:1,8,9,11 17:13,19 23:13,16,18 23:19 24:2 24:6 28:10 28:18 30:3 33:12 34:15 34:20 51:11 71:18 74:6 77:6 79:3 79:15 80:6 81:19 82:7 areas 73:8 argumenta... 23:6 97:9 arrest 16:20 20:21 27:16 27:18,21 28:5,7 72:22 74:15 74:22 75:7 75:10,15 76:5,17 77:4,16 TOOMEY REPORTING 312-853-0648 Page 1 80:19,23 arrested 27:24 50:2 74:23 arrestee 24:7 24:16,20 25:7,16,21 25:24 26:23 26:24 27:4 27:5 30:5 30:19 31:9 31:13 33:12 34:17,21 35:13 36:1 71:4 72:9 73:9 80:8 84:9 85:15 arrestees 11:11 12:16 13:18 23:14 23:20,23 25:3 30:2 31:23 32:21 35:6 72:10 72:12 78:7 78:23 80:17 81:16 82:3 82:5,6,7 arresting 27:21 28:2 28:12 30:21 31:8,12,17 33:20 75:16 asked 34:12 39:12 43:12 51:19 56:13 64:4 66:22 68:5,7 79:24 86:4 asking 47:4 55:22 82:18 84:9 92:17 92:22,24 93:3,5,7,11 assess 88:19 assumes 48:11 87:15 87:22 98:9 99:21 assuming 84:4,22 87:8 93:16 attach 76:24 attached 26:13 attention 41:11 70:16 86:1 attorney 105:21,22 attorneys 6:1 audiovisual 5:12 August 1:17 5:2 9:4 17:6 18:17 author 75:13 90:23 authored 82:15,16 available 57:9 58:1 70:13 71:16 71:21 73:19 79:21 85:22 Avenue 1:16 2:5 3:12 5:6 5:21 14:16 aware 22:20 37:13 39:10 49:23 62:9 64:17 66:11 68:18 101:13 B B 4:13 B-o-e-n-s EDDIE T. JOHNSON August 21, 2017 47:15 back 10:20 12:6 13:22 17:12 19:1 21:3 22:14 25:24 26:19 28:21,24 29:14,20,24 30:2 31:16 31:18 34:7 34:10,17 44:11 55:17 58:13 61:15 61:16 63:21 63:24 72:9 73:17 79:4 98:1 based 50:18 91:16 98:14 basis 31:10 Bates 45:7 89:15,18 Battle 2:18 2:19 6:7,8 8:8,13 14:22 15:12 16:14 21:7 23:4 26:4 27:12 30:9 30:12 32:2 33:1,22 35:15 39:4 39:12 40:4 44:24 47:4 48:11 49:13 51:19 52:16 54:3,22 55:20 56:20 57:13 62:19 63:10 64:6 65:5 66:22 67:12 68:7 69:14 71:20 73:11 74:20 77:24 78:15 80:2 82:13 83:4,24 85:3 86:4 86:23 87:14 87:20 88:10 90:3,14,22 92:17,24 93:4,8,9,18 97:10 98:11 98:21,24 99:21 102:15 103:8 Bazarek 2:19 6:10,10 61:4,8,12 beat 18:21 becoming 18:6 44:4 beginning 97:24 behalf 2:7,14 2:23 3:8,15 5:9 6:15,16 behavior 52:21,21,23 53:1,6 54:2 54:17 55:8 behavioral 52:13 believe 17:6 18:15 41:16 41:17 42:16 63:20 73:13 90:16 95:6 100:11,24 101:4 best 11:17 12:15 23:22 27:2 36:2 37:11 42:12 better 42:15 42:16 46:21 beyond 36:7 65:4,7,17 31:24 33:17 68:22 82:11 83:3 83:22 84:6 84:23 87:11 blotted 42:11 board 95:20 95:23 96:6 96:8,20,23 100:6,8,20 body 60:24 Boens' 47:14 booked 78:9 booking 31:4 31:20 81:4 booth 24:18 booths 24:15 boundaries 14:12 break 44:23 58:3,11 97:17,22 bring 13:18 25:22 31:13 31:13,15 83:23 84:17 85:1 brought 25:7 25:16 26:10 28:9 30:20 31:1,24 32:21 33:18 37:14,15 41:3 49:12 51:13 55:18 56:6,6,17 57:10 62:1 62:10 66:10 72:21 74:16 76:10 77:5 77:17 79:4 84:8 87:9 95:22 building 10:3 13:21,24 15:10,18 23:13 25:8 25:17,23 bullpen 12:20 12:24 30:6 burglary 50:2 busy 13:19 C C 1:5 2:1 3:1 4:7 5:17 7:6 104:5 105:2 C-a-p-r-o 96:17 call 12:20 21:12 84:11 86:12 called 1:10 7:3 36:18 37:8 53:4 capacity 18:10 Capron 96:17 Caproni 96:18 car 18:21 19:2,6 career 16:24 61:2,5,9 63:19 carrying 26:2 case 5:14,17 5:17 27:22 28:7 43:13 51:5,7 80:24 87:17 87:22 88:14 91:16 case-by-case 31:10 TOOMEY REPORTING 312-853-0648 Page 2 cases 56:15 category 22:3 CCR 51:6 cell 12:23 28:24 30:6 31:6 34:23 35:13,13,24 80:7 cells 12:8,9 12:11,13,17 12:21 28:23 35:1,7 72:3 72:9 81:24 centers 15:16 Central 17:1 17:8,11,14 17:19 51:11 certain 54:11 Certified 1:15 105:3 106:9 certify 36:9 105:5 chain 36:23 channel 36:12,15 38:1,18 40:17 43:19 49:20 51:12 55:16 56:10 57:1 65:20 67:18 charges 56:6 Charise 3:12 6:12 charise.val... 3:14 check 62:14 Chicago 1:16 2:5,9,12,21 3:3,6,9,10 3:13 5:4,6 5:21 6:15 7:12,13 8:19 9:9 36:4 38:14 42:9 52:22 62:18 64:22 64:24 76:16 82:1 91:12 96:8,20 97:2,5 100:6 106:2 chief 9:2 17:1 17:6,7,9,10 17:13,18 41:22 42:3 42:9 43:12 44:1 51:10 64:15,22 101:21 choke 41:9 choked 47:14 circumstance 86:15 circumstan... 54:14 69:12 70:12 citizen 22:15 39:10 64:17 citizens 51:13 52:12 53:10 62:1,9 64:3 city 2:9 3:3,9 6:15 25:21 46:6 citywide 88:4 Civil 1:12 2:9 3:3 civilian 23:3 37:14 40:20 45:18 47:12 claims 57:10 87:10 clarity's 90:14 Clark 2:20 clear 31:17 EDDIE T. JOHNSON August 21, 2017 38:2,12,17 38:22 39:22 42:22 43:6 56:5,16 57:2 clearer 43:11 clearly 69:3 Clifford 2:15 6:17 59:18 84:5 99:13 99:14,15 101:8,17 cold 15:7,18 come 60:2 84:11 command 36:12,15,23 36:24 37:16 38:1,17 40:17 43:19 49:20 51:12 55:16 56:9 57:1 65:20 67:18 commander 9:4,12 10:4 10:7,9,13 13:13 15:8 15:21 16:1 16:4,22 17:21,22 18:3,4,6 25:15 31:22 33:10 36:11 37:1,12 38:3,10,24 39:8 40:18 44:2,4,7 51:16 53:8 54:12,16 64:16,21,24 68:18 69:4 69:7,10,14 69:22 71:15 72:21 78:6 79:17 87:13 88:2,7 102:14,21 commande... 88:5 commanders 88:19 commanding 47:10 48:3 48:8 52:5 52:10 53:23 54:1 56:2,4 57:9 64:14 86:17,18 commence... 105:6 communic... 24:16 communic... 89:3 communic... 94:7 community 14:11 compare 55:22 62:6 complained 49:24 complaining 82:10 complaint 22:12 36:16 38:3 40:20 41:15 43:20 44:7 45:18 47:13 49:21 64:8 92:7 99:7 100:16 complaints 22:16,22 23:3 37:14 39:10 49:1 49:4,12 51:12 53:24 54:18 55:3 62:10,17 64:18 complete 28:3 60:13 completed 28:11 31:20 compliance 70:9,10 98:7 99:18 compound 54:21 100:22 computer 24:5,12,22 28:4 46:8 75:22 computeriz... 38:13 concern 43:16 44:5 53:5 concerning 105:9 concerns 43:14 53:4 55:11 70:4 conclusion 36:20 concur 42:10 51:6 53:16 91:6 concurred 40:24,24 41:17 50:20 concurs 70:6 conduct 62:2 62:18 63:17 64:19 confer 101:21 conference 13:5,9 14:9 confidential 42:23 43:5 43:7,8 confidentia... 46:3 congregate 15:24,24 consider 20:1 21:19 66:12 95:8 considered 53:1,5 consisting 104:13 constitutes 105:13 contact 100:13 101:18 contained 60:16 67:2 continue 68:20 continued 95:4 contraband 26:3 contract 63:20 contractual 102:24 control 98:7 99:19 convenience 76:22 conversation 94:1,4 cooperate 34:8 69:8,9 72:5 cooperated 71:14 88:23 cooperative 70:15 71:12 73:21 79:22 TOOMEY REPORTING 312-853-0648 Page 3 80:13 85:24 98:17 copies 40:3 44:22 75:22 copy 8:7 42:16 44:23 67:20 correct 8:15 17:1,2 29:2 34:18,19 35:3 41:12 41:13 42:10 43:21 44:9 45:19,20 48:4 53:2 59:12,14,16 59:19,20 60:21 61:2 66:17 71:4 71:5 81:1 84:18 89:7 90:17 94:12 94:21 100:17,24 104:15 corrective 55:5 correctly 12:10 correspond... 58:18 counsel 6:2 6:13 8:6 40:1 45:24 46:7 50:3 67:19 87:18 89:16 105:21,22 COUNTY 105:2 court 1:1 5:15,23 11:3,13,13 104:1 Courts 1:13 coverings 43:8 CPD 6:13 CR 22:9,11 22:21 37:9 38:1,3,23 41:15 42:1 57:6,7,20 crap 24:10 37:4 credibility 53:24 crisis 69:3 CRs 37:13,14 38:18 39:13 56:5,17 57:3 61:1 62:1,21 cubicles 24:4 current 7:11 custody 31:3 98:15 cuts 46:3 D D 4:1,7 7:6 D.T 2:15 Dan 14:14,15 database 38:13 date 5:1 76:5 83:9 dated 59:15 day 10:19 12:2 13:14 13:17 95:7 95:16 104:20 106:2 day-to-day 9:13 days 89:9 91:20,21 EDDIE T. JOHNSON August 21, 2017 92:1 100:7 days' 99:6,13 dealing 70:11 71:3 December 17:7 decided 34:7 decision 70:8 70:9 98:6 dedicated 22:5 Defendant 2:24 3:9 6:9 6:11 Defendants 1:7 2:15 6:17 104:7 defense 42:18 define 20:5,6 definition 21:8 delaying 70:14 73:20 79:21 85:23 department 3:10 5:5 7:12,14 8:20 35:12 36:4,19 38:14 42:10 52:7,22 55:12 62:16 64:22 65:1 65:24 70:6 91:12 94:21 95:19 97:3 97:6 100:7 101:24 102:3,6 department's 38:2 76:16 depends 12:2 21:12 deponent 46:9 103:17 104:10 deposition 1:9 5:8,9,11 36:7 58:16 59:5 65:10 65:17 77:1 103:11 104:11,12 105:10,16 105:18 depositions 1:14 deputy 17:1,5 17:7,9,10 17:13,18 41:22 42:2 42:9 43:12 44:1,2 51:10 64:15 64:21 102:8 describe 24:8 24:19 28:16 designed 12:22 52:24 80:7,16 81:15 82:4 desk 14:4 desks 24:15 detail 57:21 details 57:7 87:1 detain 28:15 detainees 69:8 detention 28:22 29:4 29:7,10,12 29:14,21 31:2,6 34:23 35:1 35:6 71:13 80:7,16,18 81:24 82:2 determinat... 91:11 determine 40:23 42:7 62:16 64:1 determined 70:6 device 5:12 26:14 differ 53:3 differences 94:18 95:6 95:14,15 different 12:3 19:1 71:10 88:14 differentiat... 73:13 difficult 43:1 46:1 85:11 dimensions 13:1 24:8 DIRECT 4:4 directed 47:18 direction 105:13 directly 105:23 director 58:19 96:8 96:19 disabled 72:23 disagreed 66:5 disciplinary 53:6 60:1 61:19 68:14 89:6 discipline 48:9,12 92:18 94:5 100:19 101:17 disciplined 66:7 92:15 93:12 98:20 98:22,23 100:7 101:4 101:8 discovery 76:15 discuss 60:2 discussed 56:12 discussions 95:4,9,10 district 1:1,1 1:13 5:15 5:16 9:5,7 9:11,12,14 9:17,20,23 10:8,11,14 11:1,12 12:6,18 13:13,16,17 13:21 14:3 14:10,17,18 15:7,10,21 15:23 16:8 16:22 17:17 17:23 18:4 18:7,13,19 18:19,22 20:3,14,20 21:3,6,19 23:12,24 25:8,15,17 27:3 28:17 29:5,11 31:23 32:1 32:21 33:11 35:2,19,21 35:24 36:11 36:24 37:13 38:24 39:9 40:17,18 TOOMEY REPORTING 312-853-0648 Page 4 44:3 51:17 53:9 64:15 71:17 72:2 72:7,11,20 72:24 73:7 73:8 74:2,6 74:7,10,13 74:17 77:19 78:6 80:12 80:15 81:12 81:15,18,22 81:23 86:18 86:22 88:8 98:4 102:13 102:17,22 104:1,1 districts 17:18 disturbance 27:23 Division 1:2 2:10 3:4 5:16 104:2 Dixon 6:18 document 7:21,22 8:1 8:2,5 39:23 39:24 43:4 43:15 44:19 44:20 45:5 45:24 46:15 46:19 47:5 49:18 67:17 67:21 68:2 68:9 75:12 75:13,21 76:8,12,14 77:8 90:23 91:23,24 92:3 96:3 documented 100:2 documents 58:16,17 59:8 68:3 dog 47:14 50:10 doing 57:1 76:21 domestic 27:22 door 28:20 double 79:8 drugs 32:22 33:18 68:19 drunk 68:19 due 72:22 duly 6:23 7:4 104:9 105:8 duties 15:20 18:2 duty 10:11 E E 2:1,1 3:1,1 4:1,7,7,7,13 6:10 7:6,6 early 10:24 easier 46:8 East 74:8 Eastern 1:2 5:16 104:2 Eddie 1:10 3:15 4:3 7:2 7:10 104:9 104:18 effort 53:1 either 36:17 38:4 43:22 64:21 72:19 72:23 84:10 elapsed 69:10 employee 105:20,22 empty 11:22 encompass 14:10 enforce 21:23 EDDIE T. JOHNSON August 21, 2017 enforced 21:22 Englewood 14:11,12,13 entered 14:2 50:8 entire 17:24 63:19 entitled 5:18 entries 28:4 entryway 15:9 equipment 24:22 25:2 et 1:6 104:6 Evans 1:6 2:15,24 5:18 6:9,11 9:16 10:4,7 16:6 17:21 18:3,8,11 18:22 19:8 19:14,16,19 20:2,16,23 21:3 22:2 22:20,21 37:15 38:23 39:9,11 41:4,8 42:2 42:6 43:23 44:7,8 47:2 47:13 48:5 48:9 49:24 51:13,17 55:14,18 56:14,17 59:18,23 60:7,12,15 60:20,24 62:11 63:5 64:1 65:2 65:21,23 66:2,7,10 66:12,21 67:5,15 68:1,18 69:7 70:13 71:2,7 72:4 73:19 75:2 79:17,17,20 79:23 83:23 84:5,17 85:1,22 89:13 90:20 91:7,11 92:15 93:12 94:8,20 97:2,5 98:20 99:18 100:17 101:16,23 102:10,13 104:6 Evans' 23:2 47:10 62:2 62:18 63:17 64:14,18 69:4,10 70:7,22 82:10 95:23 98:6 100:13 evening 95:9 event 86:10 eventually 44:6 evidence 70:5 86:13 87:16 87:22 93:17 98:9 99:22 evidentiary 70:4 examination 1:11 4:4 105:7 examined 7:4 examples 56:11 excessive 39:11 52:12 53:9,18,22 54:15 55:3 57:10 64:2 65:2 92:12 97:6 exchange 27:8 executive 96:7,19 exhausted 101:5 exhibit 4:16 4:17,18,19 4:20,21,22 7:16,21 39:17,21 40:9,11,15 41:19 44:14 44:18 45:3 45:16,23 46:20 47:23 49:7,11,14 58:21 59:1 59:2,4,7,10 60:20 67:5 67:10,11 68:10 70:3 75:2,7 77:3 83:17 89:10 90:8 94:6 96:15 exigent 69:6 existence 37:3 experience 13:12 expiration 92:12 Explain 79:22 Expressway 14:15 extend 34:9 extent 16:15 90:20 91:21 39:13 54:3 94:1,7,11 62:20 69:12 94:14,19 69:16 71:20 96:7,17 82:13 83:5 Fairley's 85:4 90:22 68:12 69:17 93:5 70:1,19 extra 8:7 82:24 90:5 extremely 91:10 96:12 15:7 fairly 14:7,7 familiar F 36:12 F 4:7 far 42:7 79:3 faay 11:19 86:20 facilities fault 49:3 71:16,21 favor 97:1 82:2,7 FCL 45:7 facility 28:15 FCRL 45:8 28:16 70:17 89:22 90:8 71:13 80:11 90:15 81:20 83:23 February 84:12,18 17:9,14 86:2 88:22 51:3 fact 22:21 Federal 1:11 72:22 2:9 3:3 factors 88:18 feet 24:13 facts 87:16 fell 22:3 87:22 88:14 fellow 20:15 91:16 93:16 felt 53:23 98:9 99:21 101:3 failed 41:11 female 72:8 99:10,16 72:12,21 fair 14:19 73:12 80:8 21:21,24 80:16,16 64:19 77:18 81:16 82:5 Fairley 58:18 82:6 87:9 59:12 60:5 females 81:23 60:19,23 fence 47:16 61:23 68:4 file 60:10,13 68:24 69:2 63:23 66:16 69:18 70:21 66:18 73:18 82:8 filed 45:21 82:16 83:1 62:1,17 84:14 89:3 64:18 TOOMEY REPORTING 312-853-0648 Page 5 files 38:23 filled 75:16 filling 80:23 find 28:22 49:3 101:15 finding 38:4 42:6 43:23 50:21 56:13 66:1,2 findings 50:23 51:7 66:4 fine 45:1 fingerprint 86:14 fingerprinted 33:13,19 34:8,13,18 34:22 71:19 72:15 73:24 79:3,6,16 80:14 81:3 81:10,17 85:15 86:12 86:21 87:12 101:6 fingerprint... 31:5 72:6 73:1,10 fingerprints 70:17 86:2 finished 13:24 first 6:2,23 7:3 23:17 40:16 47:22 51:5 91:24 104:9 five 63:21,24 76:1,21,23 92:9,10,13 92:20 93:13 99:6,13 five-minute EDDIE T. JOHNSON August 21, 2017 97:17 five-year 63:18 five-year-lo... 63:6 flag 52:24 53:8 floor 23:17 fluctuated 10:1 13:19 flush 73:14 focus 16:5 follow-up 93:24 103:7 followed 30:7 follows 7:5 FOP 63:20 force 39:11 52:12 53:10 53:19,22 54:15 55:3 57:10 64:2 65:2,22 69:4,11,13 70:22 90:21 91:8 92:12 97:6 foregoing 104:12,15 105:10 form 11:4,23 16:16 20:17 23:4 26:15 27:10 29:6 32:6,24 33:23 38:5 39:1 48:17 51:20 52:15 53:11 54:6 54:20 55:19 57:12 63:8 64:5 65:3 73:2,12 74:18 75:19 76:11 77:20 78:13 79:7 81:13 82:14 84:19 85:16 88:13 93:16 96:9 97:8 98:8 100:9 100:21 102:18 forwarded 51:7 forwards 66:19 found 52:10 foundation 11:24 15:1 15:11 16:16 23:5 27:11 32:5,24 33:23 39:2 48:17 51:20 53:12 54:6 62:19 63:9 65:4 69:16 75:18 76:12 77:21 82:14 85:9 86:24 93:16 101:10 Franko 67:16 friend 20:1 friends 20:5,6 front 15:22 92:3 function 19:14 further 44:22 76:8 103:17 G G 2:3,4 Garrett 3:5 6:14,14 8:11 11:4 11:23 14:21 14:24 20:17 21:10 23:7 26:6,15 27:6,10 29:6 30:15 32:5,23 34:1 35:18 36:6 37:17 38:5 39:1 40:1 42:13 42:21 43:6 45:4,11,24 46:14 48:16 50:3 51:22 52:15 53:11 54:5,20 55:19 56:18 57:12 58:2 58:6 62:22 63:8 64:4 65:3,13 66:24 67:19 68:5 73:2 74:18 75:11 75:18,21 76:11,18 77:7,20 78:10,13,18 79:7,24 81:13 82:20 83:8 84:19 85:6,9,16 86:6 87:3 87:23 88:12 91:1 93:15 96:9 97:8 98:8 99:23 100:9,21 101:11 102:18 103:4 geared 24:1 general 6:13 25:20 30:1 35:19 78:22 84:7 88:3 generally 30:7 generate 28:19 getting 25:13 give 13:1 22:8 64:9 70:4 87:5 97:4 given 29:23 60:8,10,14 67:3 69:2 69:11 70:12 88:8,9,18 97:6 104:16 105:14 Glenn 1:6 2:15,24 6:9 6:11 9:16 10:4,6 16:5 17:21 18:8 18:11,22 19:8,14,16 19:19,19 20:2,9,16 20:23 22:2 22:5,20,21 23:2 37:15 38:23 39:9 39:11 41:4 41:8 42:2,6 43:23 44:8 47:2,13 48:5,9 49:24 51:13 51:17 55:14 56:14,17 59:18 60:7 60:11,15,19 60:24 62:2 62:10,17 TOOMEY REPORTING 312-853-0648 Page 6 63:5,16 64:1,14,18 65:2,21,23 66:2,6,10 66:12,21 67:15 68:1 70:22 71:2 71:7 79:23 84:16 85:1 89:13 90:20 91:7,11 92:15 93:12 94:8,20 95:23 97:1 97:5 98:6 98:20 99:18 100:13,17 101:23 102:10,12 104:6 go 10:21 19:15,18 28:20 42:2 46:21 52:13 55:17 57:21 63:20,24 69:22 85:5 95:19 96:6 101:10 goes 69:2 95:3 going 5:2 7:19 8:9 16:14 20:7 29:23 42:15 42:18 44:17 46:14 49:10 58:2,8 67:9 77:8 93:15 97:16,20 100:5,8,19 103:12 good 6:3 7:8 20:20 21:14 21:15,20 22:3,5 52:3 66:13 governed 25:19 88:3 grabbed 47:16 Gray 2:16 great 82:6 ground 47:18 group 9:19 45:23 59:1 83:17 96:15 guess 9:24 11:17 13:2 13:3 32:17 42:13 guidelines 88:4 gun 49:24 H H 4:13 hair 47:17 50:1 Halsted 9:9 10:3 hand 106:2 handcuff 26:19 handcuffed 24:24 25:9 26:12 handcuffs 25:12 26:13 hang 20:11 hanging 20:6 happen 32:18 happened 30:23 33:16 62:6 hard 24:19 Harris 2:11 6:16,16 8:6 EDDIE T. JOHNSON August 21, 2017 15:13 21:9 23:8 27:13 30:14 32:4 32:7 33:2 34:3 39:5 48:15 51:23 53:15 54:8 54:23 57:14 65:6 75:20 76:13 77:11 78:1,17 79:10 80:3 82:21 83:12 85:7 86:7 87:6,24 88:15 89:15 89:18,22 90:7,16 91:2 93:19 98:12 99:24 101:9 headquarters 5:5 hear 84:1 99:1 hearing 65:9 hearings 11:13 held 12:17 17:6 79:5 80:13,19 81:11 hereto 105:23 hereunto 106:1 HICKEY 2:18 high 32:22 33:17 68:19 72:23 highly 85:18 history 61:20 64:2 97:6 hold 12:20 28:15 41:10 72:24 81:16 holding 12:8 12:11,13,17 12:23 28:24 30:6 35:13 72:3,9 81:19 88:22 home 10:22 homeless 14:19 15:3 15:9,16,17 15:23 16:9 83:23 84:8 84:11 85:1 85:15 86:11 hours 10:16 10:18,24 11:10 29:16 47:1 78:8 house 82:3 housed 28:21 82:7 houses 20:7 huge 14:9 hypothetical 30:13 32:3 33:23 52:16 54:4,21 78:16 85:5 86:24 87:15 87:21 88:9 88:11 I idea 44:5 identification 7:17 27:9 39:18 44:15 49:8 58:22 67:7,10 75:4 identify 44:24 45:5 identity 27:4 II 68:14 Illinois 1:1,16 1:17 2:5,12 2:21 3:6,13 5:6,16,22 104:1 105:1 105:4 106:2 immediately 81:18 99:17 implement... 51:8 inaccurate 8:5 inappropri... 72:8 incident 49:16 62:5 62:7 64:8 66:8,9 82:5 88:20 97:12 99:11,16,17 incidents 26:17 include 55:7 55:10,11 included 31:5 inclusive 104:13 incomplete 30:13 32:2 33:22 52:16 54:4 78:16 85:4 86:23 87:15,21 88:11 102:15 increased 91:20,21 indicates 61:18 indicating 35:9 76:5 77:13 indirectly 105:24 individual 2:14 12:21 31:5 information 8:4 38:15 38:16,17 56:16 57:8 informed 84:4 initial 91:24 initially 42:5 69:8 inside 15:17 24:5 28:15 inspect 15:22 instance 5:11 instances 52:11 54:11 instituted 5:14 interested 105:23 internal 57:19 101:21 interpret 93:1,5 intervening 95:5 intervention 52:14,21,23 53:7 54:2 54:17 55:8 interview 48:5 introduce 6:1 investigated 36:17,20 investigating 36:21 41:1 50:20 TOOMEY REPORTING 312-853-0648 Page 7 104:9,18 investigation 36:21 41:20 join 15:12,13 21:9,10 42:19 48:24 23:7,8 26:6 49:4 60:9 27:12,13 63:1,1 30:14,15 64:10 32:4,7 33:1 investigator 34:1,3 39:4 60:15 66:19 39:5 48:15 investigato... 48:16 51:22 41:18 60:8 51:23 53:16 60:17 54:5,8,22 IPRA 16:6 54:23 55:20 37:2,5,8 56:20 57:13 38:4 42:5 57:14 62:22 43:22 45:21 64:6 65:5,6 48:6 49:1 66:24 74:20 50:21 51:5 75:20 76:13 53:21 54:19 77:11,24 55:15 56:13 78:1,15,17 58:19 59:22 79:10 80:2 59:24 60:5 80:3 82:20 60:10,15,17 82:21 83:8 62:15 63:1 83:12 85:6 63:4,12,23 86:6,7 87:3 64:9 66:4 87:6,23,24 66:16,18,21 88:12,15 92:1,5 91:1,2 93:14 94:19 93:18,19 IPRA's 49:3 97:10 98:11 92:18 93:1 98:12 99:23 93:6 99:24 issue 25:10 101:11 102:24 Jones 49:12 issues 68:20 49:21,23 J 50:2 job 21:23 Jones' 50:8 Johnson 1:10 50:10 3:15 4:3,16 judge 34:12 4:17,18,19 65:8 4:20,21,22 justification 5:8 7:2,10 47:14 50:1 46:18 69:20 K 103:12,14 EDDIE T. JOHNSON August 21, 2017 K 3:12 105:2 K.L 2:16 kbattle@h... 2:22 keep 35:12 35:24 38:2 keeper 25:14 28:14 29:13 29:18,20 31:2 33:21 Kenneth 2:19 6:8 Keyshia 45:19 kicked 47:19 kind 24:18,19 King 1:3 5:18 16:7,13,21 45:7 60:6 66:9 68:19 69:3,6 70:7 70:15,22 71:17 72:4 72:14 73:21 74:12 75:8 75:17 76:10 77:5,18 79:2,15,22 80:12,19 82:9 83:20 84:4,15,17 84:22 85:24 93:14 98:4 99:19 100:14 101:18 104:3 King's 60:11 65:19 66:3 66:16 76:17 92:7,16 99:7 100:16 knew 20:9 know 12:2 letter 59:11 59:13,21 60:4 68:12 68:24 69:17 69:19 70:1 70:5,19 73:17 79:19 82:8,15,15 82:24 83:15 84:14 85:21 89:17,19,20 90:2,3,6 91:6,18 94:1 96:5,7 96:16 letters 43:9 60:24 level 97:15 levels 51:6 License 106:10 lieutenant 9:16 37:16 47:2,9 55:18 64:24 70:7,13 72:4 73:19 L 79:17,20 Lapitan 2:16 83:22 84:5 large 12:23 85:22 102:6 12:23 14:6 102:13,23 14:7,7 lieutenants 28:24 9:22 LaSalle 2:11 line 4:8 68:20 3:5 list 57:20 LAW 2:2,8 litany 22:13 2:17 3:2,10 Liticorp 5:20 laws 21:22 LITIGATI... lawyers 42:18 2:10 3:4 leadership little 13:6 9:19 24:10,10,11 legal 5:20 Lloyd 2:16 let's 17:5 LLP 2:18 29:17 located 9:7,8 13:2 20:5 21:6,13 22:7,9 27:17 29:12 34:11 39:2 41:22 64:23 74:12 75:19 78:4,18 82:17 83:5 90:24 96:22 98:14 knowledge 12:15 14:20 16:10,12,18 22:24 32:17 33:12 35:11 36:2,3 37:11,24 66:6 77:9 77:22 92:6 93:11 101:7 101:23 102:1 known 21:4 27:5 knows 83:6 23:16 74:5 locked 11:2 lockup 11:2 11:11,13,21 12:7,9,18 13:14 23:18 25:14 28:14 28:15,16,21 29:1,5,13 29:18,20 30:2,8,20 30:23 31:1 31:1,9,14 31:19 33:12 33:18,21 34:15,20 35:14 72:3 73:23 74:1 74:24 76:10 77:5,13,17 78:12 79:3 79:15 83:21 86:20 87:9 98:3,5 lockups 12:5 log 69:15 logged 39:21 45:6 long 14:8 24:13 longer 24:11 63:7 look 7:24 8:1 17:12 39:23 40:8 41:2 41:19 43:4 43:24 45:22 46:20 47:22 49:17 55:2 55:17 57:2 57:24 58:16 59:4,8 60:5 61:24 63:18 63:19 68:12 TOOMEY REPORTING 312-853-0648 Page 8 mean 12:19 20:4 37:14 51:6 73:22 86:3 91:21 means 39:3 45:4 101:5 medical 41:11 70:16 70:17 84:18 86:1,2 medicated 85:2 medication M 68:22 82:11 M 7:6 83:3,21 main 12:7 84:1,6,24 maintain 87:11 36:5 medications maintained 84:10 35:4 38:16 meet 60:1 38:19 94:14,15 making 27:18 member male 72:10 36:19 100:6 73:12 82:5 members manner 30:1 81:16 memory March 9:3 12:10 38:21 18:7,10 96:2 mark 46:3 68:20 marked 4:15 7:16,20 31:24 72:23 39:17,20 mention 43:5,7 60:23 84:14 44:14,18 mentioned 49:7,10 25:5 26:11 58:21,24 34:15 66:15 67:6,10 71:1 75:3 merit 88:20 matter 95:22 merits 62:6 matters 63:2 64:11 105:9 97:13 Max 96:17 met 94:10 maximum Michigan 100:18 1:16 3:12 70:3 73:17 76:8 82:24 91:18 94:6 96:15 looked 38:22 51:4 58:17 looking 46:22 89:11,13 90:2,5,7,10 looks 8:3,15 51:3 lot 40:2,6 EDDIE T. JOHNSON August 21, 2017 5:6 Milo 3:18 5:19 Milwaukee 5:21 mind 44:10 65:9,15 75:23 minutes 76:2 76:21,23 mischaract... 16:15 26:5 misconduct 62:11 moment 8:1 39:23 43:4 49:18 59:11 months 15:6 morning 10:24 11:10 11:20 29:16 Morrissey 2:3,4,4 4:4 6:3,4,5,6 7:7,18 8:16 11:6 12:4 15:5,19 16:19 21:1 21:17 23:11 26:9,21 27:7,19 29:8 30:10 30:18 32:11 32:19 33:9 34:14 35:17 35:20,22 36:9,10 37:19,23 38:7,11 39:7,19,24 40:2,6,7 42:14,24 43:3,17 44:16,21 45:2,6,9,14 46:5,10,17 47:8 48:13 48:20 49:9 49:14,15 50:6,7 52:4 52:18 53:14 53:20 54:13 55:6 56:1 56:23 57:15 58:4,14,23 61:14,21 63:3,14 64:13 65:7 65:18 67:8 67:13,14,21 67:23 68:11 69:23 71:23 72:1 73:4,6 73:15,16 74:11 75:5 75:14 76:1 76:7,14,20 77:2,15 78:5,11,20 79:11 80:9 81:21 82:23 83:10,14 84:3,21 85:13,20 86:16 87:4 87:7 88:6 89:1,12,17 89:20,24 90:1,4,10 90:17,18 91:5 92:19 92:22 93:2 93:7,10,23 96:14 97:16 98:2,18,23 99:4 100:4 100:12 101:1,14 102:17,20 103:1 5:21 Northern 1:1 5:15 104:1 N Notary N 2:1 3:1,5 104:22 4:1,7 7:6,6 notebook n-i 96:19 42:19 46:19 name 5:19 November 6:4,5,8 7:9 67:16 7:23 9:16 number 5:17 16:12 40:12 7:21 14:19 40:14 47:15 39:21 40:9 names 35:5 44:18 49:11 narrative 59:1,4 46:4 61:24 67:11 narratives 68:10 77:3 55:3,4 89:16,23 nature 33:7 Numeral necessary 68:14 70:12 numerous need 36:8 22:21 23:3 45:10 69:6 O 73:14 99:19 needed 68:21 O 4:7 7:6 105:2,2 82:11 83:3 o'clock 10:22 84:6,23 O'CONNOR 101:3 2:18 needs 87:10 negative 79:8 oath 104:10 object 16:14 never 19:3 65:23 75:23 61:4 85:3 93:4,15 new 13:22 objecting night 10:23 61:8 15:18 noncombat... objection 11:4,23 87:10 98:5 14:21,22,23 noon 29:17 14:24 15:11 normal 10:13 10:16,18 20:17 21:7 23:4 26:4,6 28:8 31:7 26:15 27:6 normally 27:10 29:6 28:2,6 31:8 North 2:11 30:9,12 2:20 3:5 32:2,5,23 TOOMEY REPORTING 312-853-0648 Page 9 33:22 36:6 38:5 39:1 39:12 48:16 51:19 52:15 53:11 54:3 54:6,20 55:19 56:18 57:12 61:13 62:19,22 63:8 64:4 65:3 66:22 66:24 68:5 69:16 71:20 73:2,11 74:18 75:11 75:18 76:11 76:19 77:20 78:10,13 79:7,24 81:13 82:13 82:20,22 83:4,8 84:19 85:6 85:16 86:4 86:6,23 87:3,14,21 87:23,24 88:10,12 90:22 91:1 93:20 96:9 97:8 98:8 99:21,23 100:9,21 101:9,11 102:15,18 objections 33:2 53:16 54:9 77:7 83:13 88:16 observe 99:10 observed 99:16 obtaining 70:16 86:1 occasion 19:5 27:17 occasions 34:11 occurred 33:8 99:10 October 106:3 offender 24:23 Office 3:11 22:16 officer 19:7 19:12 21:2 21:5,18,20 22:2,4,6,13 22:14,19,22 23:1 24:16 24:17,21 25:1 27:16 27:21 28:12 28:12 30:21 31:2 33:20 36:17 38:18 47:10 48:3 48:8 51:18 52:3,5,7,10 52:11 53:8 53:22,23 54:1,1,16 54:16 56:2 56:4 57:4,9 59:17,18 62:3,12,18 63:17 64:14 64:23 66:13 75:17 84:4 86:17,18 99:5,6,9,12 99:14,15 officers 13:17 20:15 21:4 21:5,13,14 EDDIE T. JOHNSON August 21, 2017 21:15 24:6 25:11 28:3 29:4,7 31:8 31:12 56:7 57:11 59:23 60:7,12 65:16 OFFICES 2:2,8,17 3:2 3:10 officially 8:22 Oh 8:13 24:10 37:4 46:12 83:19 okay 8:11,13 11:8 30:22 32:9 45:13 49:19 58:7 59:3 61:3 68:16 90:13 91:9 93:4,9 97:18 103:6 103:9 old 13:23 14:1 once 30:24 81:16 ones 51:14 operations 9:13 10:10 opinion 22:1 94:18 97:13 97:14 98:16 opportunity 40:8 45:15 OPS 22:18 36:18 37:8 38:4 54:18 56:13 62:15 OPS' 43:23 opted 80:5 option 34:16 79:17 83:22 84:20 88:21 options 33:20 34:6,13 70:13 71:2 71:7 73:19 79:2,20 84:13,16,24 85:22 order 34:12 84:7 95:18 orders 25:20 88:3 organization 22:15 organizatio... 37:10 original 75:24 other's 20:7 OTS 51:5 outcome 105:24 99:8,9 pages 104:13 pain 70:8,9 98:6 99:18 paperwork 24:7 28:3 28:11,19 Paragraph 68:15 paramedics 84:11 Pardon 89:14 part 15:20 18:2 38:16 41:7 42:17 49:20 65:20 66:15 67:18 80:22 81:2 81:4,6 96:5 participate 16:20 43:18 participated P 43:19 P 2:1,1 3:1,1 particular p.m 1:17 5:3 26:17 43:15 58:8,12 66:8 68:2 97:19,23 parties 103:10 105:23 packet 40:23 partner 19:4 page 4:2,8,15 partners 40:11,14 18:24 41:2,5,19 party 5:9,10 42:20,20 19:15,19,23 45:22 46:20 20:10 47:22 50:4 passive 70:11 50:6 51:5 Patrick 2:4 59:2,11 6:5 67:21 60:20 68:13 patrickmor... 70:3 73:18 2:6 77:3 83:16 patrol 9:2 83:17,18 19:7,12 89:19,20 20:15 21:2 90:8,11,11 21:4,18 94:6 96:15 22:2,14,19 22:22 23:1 53:22 54:1 56:7 patrolman 18:12 20:2 patrolmen 18:19 20:12 20:14 Peggy 1:14 5:23 32:11 105:3 106:8 penalty 91:19 pending 72:15 73:1 73:10 people 12:21 12:22 14:19 15:3,16,17 15:23 19:1 75:23 period 9:3,11 9:15,23 11:1,10 17:4,22 18:1 36:5 63:7,18 95:5 periodically 15:22 permanent 26:14 person 23:2 26:2 27:24 28:4,9,13 28:14 30:24 31:3 34:7 34:12,24 36:21 40:16 47:15 50:20 50:22 55:8 69:3 86:14 86:20 person's 36:23 41:1 TOOMEY REPORTING 312-853-0648 Page 10 49:4 personal 16:10,12,18 32:16 33:5 33:14 77:9 77:21 105:13 personally 62:5 64:17 64:23 personnel 9:14 10:10 31:19 53:4 53:5 55:11 pertaining 1:13 photograp... 81:7,17 photograp... 73:10 place 37:8 80:11 87:13 104:14 105:17 placed 34:22 35:14 36:1 41:9 72:4 placing 30:5 Plaintiff 1:4 1:10 2:7 5:10,13 104:4 Plaintiff's 6:2 7:15,20 39:16,21 44:13,18 45:3 46:6 49:6,11 58:20 59:1 90:8 please 6:20 point 11:9 16:24 79:14 86:12 pointed 49:24 police 3:10 5:5 7:12,13 8:19 9:14 15:15 21:5 21:5 22:12 35:12 36:4 36:17 38:1 38:14,18 42:10 51:18 52:6,11,22 53:8 55:12 57:4 62:2 62:11,16,18 63:17,22 64:22,24 65:22,24 66:13 76:16 90:21 91:8 91:12 94:21 95:19,20,22 96:6,8,20 96:23 97:2 97:5 100:5 100:6,8,19 101:24 102:3,6,9 policies 93:1 policy 25:6,6 88:2,5 93:6 Porter-Boen 47:18,19,19 Porter-Boens 47:15,16,17 Porter-Boe... 49:1 portion 69:24 position 7:11 9:1 17:3,7 positions 26:22 possible 26:24 EDDIE T. JOHNSON August 21, 2017 possibly 55:10 preliminary 22:8 29:9 52:19 prepare 8:2 27:21 prepared 28:8 preparing 68:4 present 3:17 5:4 10:2 16:7 presented 45:21 46:6 91:17 presenting 46:19 previous 105:6 print 76:2,23 printed 34:24 43:8 46:2 prints 70:14 73:20 79:21 85:23 prior 8:24 16:11 18:6 18:10 27:8 27:17 30:5 37:19 38:7 44:4 56:16 57:3,10 58:15 59:5 60:18 62:21 79:15 100:5 100:19 prisoner 33:17 72:24 prisoners 11:2 probably 9:24 11:17 13:6 14:8 18:13,18 19:24 24:10 42:17 51:15 101:20 problem 40:4 problematic 53:1 procedure 1:12 25:6 28:9 86:21 96:6 procedures 31:7 87:12 88:8 proceed 6:21 proceedings 105:15 process 23:14 23:19,23 30:7 31:4 31:20 37:7 72:6 81:4,6 81:9 processed 26:23 28:10 69:6,9 80:20,21 81:23 processing 16:21 24:2 24:5,9 26:11,23 27:20 28:18 72:13 77:19 78:8,24 79:5 80:23 81:2 profanities 47:18 professional 22:16 97:14 program 52:14,21,23 52:24 54:2 54:17 55:8 55:11 promoted 17:5 promotion 102:10 properly 99:11 protocol 96:13 provide 41:11 prudent 70:12 public 14:2 21:21 30:1 104:22 pull 46:7,15 56:5,15 pulled 50:1 punched 41:8 47:19 purpose 5:7 purposes 67:10 pursuant 1:11 pushed 41:10 put 34:23,24 57:23 72:8 88:18 putting 31:6 Q quarterly 52:6 57:18 question 11:8 22:8 29:9 30:17 32:10 32:12 36:8 39:3 46:11 46:13 52:19 57:16 61:13 63:12 65:12 65:14,14 69:15 71:24 73:5 76:3 79:9,12 84:2 87:2 91:9 98:9 99:12 questions 23:24 103:7 103:8 queue 56:9 quite 12:20 24:11 37:4,5,22 39:15 51:14 94:3 95:24 96:24 receive 52:6 59:21 received 60:4 77:13 89:2 91:24 101:17 receiving 48:6 102:2 102:5 recollection 23:22 27:2 R 33:6,15 R 2:1 3:1 4:7 recommend 7:6 52:13 99:6 R.A 2:15 99:13 raised 43:14 102:10 ran 20:10 recommen... read 32:14 36:22 41:1 46:1,9,16 41:14,17,18 61:15,15,16 50:17,19 70:1 104:11 59:22 60:1 reading 89:7 90:19 43:11 50:4 92:1,6 69:21 recommen... reads 90:24 60:9 64:10 ready 25:13 66:5 68:14 73:24 91:16 really 10:18 recommen... 13:2,18 91:4 100:18 19:3 24:2 record 5:3 25:3 37:5 7:9 32:13 46:1 38:2 42:21 reason 92:14 43:6 45:1 93:12 98:19 58:9,13 reasons 46:2 61:14 76:16 72:19 97:4 83:6 97:20 recall 16:23 98:1 103:13 18:23 19:3 105:14 19:6,13,22 recorded 20:11,19 5:12 TOOMEY REPORTING 312-853-0648 Page 11 records 35:4 35:12,24 36:5 38:22 redacted 42:17,22 reduced 105:12 refer 54:1,16 reference 50:5 referrals 55:16 referring 55:7 reflect 41:2 46:23 74:15 74:22 75:9 76:9,9 reflects 41:5 47:5 refresh 96:1 refreshed 38:21 refuses 87:11 regards 22:24 23:1 35:5 35:24 37:9 38:17,22 39:11 40:20 41:15 43:20 48:10 49:1 49:16 55:14 56:14,16 59:17,22,22 60:11,19 62:2,11,17 63:16 64:18 65:10 66:2 66:10,16 84:17 92:7 92:16 94:8 99:7,12 100:13,15 101:17 EDDIE T. JOHNSON August 21, 2017 regular 19:4 related 87:1 relation 23:18 relative 105:20,21 relatively 11:21 13:22 relevance 14:22,24 15:11 remain 15:9 25:9 remember 20:23 removed 11:12 71:17 79:18 renew 30:12 repeat 11:8 30:17 32:9 32:12 38:10 46:12 52:11 61:12 79:13 87:19 repeated 54:15 rephrase 71:23 73:4 97:3 report 27:21 27:22 28:7 28:8 41:20 42:19 57:18 74:15,22 75:7,16 77:4 80:20 80:23,24 99:11,17,20 reported 105:11 reporter 1:15 5:23 6:19 61:6,10 87:18 105:4 106:9 Reporting 5:24 reports 52:6 represent 6:8 represented 94:19 reputation 21:6 23:2,5 51:17,21 52:2 request 43:24 44:4 requested 32:14 requesting 83:20 84:1 requires 84:7 reserve 103:4 resister 70:11 resolution 60:3 resolve 94:17 95:13,15 resolved 95:6 respectful 21:24 responded 60:19 61:23 responding 60:18 response 68:4 70:24 71:1 responses 70:18 responsibili... 9:10 10:6 40:19 responsibili... 16:4 40:22 40:22 responsible 9:13 10:10 restrained 26:24 72:14 73:9 resume 7:23 8:18 17:12 retirement 19:15,18,23 20:10 return 42:5 returned 43:13 review 36:13 36:15 38:1 38:18 40:17 40:23 43:19 45:10,15 47:23 48:24 49:21 50:18 51:2,11,12 55:16 56:8 56:10,13 57:1 62:20 62:24 64:11 65:21 66:20 67:18,24 68:3 93:14 101:22 reviewed 22:15 37:9 38:3,24 42:1 55:15 63:23 64:9 65:19 66:15 66:18 68:9 reviewing 60:6 Richard 49:12,21,23 50:2,8,10 right 23:21 43:11 51:4 58:3 61:3 73:15 RIGHTS 2:9 3:3 ring 26:13 27:1 rings 26:19 72:14,17 rise 97:14 Rita 1:3 16:7 16:13 66:9 66:16 67:16 70:22 75:7 75:17 76:16 83:20 92:7 92:16 93:14 98:4 99:7 100:14,15 101:18 104:3 Rodgers 2:16 6:17 Roman 68:14 room 13:5,9 14:9 24:5,9 24:11 26:11 26:23 27:20 72:13 77:19 78:8,24 79:5 rooms 23:23 24:3 rosters 35:8 rotation 10:13 roughly 14:16 18:20 routinely 15:17 Rules 1:12 Ryan 14:14 14:15 S S 2:1 3:1 4:7 4:7,13 S-k-a-h-i-l-l TOOMEY REPORTING 312-853-0648 Page 12 41:23 safety 25:10 SAITH 103:17 sake 90:14 salary 102:2 102:5 Samuel 47:13 sat 80:7 Savich 3:18 5:19 saying 61:5 68:17 71:21 says 51:5 68:21 69:21 77:8 82:19 82:19 83:7 95:3 scope 36:7 65:4,8,17 screaming 68:21 83:2 screen 75:22 search 25:21 searched 25:18 26:1 50:8 seat 71:13 second 68:13 see 15:3 17:5 25:1 26:1 43:2 57:2,5 57:6 60:2 68:23 69:13 69:24 83:15 94:17 seeking 70:15 85:24 seen 34:11 send 36:22 separated 65:24 90:21 91:7,12,22 separation 91:4 September 18:16 45:22 46:23,24 sergeant 14:4 18:15,17 served 17:8 serves 12:10 set 72:11 106:1 setup 24:18 seven 10:1 share 8:12 Sharon 58:18 82:16 shift 19:9 shifts 29:19 shoot 50:10 short 8:10 58:10 97:21 Shorthand 1:15 105:4 106:9 shot 47:13 show 7:19,20 42:15,18 44:17 49:10 67:9 77:4,4 showing 39:20 58:24 75:6,6 77:3 sic 47:18 67:16 70:5 83:1,10 96:17 side 9:8 14:14 24:18,20,21 24:24 signature 103:5 similar 55:4 Simmons 40:21 41:3 41:8,9,9,10 EDDIE T. JOHNSON August 21, 2017 Simmons' 41:15 43:20 44:7 simply 71:11 sit 24:17,20 24:21 34:7 34:17 71:13 71:13 73:23 88:22 sitting 24:24 situations 54:11 six 10:1 size 12:14 13:4,8 Skahill 41:23 43:12 44:1 sleep 15:17 smaller 13:6 social 19:14 socialize 19:11 solution 72:19 somebody 27:17 95:18 sorry 44:19 46:24 61:6 83:10 87:20 89:24 90:5 98:24 100:15 south 1:16 2:5 3:12 5:5 9:8,9 14:13 74:6 80:6 81:19 speak 62:4 speaking 63:6 specialist 5:20 specific 50:4 51:14 specifically 17:8 20:22 39:15 65:8 specifics 102:19 specified 105:17 specify 43:15 speculation 14:23 15:1 27:14 33:3 33:24 63:10 78:2,15 101:9 speculative 26:17 54:21 73:3 74:19 78:14 85:9 88:13 spend 78:7 78:23 split 24:3,3 25:2 spot 81:11 squad 19:2 ss 105:1 staff 61:24 62:4 stamp 42:23 89:15,19 Stamped 45:7 stand 76:18 Standards 22:17 stands 61:15 62:5 63:2 64:10 97:12 start 6:7 10:19,21 31:4 starting 6:2 18:14 starts 36:23 68:17 state 1:15 7:8 65:9,15 73:18 83:2 85:21 105:1 105:4 stated 69:7 70:24 79:16 79:20 82:9 105:19 statement 16:6 60:14 66:20 67:15 67:24 69:13 70:5 73:22 81:10 statements 68:23 states 1:1,12 5:15 94:10 104:1 station 72:22 stations 15:15 24:5 statute 92:11 stay 31:16,19 Steffanie 3:5 6:14 steffanie.ga... 3:7 stenograph... 105:11 street 2:11,20 3:5 14:13 32:22 74:8 strike 56:3 79:18 84:15 100:15 SUBSCRI... 104:19 Suite 2:12,20 3:6 summary 60:17 66:19 67:2 91:19 superinten... 3:11,15 5:8 7:13 8:19 8:21 36:4 46:18 58:15 61:22 62:8 63:22 69:20 71:6 75:15 76:22 92:23 93:3 100:18 101:16,20 102:9 103:2 103:12,13 supervise 18:3 supervised 17:18 supervisor 101:4 suppose 13:11 54:12 55:2 supposed 21:22 sure 11:9,9 18:24 30:19 33:6,7,15 35:10 38:12 45:2 51:9 58:4 69:7 75:1 79:14 92:8 93:22 96:12 suspension 95:1 99:6 99:14 sustain 66:4 sustained 48:21,22,23 50:23 52:7 53:18,21 54:18 61:1 61:19 63:5 TOOMEY REPORTING 312-853-0648 Page 13 talking 20:23 26:16 35:15 35:18 37:17 38:6 53:12 Tape 97:19 97:24 103:10 Tasered 41:8 technician 86:13 technique 99:19 techniques 70:10 98:7 tell 20:19 29:15 42:12 ten 12:11 13:23 14:1 T 18:20 20:3 T 1:10 3:15 20:13 24:4 4:3,7,7,13 35:1 7:2,6,6,10 tendered 104:9,18 39:24 67:22 table 65:10 76:15 75:23 term 36:12 take 7:24 terminals 25:12 31:3 24:12 31:18 37:8 terminate 39:23 43:4 95:18 44:23 48:9 terminated 49:17 55:4 94:20 97:2 58:2 76:1 terminating 76:21,23 97:5 84:10 86:10 termination 92:5 97:16 95:23 97:15 taken 1:11,14 terminology 5:10 11:3 21:16 11:13 71:3 terms 74:23 71:7 74:24 testified 7:4 104:13 16:6 56:19 105:16 56:24 77:22 talk 20:15,22 testify 69:19 95:12 75:12 105:8 talked 21:13 testimony 63:16 66:1 Sutton 2:15 6:17 59:18 84:5 99:5,7 99:9 101:7 101:16 swear 6:20 sworn 6:23 7:4 8:22 29:22,22 31:2 104:10 104:19 105:8 system 38:2 38:12,20 53:7 56:5 56:16 57:2 EDDIE T. JOHNSON August 21, 2017 16:16 26:5 79:1 82:10 98:10 104:16 105:14 Thank 40:1 83:11 103:1 103:3,13,15 Thanks 44:12 thing 29:21 57:17,20 things 20:8 71:10 think 12:22 13:23 25:10 44:21 45:1 65:11 72:18 third 17:17 17:23 THOMAS 2:3,4 7:7 thoroughly 25:18,22 26:1 thought 22:5 thousand75:8 100:14 threatened 50:9 three 14:8 29:24 56:11 three-page 7:22 59:12 threw 47:16 47:17 Tiffany 2:11 6:16 tiffany.har... 2:13 time 9:11,15 9:23 10:17 11:1,10,15 12:21 13:20 15:3,4 17:4 17:22,24 18:1,15 19:23 22:7 25:1 29:23 32:18,18 33:16,16 34:9 36:5 36:18 45:10 47:3,10 56:8 58:1,4 58:7,12 63:18 69:10 71:14 72:15 74:12,16,23 75:9 76:6,9 76:10 77:5 77:16,17,23 78:23 79:5 79:14 88:23 95:5,8 97:18,23 102:21 103:9 104:14 105:17 timeframe 11:5 38:6 53:12 78:19 102:19 times 10:3,5 13:13,17 14:8 15:8 15:23 16:7 19:8,11 26:12 27:3 31:23 32:20 33:7,11 78:7,23 Tina 41:22 today's 5:1 58:15 59:5 Tom 6:4 Toomey 5:24 top 90:11 total 61:24 totality 69:11 tour 10:11 track 38:14 traditionally 13:14 transcript 104:12,15 105:11 Transfer 102:16 transferred 102:12,23 transported 74:9 80:6 80:10 81:19 treatment 70:7 TRR 100:3 true 104:15 105:13 truth 105:8 trying 95:13 turn 25:13 28:13 59:10 two 12:22 19:5 29:24 51:6 59:23 60:7,12 71:10 75:8 78:7 100:14 two-page 7:21 type 26:13 typewriting 105:12 typical 10:19 typically 10:19,21 11:14 15:15 18:24 24:17 25:12 28:13 U U 4:7 Uh-huh 89:5 unable 33:13 unclear 79:8 uncooperat... 33:19 34:16 34:21 71:4 73:9,12 79:2 84:22 86:20 87:10 98:5,15 understand 46:11 57:16 79:12 unfounded 48:23 50:24 unit 36:24 United 1:1,12 5:15 104:1 universal 25:20 unnecessary 69:4,11 70:23 unreasonable 70:8,23 unstable 31:24 unusual 85:19 86:15 unwarranted 69:5 unwilling 33:13 use 8:8 69:4 69:11 70:8 70:9,22 98:6 utilizes 38:14 Page 14 57:12 71:22 73:2,11 86:24 100:22 102:16 vagueness 54:7 96:10 Valente 3:12 6:12,12 vehicle 50:9 version 43:12 versus 5:18 vestibule 14:3 16:8 video 5:3,20 58:8,13 97:20 98:1 Videograp... 3:18 5:1 6:19 58:7 58:12 97:18 97:23 103:6 103:9 videotaped 1:9 5:7 vs 1:5 104:5 48:12 wasn't 24:2 31:17 67:3 80:15 81:15 91:23 watch 10:4,7 10:9 16:4 88:19 way 21:22,24 36:19 46:2 46:5 60:3 82:1 wbazarek... 2:22 we'll 36:9 76:1,23,24 we're 21:22 26:16 58:2 76:21 97:16 97:20,24 weapon 26:2 weighed 44:6 went 34:12 96:23 west 14:14,16 Western 2:5 14:16 W WHEREOF wait 71:18 106:1 waited 71:11 Whichever 98:16 36:19 wall 41:10 wide 24:12 want 6:7 25:3 Wilfredo 32:11 34:21 2:16 44:11,23 William 2:19 61:16 69:8 6:10 76:20,23 Williams 93:4 45:19 wanted 94:20 willing 72:5 94:24 79:6 V warming winter 15:6 vague 21:7 15:15 witness 3:15 26:16 27:11 warrant 50:9 4:2 6:20,22 52:15 54:21 warranted 7:3 8:14 TOOMEY REPORTING 312-853-0648 EDDIE T. JOHNSON August 21, 2017 12:1 15:2 15:14 16:17 20:18 21:11 23:9 26:7 26:18 27:15 30:16 32:9 32:15 33:4 34:5 37:21 38:9 39:14 43:1,10 45:12 47:6 48:18 52:1 53:17 54:10 55:1,21 56:21 61:17 62:23 63:11 64:7 67:1 68:8 74:21 76:4 77:9 77:12,21 78:3 80:4 81:14 85:10 85:17 86:9 88:1,17 90:12 91:3 93:21 96:11 97:11 98:13 99:2 100:1 100:10,23 101:12 103:3,15 105:7,7 106:1 woman 16:12 word 80:18 wording 42:11 work 10:13 10:16 18:11 18:21 19:1 19:8,12 20:9 worked 9:17 14:4 18:8 0745 76:6 084-003813 106:10 30:11,20 13 1:5 5:17 8:22 104:5 31:8 35:5 35:16,17,23 13th 60:20 37:2,8,18 79:19 91:7 1 37:20 38:8 94:2 1 4:22 40:11 14 59:2 52:20 53:14 40:14 50:6 15 89:9 92:1 57:8 71:8 59:2 75:3,7 15-page 71:16 72:2 77:3 97:19 44:19 72:16 73:7 1-104 104:13 16 13:10 75:9,17 1:30 1:17 5:3 1600 2:20 76:6 77:14 10 76:6 77:14 18 4:16 7:16 81:22 82:9 94:6 7:21 83:1,9,10 10:00 10:21 86:19 87:9 1919 5:21 11:20 1937 1:5 5:17 88:7 98:3 10:28 77:14 100:16 104:5 10:30 87:8 1988 18:14 101:19 100 62:9 2012 17:6,14 1998 13:24 X 1006219 18:15,17 2013 17:10 X 4:1,13 7:6 39:22 67:16 19th 46:23,24 10150 2:5 2014 17:14 Y 2 1020192 45:7 2015 17:8 Y 2:11 10523 90:15 2 68:15 97:24 2016 8:23 yeah 15:18 99:8,9 10th 71:8 59:15 60:20 16:2 18:17 103:10 75:8,17 61:23 62:8 19:21 22:6 98:3 100:16 2:33 58:6 63:24 65:21 24:14,14 2:34 58:8 101:18 68:13 79:19 26:19 27:18 11 4:20 41:19 2:50 58:12 83:9 89:4 46:14 52:2 42:20 45:22 20 2:20 24:13 90:6 94:2 57:17 80:21 46:20 58:21 2007 44:1 2017 1:17 5:2 94:16 59:1,4,7,10 2008 9:3 18:7 104:21 years 13:23 18:11 44:3 60:20 68:10 106:3 14:1 18:20 45:22 46:23 21st 1:17 5:2 70:3 75:8 20:3,13 46:24 49:17 22nd 45:22 83:17,18 63:21 64:1 50:15 89:20 90:8 233-7900 2:6 64:16 92:5 94:6 96:15 2009 51:3 2345 47:1 92:9,10,13 2011 9:4 96:16 23rd 94:11 92:21 93:13 11:00 10:22 10:12,15 24th 49:17 Yep 65:5 11:7,15,21 27 4:17 39:17 111th 74:8 12:6 13:22 11th 87:8 39:21 40:9 Z 14:18 16:11 100:14 40:11,15 23:12 24:1 12 13:10 41:19 0 26:1 29:3 89:21 96:16 003520 45:8 3 29:11,17 010522 90:9 12:00 10:22 18:18 19:2 19:5 29:4 29:10 39:9 working 101:24 works 82:1 wouldn't 10:21 13:18 25:3 31:11 31:16 56:22 57:6,21 72:10 78:4 write 96:7 writing 69:22 written 69:18 wrong 12:12 98:7 TOOMEY REPORTING 312-853-0648 Page 15 3 4:9 3/4ths 13:8 3:35 97:19 3:43 97:23 3:49 103:10 30 2:11 3:5 49:13 91:20 91:21 100:7 30-day 94:24 31 4:19 49:7 49:11,13,14 312 2:13,21 3:7,13 31st 95:10 33 4:18 44:14 44:18 45:3 45:16,23 46:20 47:23 33-page 44:19 3510 1:16 3:12 5:5 36 4:9 39 4:17 3rd 18:4 106:2 4 4 17:9 41:2,5 77:3 422-9400 2:21 43-page 67:17 44 4:18 49 4:19 5 5 60:21 70:3 5:00 11:18 58 4:20 5th 74:6,7 6 6 60:21 70:4 EDDIE T. JOHNSON August 21, 2017 73:18 83:1 60602 2:12 2:21 3:6 60643 2:5 60647 5:22 60653 3:13 5:6 67 4:21 6th 9:5,7,11 9:17,20,23 10:8,14,24 11:12 12:6 12:18 13:13 13:16,21 14:3,10,18 15:7,10,21 15:22 16:8 16:22 18:7 18:12,19,22 20:3,14 21:2,19 23:12,24 25:8,15,17 27:3 28:17 29:5,11 31:22 32:1 32:21 33:11 35:2,19,21 35:23 36:11 37:12 38:24 39:8 44:2 51:16 59:15 64:15 68:13 71:17 72:2 72:7,11,20 72:24 73:7 73:8 74:1 74:10,13,16 77:19 78:6 80:12,15 81:12,15,18 81:22,23 82:9 86:18 86:22 88:7 89:3 90:2,6 98:4 102:13 102:22 7 7 4:16,21 59:11 67:6 67:11,12,13 90:8 7-103 4:4 7:00 11:18 727 74:8 744-6959 3:7 744-7684 2:13 745-6115 3:13 75 4:22 75th 14:13 773 2:6 78th 9:9 10:3 7th 67:16 8 8 83:18 90:11 8:00 29:16 9 9:00 10:20 900 2:12 3:6 98 18:16 TOOMEY REPORTING 312-853-0648 Page 16