Case: 1:13-cv-01937 Document 182-6 Filed: 03/11/16 Page 1 of 107 PagelD #21309

EXHIBIT

Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 2 of 107 PageID #:1310

Transcript of the Testimony of
GLENN EVANS
Date: March 16, 2015
Case: RITA KING VS. GLENN EVANS, ET AL.

TOOMEY REPORTING

Phone: 312-853-0648
Fax: 312-853-9705
Email: toomeyrep@sbcglobal.net
Internet: http://www.toomeyreporting.com/

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 3 of 107 PageID #:1311

GLENN EVANS
March 16, 2015
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 deposition of GLENN EVANS,
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 30 North LaSalle Street,
Suite 900, Chicago, Illinois, on March 16, 2015,
at 11:20 a.m.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 4 of 107 PageID #:1312

GLENN EVANS
March 16, 2015
2 (Pages 2 to 5)
Page 2
1
2

A P P E A R A N C E S:

5
6

WITNESS
GLENN EVANS
3
4
5
6

Appeared on behalf of the
Plaintiff;

11
12
13
14
15
16
17
18

DIRECT EXAMINATION BY
MR. MORRISSEY:

19
20
21
22
23
24

MARKED
PAGE
PLAINTIFF'S EXHIBIT NO. 1
21
PLAINTIFF'S EXHIBIT NO. 2 (not marked.)
PLAINTIFF'S EXHIBIT NO. 3
22
PLAINTIFF'S EXHIBIT NO. 4 (not attached) 38
PLAINTIFF'S EXHIBIT NO. 5
39
******

Page 3
1
2

A P P E A R A N C E S:
THE LAW OFFICES OF:
CITY OF CHICAGO
FEDERAL CIVIL RIGHTS
LITIGATION DIVISION
BY: MS. CARLA MADELEINE KUPE-ARION
30 North LaSalle Street
Suite 900
Chicago, Illinois 60602
(312) 744-5106
carla.kupearion@cityofchicago.org

3
4
5
6
7
8

Appeared on behalf of the
Defendant, City of
Chicago;

9
10
11

THE LAW OFFICES OF:
MS. LAURA J. MORASK

12

BY: MS. LAURA J. MORASK
713 West Devon Avenue
Park Ridge, Illinois 60068
(847) 696-7185
LAURA@LAURALAW.ORG

13
14
15

and
16

THE LAW OFFICES OF:
MR. TIMOTHY M. BLACK
BY: MR. TIMOTHY M. BLACK
713 West Devon Avenue
Park Ridge, Illinois 60068
(262) 745-2837
timothyblack@gmail.com
Appeared on behalf of the
Defendant, Glenn Evans, in
his criminal case,
People of the State of
Illinois vs. Glenn Evans,
Case No. 14 CR 16367.

17
18
19
20
21
22
23
24

.

12-51

EXHIBITS
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

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
Appeared on behalf of the
individual defendants:
Glenn Evans, D.T. Clifford,
R.A. Sutton, K.L. Rodgers,
Wilfredo Lapitan, and
Lloyd Gray.

10

PAGE

2

7
8
9

INDEX

1

THE LAW OFFICES OF:
THOMAS G. MORRISSEY
BY: MR. THOMAS G. MORRISSEY
MR. PATRICK MORRISSEY
10249 South Western Avenue
Chicago, Illinois 60643
(773) 233-7900
tgmlaw@amertech.net

3
4

Page 4

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

CERTIFIED QUESTIONS
LINE
PAGE
19
12
21
13
13
14
16
15
2
16
11
16
16
16
22
16
2
17
7
17
13
17
18
17
23
17
4
18
8
18
12
18
17
18
23
18
4
19
10
19
17
19
23
19

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 5 of 107 PageID #:1313

GLENN EVANS
March 16, 2015
3 (Pages 6 to 9)
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

CERTIFIED QUESTIONS
LINE
PAGE
4
20
10
20
15
20
23
20
19
21
1
22
7
22
7
23
11
23
15
23
21
23
2
24
9
24
14
24
21
24
2
25
7
25
12
25
19
25
2
26
8
26
12
26

Page 8

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

CERTIFIED QUESTIONS
LINE
PAGE
4
32
9
32
13
32
18
32
21
32
1
33
4
33
7
33
11
33
18
33
22
33
2
34
6
34
10
34
15
34
19
34
24
34
5
35
10
35
16
35
21
35
3
36

Page 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

CERTIFIED QUESTIONS
LINE
PAGE
19
26
12
27
16
27
19
27
22
27
2
28
6
28
10
28
14
28
21
28
4
29
9
29
13
29
19
29
1
30
5
30
9
30
12
30
17
30
22
30
5
31
13
31

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

CERTIFIED QUESTIONS
LINE
PAGE
13
36
22
36
4
37
8
37
12
37
21
37
3
38
10
38
24
38
10
39
19
39
11
40
20
40
5
41
10
41
17
41
7
42
20
42
24
42
4
43
9
43
21
43

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 6 of 107 PageID #:1314

GLENN EVANS
March 16, 2015
4 (Pages 10 to 13)
Page 10

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

CERTIFIED QUESTIONS
LINE
PAGE
9
44
20
44
6
45
18
45
3
46
13
46
23
47
7
47
13
47
18
47
4
48
8
48
12
48
17
48
6
49
11
49
15
49
20
49
5
50
17
50

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

MR. MORRISSEY: You can't give a nod
of the head or say uh-huh or whatever
because the court reporter will not be able
to have a complete record; do you
understand that?
THE WITNESS: Yes.
MR. MORRISSEY: If at any time during
this deposition you don't understand one of
my questions, please stop me and I will
attempt to rephrase it; do you understand?
THE WITNESS: Yes.
WHEREUPON:
GLENN EVANS,
called as a witness herein, having been first
duly sworn, was examined and testified as
follows:
DIRECT EXAMINATION
BY MR. MORRISSEY:
Q **** Are you under any type of
medication as you sit here today?
A On the advice of my attorney, I am
invoking my Fifth Amendment right not to
testify.
Q To the extent that -- For how long --

Page 11
1
2
3
4
5
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

(WHEREUPON, the witness
was first duly sworn.)
MR. MORRISSEY: This is the discovery
deposition of Commander Evans taken
pursuant to notice and the Fede
6
Civil
Procedure.
The deposition has been continued
several times by the attorneys for the City
and Mr. Evans.
Mr. Evans, before we get started,
have you ever been deposed before?
THE WITNESS: Yes.
MR. MORRISSEY: So you understand the
general rules in regards to a discovery
deposition, correct?
THE WITNESS: I don't understand the
phrase "general rules."
MR. MORRISSEY: Well, All right, let
me explain it. In a deposition, I'm going
to ask you a series of questions, and you
are going to have to answer orally so that
the court reporter can take down your
responses. Do you understand that?
THE WITNESS: Yes.

Page 13
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Are you currently employed by the Chicago
Police Department?
A Yes.
Q How long have you been with the
Chicago Police Department?
A Since 1986.
MR. MORRISSEY: I'm going to ask to
certify the first question in regards to
whether or not you're under any type of
medication as you sit here today.
BY MR. MORRISSEY:
Q And I understand your invoking your
Fifth Amendment privilege; is that correct?
A Yes.
MR. MORRISSEY: So we will certify
that question for the Court.
BY MR. MORRISSEY:
Q When did you first become employed by
the Chicago Police Department?
A July 1986.
Q **** When you first became employed
by the Chicago Police Department, were you
required to go to a training academy?
A On the advice of my attorney, I

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 7 of 107 PageID #:1315

GLENN EVANS
March 16, 2015
5 (Pages 14 to 17)
Page 14
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

invoke my Fifth Amendment right not to testify.
MR. MORRISSEY: Again, we are going
to certify that question.
BY MR. MORRISSEY:
Q Where were you first employed as a -Strike that. Were you ever sworn in as a
member of the Chicago Police Department?
A Yes.
Q And what month and what year were you
sworn in as a member of the Chicago Police
Department?
A July 1986.
Q **** After you became a sworn member
of the Chicago Police Department, where were
you assigned as a Chicago police officer?
A On the advice of my attorney, I'm
invoking my Fifth Amendment right not to
testify.
MR. MORRISSEY: We will certify the
question.
BY MR. MORRISSEY:
Q For what period of time were you a
patrol officer with the Chicago Police
Department?

Page 16
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 **** Did you ever have the position
with the Chicago Police Department as an
officer?
MS. HARRIS: Objection, vague. Go
ahead.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** For what period of time were you
a police officer with the Chicago Police
Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** At any period of time when you
were a sworn member of the Chicago Police
Department, were you promoted to any other
position as a detective?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you ever have a position as
a sergeant in the Chicago Police Department?
A On the advice of my attorney, I

Page 15
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 Could you be more specific? What do
you mean?
Q For what period of time were you a -Strike that. When you first were sworn in as a
Chicago Police -- as a member of the Chicago
Police Department, what was your position?
A Probationary police officer.
Q And after you completed your
probationary period with the Chicago Police
Department, what rank did you obtain? Do you
understand the question?
A No, I don't.
Q Was there a probationary period that
you served with the Chicago Police Department?
A Yes.
Q **** How long was that period for?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
MR. MORRISSEY: Again, we will
certify that question. Each time the
deponent seeks to assert a Fifth Amendment
privilege, we are going to certify the
questions for the -- either the district
court or the magistrate.

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

invoke my Fifth Amendment right not to testify.
Q **** Did you ever -- For how long a
period of time were you a sergeant with the
Chicago Police Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you ever get promoted to the
position of a lieutenant with the Chicago
Police Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Were you ever assigned to the
6th Police Department in the Chicago Police
Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Were you at any point in time
ever a watch commander while assigned to the
6th District?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Were you working on April 10,
2011 as a lieutenant with the Chicago Police

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 8 of 107 PageID #:1316

GLENN EVANS
March 16, 2015
6 (Pages 18 to 21)
Page 18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 10th, 2011, were you on
duty between the hours of 8:00 a.m. and 11:00 a.m.?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you know a police officer by
the name of Sutton?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 10th, 2011, was a
Police Officer Clifford working in the 6th
District?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Was there a police officer by
the name of Officer Rodgers assigned to the 6th
District and working on April 10th, 2011 at
approximately 10:30 a.m.?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 10th, 2011, did you
have occasion to see a person by the name of

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

King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 11th, 2011 in the
lockup facility at approximately 10:30 a.m. in
the morning, did you have any physical contact
with the Plaintiff, Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 10th, 2011, did you
approve as the watch commander a probable cause
for the arrest of Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you have any contact,
physical contact, with Rita King -A On the -Q -- on -- Let me finish my question -on April 10th, 2011 in the lockup facility in
the 6th District?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Were you served with a complaint
in this lawsuit filed by Rita King?

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

Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On or about April 10th, 2011, at
approximately 10:20 in the morning, were you
present in the lockup facility at the 6th
Police District?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** At about 10:20 or thereafter on
the morning of April 10th, 2011, were you in
the presence of Ms. King and Officer Clifford,
Officer Rodgers and Officer Sutton in the
lockup facility at the 6th District?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On or about April 10th, 2011 at
10:20 a.m. in the morning, did you enter the
lockup facility and speak with the Plaintiff in
this case, Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Prior to April 10th, 2011, did
you know an individual by the name of Rita

Page 21
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 On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
(WHEREUPON, Plaintiff's
Exhibit No. 1 was marked
for identification.)
BY MR. MORRISSEY:
Q I'm showing you what has been marked
as Plaintiff's Exhibit Number 1. It's
Defendant Evans' Answer to Plaintiff's First
Set of Interrogatories. I would ask you to
take a look at that document for a moment.
MR. MORRISSEY: Let's go outside for
a second.
(WHEREUPON, a short
break was had.)
(WHEREUPON, the record was
read as requested.)
BY MR. MORRISSEY:
Q **** Mr. Evans, have you had an
opportunity to review Plaintiff's Exhibit 1
which is Defendant Evans' Answers to
Plaintiff's First Set of Interrogatories?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 9 of 107 PageID #:1317

GLENN EVANS
March 16, 2015
7 (Pages 22 to 25)
Page 22
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 **** I would ask you to turn to the
final page of Defendant Evans' Answers to the
First Set of Interrogatories, and I would ask
you whether or not that is your signature?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** I would ask you in regards to
Plaintiff's Exhibit Number 1, are those your
answers that you prepared in regards to
litigation in Rita King versus Glenn Evans?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
MR. MORRISSEY: So what are we on, 1?
I think we're only on 1, right? All right,
we are on 2, so make it 3.
(WHEREUPON, Plaintiff's
Exhibit No. 3 was marked
for identification.)
BY MR. MORRISSEY:
Q Showing you, Mr. Evans, which has
been marked as Plaintiff's Exhibit Number 3,
it's a document which states Defendant's
Answers to Affirmative Defenses Jury Demand in
Response to Plaintiff's Amended complaint. I

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

invoke my Fifth Amendment right not to testify.
Q **** Were you served or were your
attorneys -- are you -- Strike that.
Are you represented by any attorneys
in a case brought by Rita King in regards to an
incident which occurred on April 10th, 2011?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you spoken to any attorneys
in regards to an incident in regards to a
complaint filed by Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Were you served with a -- were
you or were your attorneys served with an
Amended Complaint brought by Rita King in
regards to an incident which occurred on
April 10th, 2011?
A On the advice of my attorneys, I
invoke my Fifth Amendment right not to testify.
Q **** Mr. Evans, is there a city
agency, to your knowledge, called the
Independent Police Review Authority?
A On the advice of my attorney, I

Page 23
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

would ask you to -- and it was filed as
Document Number 30 on June 28th, 2013. I would
ask you to take a look at this document. It's
right here. It's Number 3.
MS. MORASK: It's this one.
BY MR. MORRISSEY:
Q **** Have you had an opportunity to
review Plaintiff's Exhibit Number 3?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Mr. Evans, were you ever served
as a defendant in a case brought by Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On your behalf, did attorneys
file an initial Answer to a Complaint filed by
Rita King in regards to an incident which
occurred on April 10th, 2011?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** My question is did you respond
at any point to a lawsuit brought by Rita King
in the form of an Answer to the Complaint?
A On the advice of my attorney, I

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

invoke my Fifth Amendment right not to testify.
Q **** On November 7th, 2013, did you
give a statement to a Linda Franco in regards
to a citizen complaint filed by Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you appear in the office of
Linda Franco on November 7th, 2013 in regards
to a citizen complaint filed by Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you give a statement to
Ms. Franco on November 7th, 2013 in regards to
Ms. Rita King's allegation that you used
excessive force against her on April 10th,
2011?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you intend to testify at the
trial brought by Rita King in regards to
allegations that on April 10th, 2011, you used
excessive force on her in the lockup room in
the 6th District?
A On the advice of my attorney, I

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 10 of 107 PageID #:1318

GLENN EVANS
March 16, 2015
8 (Pages 26 to 29)
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

invoke my Fifth Amendment right not to testify.
Q **** Have you discussed the incident
with either Officer Sutton, Officer Clifford or
Officer Rodgers in regards to the allegations
brought by Rita King in this federal lawsuit?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 10th, 2011, did you
give any verbal commands to Rita King?
A On the advice of the attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Is it your position that on
April 10th, 2011 in the lockup at the 6th
District, Rita King refused to respond to your
verbal commands to submit to being
photographed?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Tell me what reasonable force
you used against Rita King on April 10th, 2011
in order for her to submit to being
fingerprinted and photographed in the lockup in
the 6th District?
A On the advice of my attorney, I

Page 28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

invoke my Fifth Amendment right not to testify.
Q **** Did you ever work as a security
officer in a roller rink?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you ever receive any
graduate degree or education?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you received any awards
from the city of Chicago?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** When you were promoted as a
police officer to the level of sergeant, did
you -- were you interviewed prior to receiving
that promotion by any member of the command
staff?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** When you were promoted to a
lieutenant position in the Chicago Police
department, did you take an examination to
become a -- to qualify to take the position of

Page 27
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

invoke my Fifth Amendment right not to testify.
Q Where did you go to high school?
A Excuse me?
Q Where did you go to high school?
A Could you be more specific?
Q Did you attend freshman year of high
school?
A Yes.
Q Did you graduate from a high school
in the United States?
A Yes.
Q **** Where did you graduate -- What
high school did you graduate from?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you attend college?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did you graduate from college?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you live in the city of
Chicago?
A On the advice of my attorney, I

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

lieutenant?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you ever been subject to a
citizen complaint for the use of excessive
force?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you ever been disciplined
for using excessive force against any citizen?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you had any conversations
with the mayor of Chicago in regards to your
position as a lieutenant or a commander in the
Chicago Police department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Has the superintendent of the
police, Mr. McCarthy, had any conversations
with you in regards to prior citizens'
complaints in regards to excessive force?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 11 of 107 PageID #:1319

GLENN EVANS
March 16, 2015
9 (Pages 30 to 33)
Page 30
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 **** Who is the current
superintendent of police?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Are you still being paid by the
city of Chicago as a police officer?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Are you employed currently?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you been terminated -- has
your employment been terminated in the last two
years?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Give me your general duties and
obligations as a member of the Chicago Police
Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Prior to being promoted to the
lieutenant, as a lieutenant of the Chicago
Police Department, did you undergo any

Page 32
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 objection on the record. You can answer.
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** What were your duties as -- Are
you still a commander with the Chicago Police
Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** What are the responsibilities of
a commander with the Chicago Police Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On April 10th, 2011 what were
your responsibilities as the watch commander
that morning?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you have any assets?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you have any bank accounts
currently?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.

Page 31
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

psychological evaluation?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to provide
testimony.
Q **** After citizen complaints have
been filed against you, has the police
department ever required you to undergo a
psychological evaluation to determine whether
or not you were fit to be a member of the
Chicago Police Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** When you were promoted to the
level of lieutenant in the Chicago Police
Department, was there ever, to your knowledge,
any review of the prior citizen complaints that
have been filed against you for the use of
excessive force prior to promoting you?
MS. KUPE-ARION: Objection to the
form of the question, also objection, it's
speculative and, objection, competence by
the City.
BY MR. MORRISSEY:
Q You could answer. She's just putting

Page 33
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 **** Do you own any real property?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you have any stocks or bonds?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you have any judgments
against you?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you ever been disciplined
by the Chicago Police Department for the -A On the -Q Let me finish my question -- based
upon the use of excessive force?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you ever been involved in a
civil litigation, in any civil litigation?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Were you ever a defendant in
Logan versus Evans, 97 C 8816?
A On the advice of my attorney, I

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 12 of 107 PageID #:1320

GLENN EVANS
March 16, 2015
10 (Pages 34 to 37)
Page 34
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

invoke my Fifth Amendment right not to testify.
Q **** In regards to Logan versus
Evans, were you a defendant or were you not?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Jones versus Ector, 98 C 5576,
were you a defendant in that action?
A On the advice of my attorney, I
invoke my Fifth Amendment Right not to testify.
Q **** In Randall verus the Superintendent
of the City of Chicago, 2000 C 299, were you
named as a defendant in that lawsuit?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Hall versus the City of
Chicago, 2000 C 5490, were you a defendant?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Simmons versus City of
Chicago, 2008 C 2769, were you a defendant in
that lawsuit?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Richardson versus City of

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

A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Is there any reason why you're
unable to sit for this deposition and answer
questions today?
MS. HARRIS: Objection,
mischaracterizes the testimony and evidence
in this case. You can answer.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Is there any physical reason why
you're unable to testify today?
MS. HARRIS: Objection,
mischaracterizes the testimony and evidence
in this case.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** When you were promoted to
commander, did you have any discussions with
then Superintendent McCarthy about prior

Page 35
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Chicago, 2008 C 4824, were you named as a
defendant?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Evans versus Williams and
Fudge, Inc., 2008 C 6919, were you a party in
that lawsuit?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Misher, M-i-s-h-e-r, versus
unknown Chicago Police Officers, 2010 C 1753,
were you named as a defendant in that
litigation?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In Byars, B-y-a-r-s, versus
Evans 13 C 923, were you named as a defendant
in those actions?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** In the above-listed lawsuits,
were you ever disciplined by the city of
Chicago as a result of any of those actions
brought by plaintiffs?

Page 37
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

lawsuits or citizen complaints?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Has the city of Chicago ever
disciplined you for the use of excessive force?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** What is your monthly gross
income, sir?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** What investigation did you do
prior to responding to Plaintiff's
interrogatories, first set of interrogatories?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q Did you review any police reports -A On the advice of my attorney -Q I've got to finish my question here.
A Okay, sir.
Q **** You jumped the gun here. On
April 10, 2011, did you review any police
reports prepared by Officer Clifford or Officer
Sutton in regards to the arrest of Rita King?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 13 of 107 PageID #:1321

GLENN EVANS
March 16, 2015
11 (Pages 38 to 41)
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

A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** What is a Tactical Response
Report with the Chicago Police Department -Strike that. Let me ask you a question.
Are you familiar with a form called a
Tactical Response Report?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** On or after April 10th, 2011,
why did you not prepare a Tactical Response
Report in regards to your contact with Rita
King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
MR. MORRISSEY: Why don't we take a
two-minute break here.
(WHEREUPON, a short break
was had.)
(WHEREUPON, Plaintiff's
Exhibit No. 4 was marked
for identification.)
BY MR. MORRISSEY:
Q **** I'm showing you what has been

Page 40
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

attorneys 03170 through 3172.
Mr. Evans, does the Chicago Police
Department have general procedures or orders
that are followed by members of the Chicago
Police Department?
MS. KUPE-ARION: Objection to the
form of the question, objection competency.
MR. MORRISSEY: Well, let me rephrase
the question.
BY MR. MORRISSEY:
Q **** Are there written procedures
that outline the duties and responsibilities of
members of the Chicago Police Department?
MS. KUPE-ARION: Same objection by
the City.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** What type of written orders are
issued by the Chicago Police Department?
MS. KUPE-ARION: Objection to the
form of the question and competence as
well.

Page 39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

marked as Plaintiff's Exhibit Number 4. It's a
Tactical Response Report by the Chicago Police
Department. I would ask you to take a look at
that form for a moment; and for the record,
apparently it's a two-page form.
Mr. Evans, is this a form that's used
by the Chicago Police Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Specifically, in April of 2010,
did the city of Chicago have a form called a
Tactical Response Report?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
(WHEREUPON, Plaintiff's
Exhibit No. 5 was marked
for identification.)
BY MR. MORRISSEY:
Q **** I'm showing you what is marked
as Plaintiff's Exhibit Number 5. The form is
captioned Detention Facilities General
Procedures and Responsibilities, Special Order
SO6-01-02. I would ask you to take a look at
this document that's been Bates stamped by your

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

BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Looking at Plaintiff's Exhibit
Number 5, is this a written order of the
Chicago Police Department?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Does the City of Chicago Police
Department have written procedures and
guidelines involving screening and monitoring
sick or injured or emotionally challenged
arrestees?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** If Rita King was not cooperative
in the lockup in the 6th District on April 10th,
2011, why was she not placed into a lockup
facility -MS. HARRIS: Objection, form.
BY MR. MORRISSEY:
Q -- prior to being fingerprinted and
photographed?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 14 of 107 PageID #:1322

GLENN EVANS
March 16, 2015
12 (Pages 42 to 45)
Page 42
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MS. HARRIS: Objection, form,
speculation, foundation, competence.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** If a person is suffering from a
psychological illness such as a bipolar
disorder, are there written procedures in
regards to processing such an arrestee by the
Chicago Police Department?
MS. HARRIS: Objection, form,
speculation, foundation, competence.
MS. KUPE-ARION: The City joins in
those objections.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Where is the 6th Police District
located in the city of Chicago?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** How many lockup cells are there

Page 44
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

force?
MS. HARRIS: Objection, form,
speculation, foundation, competence.
MS. KUPE-ARION: City joins.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** As a commander with the Chicago
Police Department, are officers disciplined if
they are found to -- found to have used
excessive force on citizens?
MS. HARRIS: Objection, form,
speculation, foundation, competence.
MS. KUPE-ARION: City joins.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** As a sergeant, have you ever
disciplined a member of the Chicago Police
Department when you found or determined that
the person -- that a police officer had used
excessive force?

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

in the lockup area of the 6th District?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** How would answering the question
in regards to how many lockups are in the 6th
District impact your Fifth Amendment rights?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Are there procedures or policies
within the Chicago Police Department for
processing arrestees who are high or
intoxicated on illegal street drugs?
MS. HARRIS: Objection, form,
speculation, foundation, competence.
MS. KUPE-ARION: The City joins in
those objections.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Are there any procedures within
the Chicago Police Department to discharge a
member of the police department who receives
frequent citizen complaints about excessive

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

MS. HARRIS: Objection, relevance.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** As a lieutenant, have you ever
disciplined or caused charges to be brought
against a police officer -MS. HARRIS: Objection, relevance.
BY MR. MORRISSEY:
Q -- in regards to the use of excessive
force?
MS. HARRIS: Objection, relevance.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** As a lieutenant, have you ever
disciplined a member of the Chicago Police
Department if you found or believed that they
had used excessive force against a citizen?
MS. HARRIS: Objection, relevance.
BY THE WITNESS:
A On the advice of my attorney, I

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 15 of 107 PageID #:1323

GLENN EVANS
March 16, 2015
13 (Pages 46 to 49)
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

invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** As a commander, have you ever
disciplined or caused a review of a police
officer or a lieutenant or a sergeant who you
believe had used excessive force against a
citizen?
MS. HARRIS: Objection, relevance.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Are you aware of the City of
Chicago's Police Department ever disciplining a
police officer, sergeant or lieutenant accused
of using excessive force against a citizen?
MS. HARRIS: Objection, vague, overly
broad, relevance.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** What is IPRA to your knowledge?
MS. HARRIS: Objection, competence,

Page 48
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 On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Did Rita King on April 10, 2011
strike you?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Did Rita King ever kick you on
April 10, 2011?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Have you ever given any
statement to anybody in regards to allegations
in regards to Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** At what point -- Assuming you
gave a statement to the Illinois -- or the
Independent Police Review Authority in November
of 2013 in regards to allegations by Rita King,
at what point did you decide that you would no
longer give statements in regards to Ms. King's
allegation?
MS. HARRIS: Objection, form,

Page 47
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

speculation, foundation.
MS. KUPE-ARION: City joins.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Have you ever given a statement
to the Independent Police Review Association?
MS. HARRIS: Objection, form.
MR. MORRISSEY: I'm sorry. Let me
rephrase that.
BY MR. MORRISSEY:
Q **** Have you ever been requested to
give a statement to the Independent Police
Review Authority of the City of Chicago?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** What is your understanding as a
member of the Chicago Police force of the term
"excessive force"?
MS. HARRIS: Objection, speculation,
foundation, competence, form.
MS. KUPE-ARION: City joins.
BY THE WITNESS:

Page 49
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

harassing.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Do you agree that you have
previously answered the complaint brought by
Rita King?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Do you agree that you also filed
an answer to Rita King's Amended Complaint?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Furthermore, you gave a
statement in regards to Rita King's allegation
in November of 2013, correct?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
Q **** Are you denying that in November
of 2013 that you gave a statement to the
Independent Police Review Authority?
MS. HARRIS: Objection, form,
harassing.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 16 of 107 PageID #:1324

GLENN EVANS
March 16, 2015
14 (Pages 50 to 53)
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
24

BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Are you aware that if the jury
returns a verdict in regards to punitive
damages in this case, that the city is not
going to indemnify you in regards to this -any damages awarded for punitive damages?
MS. HARRIS: Objection, form.
MS. KUPE-ARION: Objection to the
form of the question.
BY THE WITNESS:
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
BY MR. MORRISSEY:
Q **** Are you going to testify at
trial that you're financially unable to pay any
punitive damages which may or may not be
entered against you by a jury?
A On the advice of my attorney, I
invoke my Fifth Amendment right not to testify.
MR. MORRISSEY: I have nothing
further. All the questions in this

Page 52
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. MORRISSEY: You can bring
whatever motions -MS. HARRIS: It's not an argument,
Counsel.
MR. MORRISSEY: Well, I'm just -MS. HARRIS: I'm putting what I -MR. MORRISSEY: You can put whatever
you want.
MS. HARRIS: -- intend to do on the
record. I understand you object. That's
your position. We are not going to argue
about it. Everyone is just putting their
position on the record. That's all this
is.
MR. MORRISSEY: Mr. Evans, your
lawyer is going to advise you. You have
the right when this transcript is
transcribed, and it will be transcribed, to
review the transcript of today's proceeding
or you have the option of relying on the
court reporter to take down accurately your
responses to my questions. It's up to you.
MS. HARRIS: We are going to reserve.
MR. MORRISSEY: All right.

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

deposition in which Mr. Evans has invoked
his Fifth Amendment privilege I'm
certifying for the Court and will bring
this before the Court at the earliest time
period.
MS. KUPE-ARION: And for the City,
the City is reserving, for the record,
definitely reserving the right to recall
Commander Evans should the privilege
amendment no longer apply.
MR. MORRISSEY: Well, to the extent
that Commander Evans is taking the Fifth
Amendment, we are certainly not going to be
prejudiced at trial if all of a sudden
Commander Evans decides that he's now
decided that he's going to waive his Fifth
Amendment privilege. So that certainly
would put us at a great disadvantage but
anyway, that's for the Court to decide.
MS. HARRIS: On behalf of Glenn
Evans, we will be seeking to have the
deposition subject to a protective order
and we'll be bringing the proper motions
before the Court.

Page 53

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

FURTHER DEPONENT SAITH NOT.....

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 17 of 107 PageID #:1325

GLENN EVANS
March 16, 2015
15 (Pages 54 to 56)
Page 56

Page 54
1
2
3

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
RITA KING,

)
)

4

Plaintiff,

)
)

5

vs.

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

) No. 13 C 1937
)
GLENN EVANS, et al.,
)
)
Defendants.
)
I, GLENN EVANS, being first duly
sworn, on oath, say that I am the deponent in
the aforesaid deposition, that I have read the
foregoing transcript of my deposition,
consisting of pages 1-54 inclusive, taken at
the aforesaid time and place and that the
foregoing is a true and correct transcript of
my testimony so given.
____________________________
GLENN EVANS
SUBSCRIBED AND SWORN TO
me before this ________ day
of ___________________, A.D. 2015.
_________________________
Notary Public

23
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

IN WITNESS WHEREOF, I do hereunto set
my hand at Chicago, Illinois, this _______ day
of ____________________, 2015.

______________________________________
Peggy A. Anderson
Certified Shorthand Reporter
License No. 084-003813

Page 55

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 )
) ss:
COUNTY OF C O O K )
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

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 18 of 107 PageID #:1326

GLENN EVANS
March 16, 2015
Page 57
A
able 12:3
abovelisted 35:21
academy 13:23
accounts 32:21
accurately 52:21
accused 46:15
action 34:7 55:24
actions 35:18,23
adjourned 55:19
advice 12:21 13:24
14:16 15:17 16:8
16:14,20,24 17:5
17:10,16,21 18:2
18:6,10,15,21
19:2,8,15,21 20:2
20:8,13,21 21:1
21:23 22:5,11
23:9,13,19,24
24:7,12,19,24
25:5,10,17,24
26:6,10,17,24
27:14,17,20,24
28:4,8,12,19 29:2
29:7,11,17,23
30:3,7,10,15,20
31:2,11 32:2,7,11
32:16,19,23 33:2
33:5,9,16,20,24
34:4,8,13,17,22
35:3,8,14,19 36:1
36:10,19 37:2,6
37:10,15,18 38:1
38:8,14 39:8,13
40:17 41:2,8,15
42:4,17,22 43:2,7
43:18 44:6,17
45:3,15,24 46:10
46:20 47:4,16
48:1,6,10,15 49:3
49:9,13,18 50:2
50:14,21
advise 52:16
affirmative 22:23

aforesaid 54:11,14
agency 24:22
agree 49:6,11
ahead 16:6
al 1:6 54:6
allegation 25:14
48:23 49:16
allegations 25:21
26:4 48:13,20
amended 22:24
24:16 49:12
amendment 12:22
13:13 14:1,17
15:18,21 16:9,15
16:21 17:1,6,11
17:17,22 18:3,7
18:11,16,22 19:3
19:9,16,22 20:3,9
20:14,22 21:2,24
22:6,12 23:10,14
23:20 24:1,8,13
24:20 25:1,6,11
25:18 26:1,7,11
26:18 27:1,15,18
27:21 28:1,5,9,13
28:20 29:3,8,12
29:18,24 30:4,8
30:11,16,21 31:3
31:12 32:3,8,12
32:17,20,24 33:3
33:6,10,17,21
34:1,5,9,14,18,23
35:4,9,15,20 36:2
36:11,20 37:3,7
37:11,16 38:2,9
38:15 39:9,14
40:18 41:3,9,16
42:5,18,23 43:3,6
43:8,19 44:7,18
45:4,16 46:1,11
46:21 47:5,17
48:2,7,11,16 49:4
49:10,14,19 50:3
50:15,22 51:2,10
51:13,17

amertech 2:6
anderson 1:14 55:3
56:8
answer 11:21 21:9
23:16,23 31:24
32:1 36:4,8 49:12
answered 49:7
answering 43:4
answers 21:21 22:2
22:9,23
anybody 48:13
anyway 51:19
apparently 39:5
appear 25:7
appeared 2:7,16
3:8,21
apply 51:10
approve 20:11
approximately
18:20 19:5 20:5
april 17:23 18:4,12
18:19,23 19:4,11
19:17,23 20:4,10
20:19 23:18 24:6
24:18 25:15,21
26:8,13,20 32:13
37:22 38:10 39:10
41:18 48:4,9
area 43:1
argue 52:11
argument 52:3
arrest 20:12 37:24
arrestee 42:10
arrestees 41:14
43:11
assert 15:21
assets 32:18
assigned 14:15
17:13,19 18:18
association 47:8
assuming 48:17
attached 4:12
attempt 12:10
attend 27:6,16
attorney 12:21

13:24 14:16 15:17
16:8,14,20,24
17:5,10,16,21
18:2,6,10,15,21
19:2,8,15,21 20:2
20:8,13,21 21:1
21:23 22:5,11
23:9,13,19,24
24:7,12,24 25:5
25:10,17,24 26:6
26:10,17,24 27:14
27:17,20,24 28:4
28:8,12,19 29:2,7
29:11,17,23 30:3
30:7,10,15,20
31:2,11 32:2,7,11
32:16,19,23 33:2
33:5,9,16,20,24
34:4,8,13,17,22
35:3,8,14,19 36:1
36:10,19 37:2,6
37:10,15,18 38:1
38:8,14 39:8,13
40:17 41:2,8,15
42:4,17,22 43:2,7
43:18 44:6,17
45:3,15,24 46:10
46:20 47:4,16
48:1,6,10,15 49:3
49:9,13,18 50:2
50:14,21 55:21,22
attorneys 11:8
23:15 24:3,4,9,15
24:19 40:1
authority 24:23
47:15 48:19 49:22
avenue 2:5 3:13,18
awarded 50:9
awards 28:10
aware 46:13 50:5
B
b 4:6
bank 32:21
based 33:14

TOOMEY REPORTING
312-853-0648

bates 39:24
behalf 2:7,16 3:8
3:21 23:15 51:20
believe 46:6
believed 45:20
bipolar 42:8
black 3:17,18
bonds 33:4
break 21:15 38:17
38:18
bring 51:3 52:1
bringing 51:23
broad 46:18
brought 23:12,22
24:5,16 25:20
26:5 35:24 45:7
49:7
byars 35:16,16
C
c 1:5 2:1 3:1 5:1 6:1
7:1 8:1 9:1 10:1
12:17 33:23 34:6
34:11,16,20 35:1
35:6,11,17 54:5
55:2
called 1:10 12:14
24:22 38:6 39:11
cant 12:1
captioned 39:21
carla 3:5,7
case 3:22,23 19:20
23:12 24:5 36:8
36:17 50:7
cause 20:11
caused 45:7 46:4
cells 42:24
certainly 51:13,17
certified 1:14 55:3
56:9
certify 13:8,15 14:3
14:19 15:20,22
55:5
certifying 51:3
challenged 41:13

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 19 of 107 PageID #:1327

GLENN EVANS
March 16, 2015
Page 58
charges 45:7
chicago 1:16 2:5,10
2:13 3:3,6,9 13:1
13:5,19,22 14:7
14:10,14,15,23
15:5,5,9,14 16:3
16:12,17,23 17:4
17:8,14,24 27:23
28:11,22 29:14,16
30:6,18,23 31:10
31:14 32:5,10
33:12 34:11,16,20
35:1,11,23 37:4
38:4 39:2,7,11
40:2,4,13,21 41:7
41:10 42:11,21
43:10,22 44:9,21
45:19 47:15,19
56:2
chicagos 46:14
citizen 25:4,9 29:5
29:10 31:5,16
37:1 43:24 45:21
46:7,16
citizens 29:21
44:12
city 2:10 3:3,9 11:8
24:21 27:22 28:11
30:6 31:22 34:11
34:15,19,24 35:22
37:4 39:11 40:15
41:10 42:14,21
43:15 44:4,15
46:13 47:2,15,23
50:7 51:6,7
cityofchicago 2:15
3:7
civil 1:11 2:10 3:3
11:5 33:19,19
clifford 2:17 18:13
19:12 26:3 37:23
college 27:16,19
com 3:20
command 28:17
commander 11:4

17:19 20:11 29:15
32:5,10,14 36:23
44:9 46:3 51:9,12
51:15
commands 26:9,15
commencement
55:6
competence 31:21
40:23 42:2,13
43:14 44:3,14
46:24 47:22
competency 40:7
complaint 20:23
22:24 23:16,23
24:11,16 25:4,9
29:5 49:7,12
complaints 29:22
31:5,16 37:1
43:24
complete 12:4
completed 15:8
concerning 55:9
consisting 54:13
constitutes 55:13
contact 20:6,15,16
38:12
continued 11:7
conversations
29:13,20
cooperative 41:17
correct 11:15 13:13
49:17 54:15
counsel 52:4 55:21
55:22
county 55:2
court 1:1 11:22
12:3 13:16 15:24
51:3,4,19,24
52:21 54:1
courts 1:12
cr 3:23
criminal 3:22
current 30:1
currently 13:1 30:9
32:22

D
d 2:17 4:1 5:1 6:1
7:1 8:1 9:1 10:1
12:17 54:21
damages 50:7,9,9
50:19
day 54:20 56:2
decide 48:21 51:19
decided 51:16
decides 51:15
defendant 3:9,21
21:9,21 22:2
23:12 33:22 34:3
34:7,12,16,20
35:2,12,17
defendants 1:7
2:16 22:22 54:7
defenses 22:23
definitely 51:8
degree 28:7
demand 22:23
denying 49:20
department 13:2,5
13:19,22 14:7,11
14:14,24 15:6,10
15:14 16:3,13,18
16:23 17:4,9,14
17:15 18:1 28:23
29:16 30:19,24
31:7,10,15 32:6
32:10 33:12 38:4
39:3,7 40:3,5,13
40:21 41:7,11
42:11 43:10,22,23
44:10,22 45:20
46:14
deponent 15:21
53:3 54:10
deposed 11:11
deposition 1:9 11:4
11:7,15,19 12:8
36:4 51:1,22
54:11,12 55:10,16
55:18

depositions 1:13
detective 16:19
detention 39:21
determine 31:8
determined 44:22
devon 3:13,18
direct 4:3
direction 55:13
directly 55:23
disadvantage 51:18
discharge 43:22
disciplined 29:9
33:11 35:22 37:5
44:10,21 45:7,19
46:4
disciplining 46:14
discovery 11:3,14
discussed 26:2
discussions 36:23
disorder 42:9
district 1:1,1,12
15:23 17:20 18:14
18:19 19:7,14
20:20 25:23 26:14
26:23 41:18 42:20
43:1,6 54:1,1
division 1:2 2:11
3:4 54:2
document 21:11
22:22 23:2,3
39:24
dont 11:16 12:8
15:12 38:16
drugs 43:12
duly 11:2 12:15
54:9 55:8
duties 30:17 32:4
40:12
duty 18:5

12:17
earliest 51:4
eastern 1:2 54:2
ector 34:6
education 28:7
either 15:23 26:3
emotionally 41:13
employed 13:1,18
13:21 14:5 30:9
employee 55:20,22
employment 30:13
enter 19:18
entered 50:20
et 1:6 54:6
evaluation 31:1,8
evans 1:6,9 2:17
3:21,23 4:2 11:4,9
11:10 12:13 21:9
21:19,21 22:2,10
22:20 23:11 24:21
33:23 34:3 35:5
35:17 39:6 40:2
51:1,9,12,15,21
52:15 54:6,9,18
evidence 36:7,16
examination 1:10
4:3 28:23 55:7
examined 12:15
excessive 25:15,22
29:5,10,22 31:18
33:15 37:5 43:24
44:12,24 45:11,21
46:6,16 47:20
excuse 27:3
exhibit 4:9,10,11
4:12,13 21:4,8,20
22:8,17,21 23:8
38:21 39:1,16,20
41:5
explain 11:19
extent 12:24 51:11

E
e 2:1,1 3:1,1 4:1,6
F
5:1,1,1 6:1,1,1 7:1
7:1,1 8:1,1,1 9:1,1 f 5:1 6:1 7:1 8:1 9:1
9:1 10:1,1,1 12:17
10:1

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 20 of 107 PageID #:1328

GLENN EVANS
March 16, 2015
Page 59
facilities 39:21
facility 19:6,14,19
20:5,19 41:20
familiar 38:6
fede 11:5
federal 1:11 2:10
3:3 26:5
fifth 12:22 13:13
14:1,17 15:18,21
16:9,15,21 17:1,6
17:11,17,22 18:3
18:7,11,16,22
19:3,9,16,22 20:3
20:9,14,22 21:2
21:24 22:6,12
23:10,14,20 24:1
24:8,13,20 25:1,6
25:11,18 26:1,7
26:11,18 27:1,15
27:18,21 28:1,5,9
28:13,20 29:3,8
29:12,18,24 30:4
30:8,11,16,21
31:3,12 32:3,8,12
32:17,20,24 33:3
33:6,10,17,21
34:1,5,9,14,18,23
35:4,9,15,20 36:2
36:11,20 37:3,7
37:11,16 38:2,9
38:15 39:9,14
40:18 41:3,9,16
42:5,18,23 43:3,6
43:8,19 44:7,18
45:4,16 46:1,11
46:21 47:5,17
48:2,7,11,16 49:4
49:10,14,19 50:3
50:15,22 51:2,12
51:16
file 23:16
filed 20:24 23:1,16
24:11 25:4,9 31:6
31:17 49:11
final 22:2

financially 50:18
fingerprinted
26:22 41:23
finish 20:18 33:14
37:19
first 11:2 12:14
13:8,18,21 14:5
15:4 21:9,22 22:3
37:14 54:9
fit 31:9
followed 40:4
follows 12:16
force 25:15,22
26:19 29:6,10,22
31:18 33:15 37:5
44:1,12,24 45:12
45:21 46:6,16
47:19,20
foregoing 54:12,15
55:10
form 23:23 31:20
38:6 39:4,5,6,11
39:20 40:7,23
41:21 42:1,12
43:13 44:2,13
47:9,22 48:24
49:23 50:10,12
found 44:11,11,22
45:20
foundation 42:2,13
43:14 44:3,14
47:1,22
franco 25:3,8,13
frequent 43:24
freshman 27:6
fudge 35:6
further 50:24 53:3
furthermore 49:15
G
g 2:3,4
general 11:14,17
30:17 39:21 40:3
give 12:1 25:3,12
26:9 30:17 47:14

48:22
given 47:7 48:12
54:16 55:14
glenn 1:6,9 2:17
3:21,23 4:2 12:13
22:10 51:20 54:6
54:9,18
gmail 3:20
go 13:23 16:5 21:12
27:2,4
going 11:19,21 13:7
14:2 15:22 50:8
50:17 51:13,16
52:11,16,23
graduate 27:9,12
27:13,19 28:7
gray 2:18
great 51:18
gross 37:8
guidelines 41:12
gun 37:21

22:18 38:22 39:17
illegal 43:12
illinois 1:1,15,16
2:5,13 3:6,13,19
3:23 48:18 54:1
55:1,4 56:2
illness 42:8
im 11:19 13:7
14:16 21:7 38:24
39:19 47:10 51:2
52:5,6
impact 43:6
incident 23:17 24:6
24:10,17 26:2
inclusive 54:13
income 37:9
indemnify 50:8
independent 24:23
47:8,14 48:19
49:22
indirectly 55:24
individual 2:16
H
19:24
h 4:6
initial 23:16
hall 34:15
injured 41:13
hand 56:2
intend 25:19 52:9
harassing 49:1,24
interested 55:23
harris 2:12,15 16:5 interrogatories
36:6,15 41:21
21:10,22 22:3
42:1,12 43:13
37:14,14
44:2,13 45:1,9,13 interviewed 28:16
45:22 46:8,17,24 intoxicated 43:12
47:9,21 48:24
investigation 37:12
49:23 50:10 51:20 invoke 14:1 15:18
52:3,6,9,23
16:9,15,21 17:1,6
head 12:2
17:11,17,22 18:3
hereto 55:23
18:7,11,16,22
hereunto 56:1
19:3,9,16,22 20:3
hes 51:15,16
20:9,14,22 21:2
high 27:2,4,6,9,13
21:24 22:6,12
43:11
23:10,14,20 24:1
hours 18:5
24:8,13,20 25:1,6
25:11,18 26:1,7
I
26:11,18 27:1,15
identification 21:5
27:18,21 28:1,5,9

TOOMEY REPORTING
312-853-0648

28:13,20 29:3,8
29:12,18,24 30:4
30:8,11,16,21
31:3,12 32:3,8,12
32:17,20,24 33:3
33:6,10,17,21
34:1,5,9,14,18,23
35:4,9,15,20 36:2
36:11,20 37:3,7
37:11,16 38:2,9
38:15 39:9,14
40:18 41:3,9,16
42:5,18,23 43:3,8
43:19 44:7,18
45:4,16 46:1,11
46:21 47:5,17
48:2,7,11,16 49:4
49:10,14,19 50:3
50:15,22
invoked 51:1
invoking 12:22
13:12 14:17
involved 33:18
involving 41:12
ipra 46:23
issued 40:21
ive 37:19
J
j 3:11,12
joins 42:14 43:15
44:4,15 47:2,23
jones 34:6
judgments 33:7
july 13:20 14:12
jumped 37:21
june 23:2
jury 22:23 50:5,20
K
k 2:17 55:2
kick 48:8
king 1:3 19:1,12,20
20:1,7,12,16,24
22:10 23:12,17,22

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 21 of 107 PageID #:1329

GLENN EVANS
March 16, 2015
Page 60
24:5,11,16 25:4,9
25:20 26:5,9,14
26:20 37:24 38:13
41:17 48:4,8,14
48:20 49:8 54:3
kings 25:14 48:22
49:12,16
know 18:8 19:24
knowledge 24:22
31:15 46:23
kupearion 3:5,7
31:19 40:6,14,22
42:14 43:15 44:4
44:15 47:2,23
50:11 51:6

20:5,19 25:22
morrissey 2:3,4,4
26:13,22 41:18,19
4:4 11:3,13,18
42:24 43:1
12:1,7,18 13:7,11
lockups 43:5
13:15,17 14:2,4
logan 33:23 34:2
14:19,21 15:19
long 12:24 13:4
16:1,10 17:12
15:16 17:2
21:6,12,18 22:13
longer 48:22 51:10
22:19 23:6 31:23
look 21:11 23:3
36:12,21 38:16,23
39:3,23
39:18 40:8,10,19
looking 41:5
41:4,22 42:6,19
43:20 44:8,19
M
45:5,10,17 46:2
m 1:17 3:17,18
46:12,22 47:6,10
12:17 18:5,5,20
47:12 48:3 49:5
19:18 20:5
50:4,16,23 51:11
L
madeleine 3:5
52:1,5,7,15,24
l 2:17
magistrate 15:24
motions 51:23 52:2
lapitan 2:18
march 1:16
N
lasalle 1:15 2:12
marked 4:8,10 21:4
3:5
21:7 22:17,21
n 2:1 3:1 4:1 5:1
laura 3:11,12,14
38:21 39:1,16,19
6:1 7:1 8:1 9:1
lauralaw 3:14
matters 55:9
10:1 12:17,17
law 2:2,9 3:2,11,16 mayor 29:14
name 18:9,18,24
lawsuit 20:24 23:22 mccarthy 29:20
19:24
26:5 34:12,21
36:24
named 34:12 35:1
35:7
mean 15:2
35:12,17
lawsuits 35:21 37:1 medication 12:20
net 2:6
lawyer 52:16
13:10
nod 12:1
level 28:15 31:14
member 14:7,10,13 north 1:15 2:12 3:5
license 56:10
15:5 16:17 28:17 northern 1:1 54:1
lieutenant 17:8,24
30:18 31:9 43:23 notary 54:22
28:22 29:1,15
44:21 45:19 47:19 notice 11:5
30:23,23 31:14
members 40:4,13
november 25:2,8
45:6,18 46:5,15
mischaracterizes
25:13 48:19 49:17
linda 25:3,8
36:7,16
49:20
line 5:2 6:2 7:2 8:2 misher 35:10,10
number 21:8 22:8
9:2 10:2
moment 21:11 39:4
22:21 23:2,4,8
litigation 2:11 3:4
monitoring 41:12
39:1,20 41:6
22:10 33:19,19
month 14:9
O
35:13
monthly 37:8
o 5:1 6:1 7:1 8:1 9:1
live 27:22
morask 3:11,12
10:1 12:17 55:2,2
lloyd 2:18
23:5
oath 54:10
located 42:21
morning 19:5,11
lockup 19:6,14,19
19:18 20:6 32:15 object 52:10

objection 16:5
31:19,20,21 32:1
36:6,15 40:6,7,14
40:22 41:21 42:1
42:12 43:13 44:2
44:13 45:1,9,13
45:22 46:8,17,24
47:9,21 48:24
49:23 50:10,11
objections 42:15
43:16
obligations 30:18
obtain 15:10
occasion 18:24
occurred 23:18
24:6,17
office 25:7
officer 14:15,23
15:7 16:4,12 18:8
18:13,17,18 19:12
19:13,13 26:3,3,4
28:3,15 30:6
37:23,23 44:23
45:8 46:5,15
officers 35:11
44:10
offices 2:2,9 3:2,11
3:16
okay 37:20
opportunity 21:20
23:7
option 52:20
orally 11:21
order 26:21 39:22
41:6 51:22
orders 40:3,20
org 2:15 3:7,14
outcome 55:24
outline 40:12
outside 21:12
overly 46:17
P
p 2:1,1 3:1,1
page 4:1,8 5:2 6:2

TOOMEY REPORTING
312-853-0648

7:2 8:2 9:2 10:2
22:2
pages 54:13
paid 30:5
park 3:13,19
parties 55:23
party 35:6
patrick 2:4
patrol 14:23
pay 50:18
peggy 1:14 55:3
56:8
people 3:22
period 14:22 15:3,9
15:13,16 16:11,16
17:3 51:5
person 18:24 42:7
44:23
personal 55:13
pertaining 1:12
photographed
26:16,22 41:24
phrase 11:17
physical 20:6,16
36:13
place 54:14 55:17
placed 41:19
plaintiff 1:4,10 2:8
19:19 20:7 54:4
plaintiffs 4:9,10,11
4:12,13 21:3,8,9
21:20,22 22:8,16
22:21,24 23:8
35:24 37:13 38:20
39:1,15,20 41:5
please 12:9
point 17:18 23:22
48:17,21
police 13:2,5,19,22
14:7,10,14,15,23
15:5,6,7,9,14 16:3
16:12,12,17,23
17:4,9,14,14,24
18:8,13,17 19:7
24:23 28:15,22

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 22 of 107 PageID #:1330

GLENN EVANS
March 16, 2015
Page 61
29:16,20 30:2,6
30:18,24 31:6,10
31:14 32:5,10
33:12 35:11 37:17
37:22 38:4 39:2,7
40:2,5,13,21 41:7
41:10 42:11,20
43:10,22,23 44:10
44:21,23 45:8,19
46:4,14,15 47:8
47:14,19 48:19
49:22
policies 43:9
position 15:6 16:2
16:19,22 17:8
26:12 28:22,24
29:15 52:11,13
prejudiced 51:14
prepare 38:11
prepared 22:9
37:23
presence 19:12
present 19:6
previous 55:6
previously 49:7
prior 19:23 28:16
29:21 30:22 31:16
31:18 36:24 37:13
41:23
privilege 13:13
15:22 51:2,9,17
probable 20:11
probationary 15:7
15:9,13
procedure 1:11
11:5
procedures 39:22
40:3,11 41:11
42:9 43:9,21
proceeding 52:19
proceedings 55:15
processing 42:10
43:11
promoted 16:18
17:7 28:14,21

52:10,13 55:14
reduced 55:12
refused 26:14
regards 11:14 13:8
22:7,9 23:17 24:5
24:10,10,17 25:3
25:8,13,20 26:4
29:14,21,22 34:2
37:24 38:12 42:10
43:5 45:11 48:13
48:14,20,22 49:16
50:6,8
relative 55:20,21
relevance 45:1,9,13
45:22 46:8,18
relying 52:20
Q
rephrase 12:10
qualify 28:24
40:8 47:11
question 13:8,16
report 38:4,7,12
14:3,20 15:11,20
39:2,12
20:18 23:21 31:20 reported 55:11
33:14 37:19 38:5 reporter 1:14
40:7,9,23 43:4
11:22 12:3 52:21
50:12
55:4 56:9
questions 11:20
reports 37:17,23
12:9 15:23 36:5
represented 24:4
50:24 52:22
requested 21:17
47:13
R
required 13:23
r 2:1,17 3:1 5:1 6:1
31:7
7:1 8:1 9:1 10:1
reserve 52:23
12:17
reserving 51:7,8
randall 34:10
respond 23:21
rank 15:10
26:14
read 21:17 54:11
responding 37:13
real 33:1
response 22:24
reason 36:3,13
38:3,7,11 39:2,12
reasonable 26:19
responses 11:23
recall 51:8
52:22
receive 28:6
responsibilities
received 28:10
32:9,14 39:22
receives 43:23
40:12
receiving 28:16
result 35:23
record 12:4 21:16
returns 50:6
32:1 39:4 51:7
review 21:20 23:8

30:22 31:13 36:22
promoting 31:18
promotion 28:17
proper 51:23
property 33:1
protective 51:22
provide 31:3
psychological 31:1
31:8 42:8
public 54:22
punitive 50:6,9,19
pursuant 1:11 11:5
put 51:18 52:7
putting 31:24 52:6
52:12

24:23 31:16 37:17
37:22 46:4 47:8
47:15 48:19 49:22
52:19
richardson 34:24
ridge 3:13,19
right 11:18 12:22
14:1,17 15:18
16:9,15,21 17:1,6
17:11,17,22 18:3
18:7,11,16,22
19:3,9,16,22 20:3
20:9,14,22 21:2
21:24 22:6,12,14
22:14 23:4,10,14
23:20 24:1,8,13
24:20 25:1,6,11
25:18 26:1,7,11
26:18 27:1,15,18
27:21 28:1,5,9,13
28:20 29:3,8,12
29:18,24 30:4,8
30:11,16,21 31:3
31:12 32:3,8,12
32:17,20,24 33:3
33:6,10,17,21
34:1,5,9,14,18,23
35:4,9,15,20 36:2
36:11,20 37:3,7
37:11,16 38:2,9
38:15 39:9,14
40:18 41:3,9,16
42:5,18,23 43:3,8
43:19 44:7,18
45:4,16 46:1,11
46:21 47:5,17
48:2,7,11,16 49:4
49:10,14,19 50:3
50:15,22 51:8
52:17,24
rights 2:10 3:3 43:6
rink 28:3
rita 1:3 19:1,20,24
20:7,12,16,24
22:10 23:12,17,22

TOOMEY REPORTING
312-853-0648

24:5,11,16 25:4,9
25:14,20 26:5,9
26:14,20 37:24
38:12 41:17 48:4
48:8,14,20 49:8
49:12,16 54:3
rodgers 2:17 18:18
19:13 26:4
roller 28:3
room 25:22
rules 1:11 11:14,17
S
s 2:1 3:1 4:6 5:1,1
6:1,1 7:1,1 8:1,1
9:1,1 10:1,1
saith 53:3
school 27:2,4,7,9
27:13
screening 41:12
second 21:13
security 28:2
see 18:24
seeking 51:21
seeks 15:21
sergeant 16:23
17:3 28:15 44:20
46:5,15
series 11:20
served 15:14 20:23
23:11 24:2,14,15
set 21:10,22 22:3
37:14 56:1
shes 31:24
short 21:14 38:18
shorthand 1:14
55:4 56:9
showing 21:7 22:20
38:24 39:19
sick 41:13
signature 22:4
simmons 34:19
sir 37:9,20
sit 12:20 13:10 36:4
so60102 39:23

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 23 of 107 PageID #:1331

GLENN EVANS
March 16, 2015
Page 62
sorry 47:10
south 2:5
speak 19:19
special 39:22
specific 15:1 27:5
specifically 39:10
specified 55:17
speculation 42:2,13
43:14 44:3,14
47:1,21
speculative 31:21
spoken 24:9
ss 55:1
staff 28:18
stamped 39:24
started 11:10
state 1:15 3:22 55:1
55:4
stated 55:19
statement 25:3,12
47:7,14 48:13,18
49:16,21
statements 48:22
states 1:1,12 22:22
27:10 54:1
stenographically
55:11
stocks 33:4
stop 12:9
street 1:15 2:12 3:5
43:12
strike 14:6 15:4
24:3 38:5 48:5
subject 29:4 51:22
submit 26:15,21
subscribed 54:19
sudden 51:14
suffering 42:7
suite 1:16 2:13 3:6
superintendent
29:19 30:2 34:10
36:24
sutton 2:17 18:9
19:13 26:3 37:24
sworn 11:2 12:15

14:6,10,13 15:4
16:17 54:10,19
55:8

38:15 39:9,14
40:18 41:3,9,16
42:5,18,23 43:3,8
43:19 44:7,18
T
45:4,16 46:1,11
t 2:17 4:6 5:1,1 6:1
46:21 47:5,17
6:1 7:1,1 8:1,1
48:2,7,11,16 49:4
9:1,1 10:1,1 12:17
49:10,14,19 50:3
12:17
50:15,17,22 55:8
tactical 38:3,7,11
testimony 31:4
39:2,12
36:7,16 54:16
take 11:22 21:11
55:14
23:3 28:23,24
tgmlaw 2:6
38:16 39:3,23
thats 39:6,24 51:19
52:21
52:10,13
taken 1:10,13 11:4 think 22:14
54:13 55:16
thomas 2:3,4
tell 26:19
tiffany 2:12,15
term 47:19
time 12:7 14:22
terminated 30:12
15:3,20 16:11,16
30:13
17:3,18 51:4
testified 12:15
54:14 55:17
testify 12:23 14:1
times 11:8
14:18 15:18 16:9 timothy 3:17,18
16:15,21 17:1,6
timothyblack 3:20
17:11,17,22 18:3 today 12:20 13:10
18:7,11,16,22
36:5,14
19:3,9,16,22 20:3 todays 52:19
20:9,14,22 21:2
training 13:23
21:24 22:6,12
transcribed 52:18
23:10,14,20 24:1
52:18
24:8,13,20 25:1,6 transcript 52:17,19
25:11,18,19 26:1
54:12,15 55:11
26:7,11,18 27:1
trial 25:20 50:18
27:15,18,21 28:1
51:14
28:5,9,13,20 29:3 true 54:15 55:13
29:8,12,18,24
truth 55:8
30:4,8,11,16,21
turn 22:1
31:12 32:3,8,12
two 30:13
32:17,20,24 33:3 twominute 38:17
33:6,10,17,21
twopage 39:5
34:1,5,9,14,18,23 type 12:19 13:9
35:4,9,15,20 36:2
40:20
36:11,14,20 37:3 typewriting 55:12
37:7,11,16 38:2,9

U
u 5:1 6:1 7:1 8:1
9:1 10:1
uhhuh 12:2
unable 36:4,14
50:18
undergo 30:24 31:7
understand 11:13
11:16,23 12:5,8
12:10 13:12 15:11
52:10
understanding
47:18
united 1:1,12 27:10
54:1
unknown 35:11
use 29:5 31:17
33:15 37:5 45:11
V
vague 16:5 46:17
verbal 26:9,15
verdict 50:6
versus 22:10 33:23
34:2,6,15,19,24
35:5,10,16
verus 34:10
vs 1:5 3:23 54:5
W
waive 51:16
want 52:8
watch 17:19 20:11
32:14
west 3:13,18
western 2:5
whereof 56:1
wilfredo 2:18
williams 35:5
witness 4:1 11:1,12
11:16,24 12:6,11
12:14 16:7 36:9
36:18 40:16 41:1
42:3,16 43:17
44:5,16 45:2,14

TOOMEY REPORTING
312-853-0648

45:23 46:9,19
47:3,24 49:2 50:1
50:13 55:7,7 56:1
work 28:2
working 17:23
18:13,19
written 40:11,20
41:6,11 42:9
X
x 4:1,6 12:17
Y
y 2:12
year 14:9 27:6
years 30:14
youre 13:9 36:3,14
50:18
Z
0
00 18:5,5
03170 40:1
084003813 56:10
1
1 4:9 6:8 7:17 8:8
21:4,8,20 22:8,13
22:14
10 5:22 6:4 7:10
8:16,21 9:10,12
9:17 17:23 18:20
19:5,10,18 20:5
37:22 48:4,9
10249 2:5
10th 18:4,12,19,23
19:4,11,17,23
20:10,19 23:18
24:6,18 25:15,21
26:8,13,20 32:13
38:10 41:18
11 1:17 5:8 6:11
8:11 9:14 10:18
18:5

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 24 of 107 PageID #:1332

GLENN EVANS
March 16, 2015
Page 63
11th 20:4
12 5:3,18 6:20,24
7:4,20 9:7 10:15
1251 4:4
13 1:5 5:4,5,13 7:15
7:24 8:5 9:3 10:8
10:11 35:17 54:5
14 3:23 5:5 6:16
7:11
15 5:6 6:5,12 8:17
10:19
154 54:13
16 1:16 5:6,7,8,9,9
5:10 7:5 8:22
16367 3:23
17 5:11,12,13,14,15
5:19,23 7:21 9:18
10:16,22
1753 35:11
18 5:14,16,17,18,19
5:20 8:6,12 10:6
10:12
19 5:3,21,22,23,24
6:7,21 7:3,6,16
8:18 9:13
1937 1:5 54:5
1986 13:6,20 14:12

48:4,9
2013 23:2 25:2,8,13
48:20 49:17,21
2015 1:16 54:21
56:3
21 4:9 5:4 6:7,13,17
7:12 8:7,23 9:8,24
22 4:11 5:10 6:8,9
7:7,22 8:13 9:4
23 5:15,20,24 6:6
6:10,11,12,13
10:9
2337900 2:6
24 6:14,15,16,17
8:19 9:11,21
25 6:18,19,20,21
26 6:22,23,24 7:3
262 3:19
27 7:4,5,6,7
2769 34:20
28 7:8,9,10,11,12
28th 23:2
29 7:13,14,15,16
299 34:11

3
3 4:11 8:24 9:9 10:7
22:15,17,21 23:4
2
23:8
2 4:10 5:7,11 6:14
30 1:15 2:12 3:5
6:18,22 7:8 8:14
7:17,18,19,20,21
22:15
7:22 18:20 20:5
20 1:17 6:3,4,5,6
23:2
9:15,20 10:4,20
31 7:23,24
19:5,10,18
312 2:14 3:7
2000 34:11,16
3172 40:1
2008 34:20 35:1,6
32 8:3,4,5,6,7
2010 35:11 39:10
33 8:8,9,10,11,12
2011 17:24 18:4,12
8:13
18:19,23 19:4,11 34 8:14,15,16,17,18
19:17,23 20:4,10
8:19
20:19 23:18 24:6 35 8:20,21,22,23
24:18 25:16,21
36 8:24 9:3,4
26:8,13,20 32:13 37 9:5,6,7,8
37:22 38:10 41:19 38 4:12 9:9,10,11

39 4:13 9:12,13
4
4 4:12 5:16,21 6:3
7:13 8:3,9 9:5,22
10:13 38:21 39:1
40 9:14,15
41 9:16,17,18
42 9:19,20,21
43 9:22,23,24
44 10:3,4
45 10:5,6
46 10:7,8
47 10:9,10,11,12
48 10:13,14,15,16
4824 35:1
49 10:17,18,19,20

7447684 2:14
7452837 3:19
773 2:6
7th 25:2,8,13
8
8 5:17 6:23 9:6
10:14 18:5
847 3:14
8816 33:23
9
9 6:15 7:14,19 8:4
9:23 10:3
900 1:16 2:13 3:6
923 35:17
97 33:23
98 34:6

5
5 4:13 7:18,23 8:20
9:16 10:21 39:16
39:20 41:6
50 10:21,22
5490 34:16
5576 34:6
6
6 7:9 8:15 10:5,17
11:5
60068 3:13,19
60602 2:13 3:6
60643 2:5
6919 35:6
6967185 3:14
6th 17:14,20 18:13
18:18 19:6,14
20:20 25:23 26:13
26:23 41:18 42:20
43:1,5
7
7 5:12 6:9,10,19
8:10 9:19 10:10
713 3:13,18
7445106 3:7

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 25 of 107 PageID #:1333

Transcript of the Testimony of
GLENN EVANS
Date: February 29, 2016
Case: RITA KING VS. GLENN EVANS, ET AL.

TOOMEY REPORTING

Phone: 312-853-0648
Fax: 312-853-9705
Email: toomeyrep@sbcglobal.net
Internet: http://www.toomeyreporting.com/

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 26 of 107 PageID #:1334

GLENN EVANS
February 29, 2016
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 deposition of GLENN EVANS,
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 10150 South Western
Avenue, Chicago, Illinois, on February 29, 2016
at 1:15 p.m.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 27 of 107 PageID #:1335

GLENN EVANS
February 29, 2016
2 (Pages 2 to 5)
Page 2
1
2
3
4
5
6

A P P E A R A N C E S:

WITNESS

11
12
13
14

GLENN EVANS
3
4
5
6

Appeared on behalf of the
Plaintiff;

15

Appeared on behalf of the
individual defendants:
Glenn Evans, D.T. Clifford,
R.A. Sutton, K.L. Rodgers,
Wilfredo Lapitan, and
Lloyd Gray.

17
18
19
20
21
22
23
24

DIRECT EXAMINATION BY
MR. MORRISSEY:

MARKED
EVANS EXHIBIT NO. 1
EVANS EXHIBIT NO. 2
EVANS EXHIBIT NO. 3
EVANS EXHIBIT NO. 4
EVANS EXHIBIT NO. 5

A P P E A R A N C E S:
THE LAW OFFICES OF:
CITY OF CHICAGO
FEDERAL CIVIL RIGHTS
LITIGATION DIVISION
BY: MS. CARLA MADELEINE KUPE-ARION
30 North LaSalle Street
Suite 900
Chicago, Illinois 60602
(312) 744-5106
carla.kupearion@cityofchicago.org

3
4
5
6
7
8

Appeared on behalf of the
Defendant, City of
Chicago;

9
10
11

THE LAW OFFICES OF:
QUINTAIROS, PRIETO,
WOOD & BOYER, P.A.
BY: MR. KENNETH BATTLE
MR. ANTHONY L. SCHUMANN
233 South Wacker Drive
70th Floor
Chicago, Illinois 60606
(312) 566-0040
kenneth.battle@qpwblaw.com
Appeared on behalf of the
Defendant, Glenn Evans.

12
13
14
15
16
17
18
19
20
21
22
23
24

.

PAGE
41
56
62
67
128

******

Page 3
1
2

5-212

EXHIBITS
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

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

16

PAGE

2

7

10

INDEX

1

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

8
9

Page 4

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

(WHEREUPON, the witness
was first duly sworn.)
MR. MORRISSEY: This is the
continuation of the deposition of Glenn
Evans taken pursuant to the order of the
Court. My name is Pat Morrissey. I
represent Rita King.
WHEREUPON:
GLENN EVANS,
called as a witness herein, having been first
duly sworn, was examined and testified as
follows:
DIRECT EXAMINATION
BY MR. MORRISSEY:
Q Please state your name for the
record?
A Glenn Evans.
Q Are you currently employed?
A Yes.
Q Where do you work?
A City of Chicago.
Q What is your title?
A Commander.
Q What are you the commander of?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 28 of 107 PageID #:1336

GLENN EVANS
February 29, 2016
3 (Pages 6 to 9)
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

A Police department.
Q Do you have an assignment?
A Yes.
Q Where are you assigned?
A Headquarters.
Q How long have you been a commander
assigned to headquarters?
A Since August 2014.
Q What are your responsibilities as a
commander assigned to headquarters?
A Administrative.
Q Are you texting your attorney at the
moment?
MR. BATTLE: Objection.
BY THE WITNESS:
A We're discussing -MR. BATTLE: That's privileged
information.
BY THE WITNESS:
A -- privileged information.
BY MR. MORRISSEY:
Q I didn't ask what you texted your
attorney. I asked you whether you sent your
attorney a text?

Page 8

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 But under the rules, you cannot take
a break if I have a question pending; is that
understood?
MR. BATTLE: We'll stipulate. Keep
going.
BY THE WITNESS:
A Yes.
BY MR. MORRISSEY:
Q Is that understood?
A I'm stipulating to what my attorney
stated.
Q As a commander assigned to
headquarters, what are your responsibilities?
A Administrative function. Right now,
on leave.
Q How long have you been on leave for?
A Since August 2014.
Q Since August of 2014, do you report
periodically to headquarters?
A I'm on leave now, but yes, I did.
Q What does it mean that you're on
leave?
A It means I'm not on active duty.
Q Are you currently being paid by the

Page 7
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 No, I didn't send him a text, and
it's still privileged information.
MR. BATTLE: Let's move on, Pat.
BY MR. MORRISSEY:
Q Well, Mr. Evans, I ask that if
there's a question pending that you don't
communicate with your attorney via telephone,
okay?
MR. BATTLE: We are not communicating
about a question.
BY THE WITNESS:
A We're not communicating about
anything.
BY MR. MORRISSEY:
Q Mr. Evans, when I ask you questions,
I'm going to ask that you answer them orally,
okay?
A I'm intelligent enough to articulate
my response.
Q If you want to take a break after I
ask a question and you answer it, you can do
so, okay?
A I'll take a break when I need to,
yes.

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

city of Chicago?
A Yes.
Q Are you making -- being compensated
at the rate of a commander presently?
A No.
Q What is your compensation currently?
A I don't know offhand.
Q Do you receive a periodic paycheck
from the Chicago Police Department?
A Not a paycheck, no.
Q Do you receive any form of monetary
compensation presently from the city of
Chicago?
A Yes.
Q And is that -- and why do you receive
compensation periodically from the city?
A You would have to ask them. That's
an operational -- that's an operation, not
administrative.
Q Do you receive a check from payroll
from the city of Chicago presently?
A A paycheck?
Q Correct.
A No.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 29 of 107 PageID #:1337

GLENN EVANS
February 29, 2016
4 (Pages 10 to 13)
Page 10
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 stop receiving a
paycheck from the city?
A Don't recall.
Q Was it sometime on or around August
of 2014?
A Don't recall.
Q What did you review in preparation
for today's deposition?
A Numerous documents and news articles.
Q Tell me what documents you reviewed.
A Numerous police reports, case
reports.
Q Tell me exactly which police reports
and case reports you reviewed.
A I can't tell you exactly.
Q Where did you review these documents?
A I can't tell you that exactly.
Q When did you review these documents?
A Intermittently between -- I guess
between the inception of this case and now.
Q Did you review police reports
relating to Rita King?
A I'm sorry?
Q Did you review police reports

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

accurately gauge based on those reports.
BY MR. MORRISSEY:
Q Prior to your assignments at
headquarters, where were you assigned?
A Harrison and Kedzie.
Q Where is -- Strike that. Is that a
district?
A Yes.
Q What's the district number?
A 11.
Q Tell me the months when you were
assigned to the 11th District as a commander?
A The months I was assigned?
Q Correct.
A Don't recall directly, maybe between
March to August 2014.
Q Why were you transferred in August of
2014 to headquarters?
A Why was I transferred?
Q Correct.
A Because the superintendent
transferred me there.
Q Did you have a conversation with the
superintendent why you were transferred to

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

relating to Rita King?
A Some of the reports, yes.
Q Did you review your CR files?
A Some of the reports, yes.
Q Tell me what CR files you reviewed in
preparation for today's deposition?
A I cannot tell you that.
Q What news reports did you review in
preparation for today's deposition?
A The one that sticks out in my mind is
an article from the Daily Beast that your
office submitted saying I'm Chicago's dirtiest
cop. Outside of that, I don't recall the rest.
Q How many CR files are you aware of
that you are involved with?
A Don't know offhand.
Q Is there anything that can refresh
your memory about how many times you've been -you've had citizen complaints of misconduct?
MR. BATTLE: Throughout his career?
MR. MORRISSEY: Correct.
BY THE WITNESS:
A No, because a lot of those are not
correct. So there's no real way I can really

Page 13

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

headquarters?
A Pretty much, no.
Q Were you relieved of your police
powers at that point?
A Yes.
Q Why were you relieved of your police
powers?
A Because a pending criminal charge.
Q What were you charged with?
A I was charged with -- I was falsely
charged with aggravated battery and official
misconduct with a quote on falsely.
Q Why do you say you were falsely
charged?
A Because the allegations were untrue.
Q What were the allegations?
A The allegations were aggravated
battery and official misconduct.
Q Do you recall the facts and
circumstances surrounding those charges?
A There were no facts in that charge.
They were all false.
Q Well, what were the false factual
charges, to your recollection?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 30 of 107 PageID #:1338

GLENN EVANS
February 29, 2016
5 (Pages 14 to 17)
Page 14
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 There is no such thing as a false and
factual charge. That's an oxymoron. Can you
restate that?
Q Were you charged with putting a gun
down a suspect's throat?
A Yes.
MR. BATTLE: Objection to relevance.
It has nothing to do with this case at all.
It has nothing to do with even the Monell
claims.
BY MR. MORRISSEY:
Q You can answer the question.
MR. BATTLE: Go ahead. You can
answer.
BY THE WITNESS:
A Yes.
BY MR. MORRISSEY:
Q And was that suspect's DNA found on
your gun?
MR. BATTLE: Same objection to
relevance. It has nothing to do with this
case. It is completely irrelevant. It has
nothing to do with the Monell claims at
all.

Page 16

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

it into my ear like your father is doing
into your ear and then I'll object? We'll
be here all night.
MR. MORRISSEY: That's fine.
THE WITNESS: That works for me.
MR. SCHUMANN: I'm still waiting for
the rule.
MR. MORRISSEY: It's not my
deposition.
BY MR. MORRISSEY:
Q You can answer, Mr. Evans.
MR. SCHUMANN: I'm still waiting on
the rule.
MR. BATTLE: There's no rule that
says that, Counsel. Did you know that?
THE WITNESS: If there's no rule, am
I obligated to answer?
MR. BATTLE: You can answer.
BY THE WITNESS:
A Restate the question.
BY MR. MORRISSEY:
Q Was your -- Was the suspect's DNA
found on the gun, your gun, that caused -A Based upon the lies --

Page 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. SCHUMANN: It's also not
calculated to lead to relevant information.
MR. MORRISSEY: Let's not -- During
this deposition, I would ask that only one
attorney for Mr. Evans make the objections,
okay?
MR. BATTLE: You can ask.
MR. MORRISSEY: Well, under the
rules, only one attorney should be
representing, making speaking objections.
MR. SCHUMANN: What rule is that?
MS. HARRIS: And just for the record,
we represent the other defendants. Every
attorney here has a right to make an
objection. Ms. Kupe-Arion is here for the
city.
BY THE WITNESS:
A These are all of my attorneys, so I'm
going to be taking their advice and their
counsel.
MR. MORRISSEY: I'm going to ask that
only one attorney for Mr. Evans make
objections.
MR. BATTLE: Do you want him to speak

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

Q

Let me ask the questions.
MR. BATTLE: Hold on. Just hold on.
THE WITNESS: All right.
BY MR. MORRISSEY:
Q Mr. Evans, was that suspect's DNA
found on the barrel of your gun that caused you
to be reassigned from the 11th District to
police department headquarters, to your
knowledge?
A I don't know what kind of evidence
they found on there. A lot of it was falsified
evidence and contrived evidence. So I couldn't
answer that.
Q Did you have a conversation with
Superintendent McCarthy prior to your
reassignment to police department headquarters?
A Did I have a conversation with him?
Q Correct.
A I've had multiple conversations with
the superintendent.
Q I'm asking specifically when you were
transferred from the 11th District to police
department headquarters?
A I've had multiple conversations with

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 31 of 107 PageID #:1339

GLENN EVANS
February 29, 2016
6 (Pages 18 to 21)
Page 18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

him.
Q Regarding why you were transferred?
A Why I was transferred from the 3rd
District to the 11th District?
Q From the 11th District to police
department headquarters?
A No, he didn't give me a specific -that I can recall, we didn't have a specific
conversation regarding that, not that I can
recall.
Q What did the superintendent tell you
about your reassignment?
A He said that I was stripped and
charged, and I had to go to headquarters; and
that's the extent of the conversation that I
can recall.
Q Who were you reporting to when you
went to headquarters as a commander?
A Who was I reporting to?
Q Correct.
A Report to the office of the first
deputy.
Q And who was the first deputy?
A It was Alfonzo Wysinger at the time.

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

A For the police department, no.
Q Why not?
A Because I was told not to carry a
weapon.
Q Who told you not to carry a weapon?
A That was a written directive by the
police department.
Q Did the written directive say why you
were not allowed to carry a firearm?
A Yes, due to the charges that were
falsely brought against me.
Q The charges were terminated in your
favor, correct?
A The charges were not terminated. The
charges were found -- I was found not guilty on
all nine charges.
Q Did you request to have the ability -Strike that. Do you presently -- Strike that.
Do you presently hold the rank of
lieutenant?
A That's my career service rank, yes.
Q Have you ever had a conversation with
Mr. Escalante regarding -- Strike that.
How long have you worked for the

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

Q Mr. Evans, do you presently report to
First Deputy Wysinger?
MR. BATTLE: Do you understand that
question?
BY THE WITNESS:
A Do I presently report to him?
BY MR. MORRISSEY:
Q Correct.
A No.
Q Who do you presently report to?
A I report to the office of the first
deputy.
Q And who is the first deputy
presently?
A The office of the first deputy would
be Escalante.
Q Mr. Evans, have you asked Chief
Escalante to be reinstated as a commander?
A Not as of yet, no.
Q Are you eligible -- Do you have
police powers presently?
A No.
Q Do you have the ability to carry a
weapon presently?

Page 21
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

police department?
A I'm sorry?
Q How long have you worked for the
Chicago Police Department?
A How long have I worked for the
Chicago Police Department? Since July of '86.
Q When you were the commander of the
11th District, to your knowledge, did any
citizens file a complaint against you?
A I have not been served with any
complaints regarding the 11th District.
Q As a commander in the 11th District,
did you participate in the Command Channel
Review of CR files?
MR. BATTLE: Of other police
officers?
BY MR. MORRISSEY:
Q Correct.
A Yes.
Q As the commander of the 11th
District, tell me your responsibilities as a
participant in the Command Channel Review of
another officer's CR file.
A That's a convoluted question. I

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 32 of 107 PageID #:1340

GLENN EVANS
February 29, 2016
7 (Pages 22 to 25)
Page 22
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

can't respond to that. You'll have to simplify
it.
Q When you were the commander of the
11th District, were you provided any training
about how to conduct a Command Channel Review?
A Did I provide any training?
Q I asked you were provided any
training by the city of Chicago Police
Department regarding how to conduct a Command
Channel Review of another officer's CR file?
A Are you saying as a commander of the
11th District, was I provided any training?
Q Correct.
A As a commander in the 11th District?
Q Correct.
A No, just as the commander of the 11th
District.
Q Describe what training you have had
regarding a Command Channel Review of another
police officer's CR file?
A That's a broad question, and I really
don't know how to answer that.
Q Did you have any formal training
where a superior officer told you about how you

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

directives relating to how long you as a
commander would have to review and make a
recommendation on a CR file of another officer?
A That's another multifaceted question
that I have problems comprehending.
Q After you receive a CR file from
IPRA, what would you do?
A I'd review it.
Q And how long would it typically take
you to review the CR file?
A It depends.
Q Would there be a time limit where you
would have to make a decision based on your
review of a CR file?
A I'm going to say that there is a time
limit to every report that requires your
action.
Q After that time period expired, what
would you do?
A After that time limit expired -- I
couldn't answer that because I always completed
my -- To my recollection, I always completed my
investigations in a timely manner.
Q When you were the commander of the

Page 23
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

as a commander would participate in a Command
Channel Review of another police officer?
A You make these convoluted extraneous
questions that I cannot articulate because you
lump multiple queries into one string-on
question; because I cannot answer those, you'll
have to condense them in a fashion that I can
answer those questions.
Q When you were the commander of the
11th District, what would you do if you
received a CR file from IPRA where a
recommendation for discipline was made?
A I would review it.
Q Would there be a time period where
you would have to complete your review of the
sustained CR finding?
A There's a time period that you have
to -- Generally, there's a time period to
everything that comes across your desk.
Q As a commander, how much time would
IPRA provide you to review a CR that they
deemed a sustained finding?
A IPRA doesn't issue me directives.
Q Does the city of Chicago issue you

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

11th District, on average per month, how many
CR files would you review?
A I couldn't tell you that. It varies.
Q Can you give me a range?
A No.
Q What were your responsibilities as a
commander in the 11th District?
A Ensure, manage police, public safety
and police responses to a geographic area.
Q Prior to working in the 11th
District, where were you assigned?
A Prior to working in the 111th
district?
Q Correct.
A The 3rd District.
Q Where is the 3rd District?
A Physically?
Q Correct.
A 7100 South Cottage Grove -- 7030
South Cottage Grove -- or 7040 South Cottage
Grove.
Q How long were you the commander of
the 3rd District?
A I was the commander of the 3rd

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 33 of 107 PageID #:1341

GLENN EVANS
February 29, 2016
8 (Pages 26 to 29)
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

District from August, I believe, 2012 to -- I
don't really recall. I think March of 2014.
That's just a guesstimate like most of my
responses are, so don't hold me to those.
Q You understand you're under oath
today, correct?
A That's exactly why -- which is why
I'm not going to lie. I'm going to tell you
the truth as I recall.
Q What were your responsibilities as
commander in the 3rd District?
A The same as they were for the 11th
District.
Q And when you were commander of the
3rd District, did you participate in the
Command Channel Review?
A Did I participate in the Command
Channel Review?
Q Of CR files, yes.
A Yes.
Q Prior to your assignment in the 3rd
District, what was your position?
A Prior to my assignment to the 3rd
District?

Page 28
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 were you interviewed by the
superintendent?
A Sir, I don't recall.
Q Where did the interview occur?
MR. BATTLE: You said where?
MR. MORRISSEY: Yeah.
BY THE WITNESS:
A I think it was in his office.
BY MR. MORRISSEY:
Q And who was the superintendent?
A That would be Superintendent
McCarthy.
Q Who was present during this
conversation with you and Superintendent
McCarthy?
A Who was present in that office? I
don't know. People were walking in and out of
that office, so I couldn't tell you who was in
there during the entire duration of the
interview.
Q Other than you and Superintendent
McCarthy, can you tell me anybody else who was
present during this conversation?
A I don't remember at this point.

Page 27
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 Correct.
A I was a lieutenant in the 6th
District.
Q Tell me time periods when you were a
lieutenant in the 6th District?
A Roughly, and don't hold me to this
because my memory isn't what it used to be, I'm
going to say from maybe May, June 2006 to
approximately August 2012.
Q Did you request to be promoted to
commander?
A Did I request a promotion to
commander?
Q Correct.
A Not that I recall.
Q Do you know if a commanding officer
recommended you, the superintendent's office,
to be commander?
A To be honest, I don't know how that
process went.
Q Were you interviewed prior to your
promotion to commander by the superintendent of
police?
A Yes.

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

Q Do you recall what was discussed
during this interview?
A I have very, very, very, very vague
recollections.
Q Tell me about what you do remember.
A He asked me about the command
position, would I be willing to take it and I
think he gave me a brief overview of what his
expectations were.
Q What were his expectations?
A Manage the district, address crime
conditions and manage the district.
Q Did you have a conversation with
Superintendent McCarthy regarding the number of
times you have been complained about by other
citizens for using excessive force?
A No, I don't recall having any
conversations. It possibly could have
happened, but I don't recall. I'm not going to
say yes or no. I just don't recall at this
point.
Q Is there anything that could refresh
your memory whether you had a conversation with
Superintendent McCarthy about allegations by

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 34 of 107 PageID #:1342

GLENN EVANS
February 29, 2016
9 (Pages 30 to 33)
Page 30

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

other citizens that you used excessive force?
A A transcript of our conversation or
tape recording or a videotape recorder.
Q Do you know whether the conversation
was recorded?
A I don't know. I doubt it. I don't
recall. I don't know what goes on in his
office. I don't know anything he's got, if
anything.
Q And this conversation would have
occurred before August of 2012?
A Yes.
Q Do you know whether it was the
summertime in 2012 when this conversation
occurred?
A Was it the summertime in 2012?
Q Correct.
A I don't recall when the conversation
was.
Q How long after this conversation were
you promoted to commander?
A I don't recall. I don't recall the
timeframe.
Q When you had this conversation with

Page 32
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 Is that an acronym you use in the
police department?
A Yes.
Q What is that referred to as?
A Within the Chicago Police Department,
it would be the Internal Affairs Division.
Q Do you know who presently is the
commander of IAD?
A There's a commander of IAD. Do I
know presently who is commander of IAD?
Q Correct.
A There's two commanders in IAD.
Q Tell me who the commanders are.
A One is Robert Klinus (phonetic). The
other is Brendan Deenihan.
Q Do you know whether IAD conducts
reviews of officers' CR files?
A I have never been assigned to IAD, so
I cannot advise you as to their protocols.
Q I'm not asking what the protocol is.
I'm asking, to your knowledge, do you know
whether IAD reviews CR files?
MR. BATTLE: That's exactly what
you're asking him.

Page 31
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Superintendent McCarthy regarding a promotion,
had you been named as a defendant in lawsuits
arising from your work as a police officer?
A Had I been named prior to the
conversation with McCarthy?
Q Correct.
A Yes.
Q All right, how many times were you
named as a defendant?
A I don't recall.
Q More than one?
A I don't recall, possibly.
Q Is there anything that would refresh
your memory about how many times you had been
named as a defendant prior to this conversation
you had with Superintendent McCarthy?
A If the documentation is correct, it
would but there's a lot of erroneous
documentation out there. So I can't answer yes
or no to that.
Q Do you know whether IAD -- I'll
rephrase. What is IAD?
A That depends on what context you're
talking in. Those are acronyms.

Page 33
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 I'm going to stand by my previous
response.
BY MR. MORRISSEY:
Q Well, you can state it again.
A Well, I'm going to stand by my
previous response. I was never assigned to
IAD, and I cannot tell you what their protocol
is.
Q Prior to your promotion to commander,
do you know whether IAD ever conducted any
investigation into you?
A That's a broad question. I don't
know what you mean, did they conduct any
investigation. It depends.
Q Regarding allegations of misconduct
by you.
A Prior to my promotion, yes.
Q Tell me about the circumstances where
you're aware that IAD conducted an
investigation on you?
A I cannot tell you about any
particular circumstances because I don't have a
recollection of all of them.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 35 of 107 PageID #:1343

GLENN EVANS
February 29, 2016
10 (Pages 34 to 37)
Page 34
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 How were you made aware when IAD
investigated you for allegations of misconduct?
A They would request an interview or
they'd request that I submit a report.
Q Do you know whether IAD ever
recommended disciplinary charges against you?
A Within what timeframe?
Q During your entire time with the
police department?
A Yes, probably.
Q Do you know how many times?
A No, I don't.
Q Do you know what type of discipline
IAD -A No, I don't recall.
Q Let me ask the question, Mr. Evans.
MR. BATTLE: Hold on one second. You
don't have to raise your voice, Counsel.
THE WITNESS: Yeah, you're real
disrespectful.
BY MR. MORRISSEY:
Q Do you know what discipline IAD
recommended for you?
A It varied.

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

Q Prior to me saying that, were you
aware that IPRA conducted an investigation -had an open investigation regarding Rita King?
A Yes. I know they had an open
investigation.
Q How do you know?
A You just said it.
Q Prior to me saying it, were you aware
that Rita King caused IPRA to open an
investigation based on allegations of
misconduct by you?
A I don't know if Rita King caused it
because sometimes attorneys and other personnel
will encourage her. So I don't know what Rita
King caused.
Q Are you aware that IPRA recommended
that you be suspended 15 days?
MR. BATTLE: Objection, asked and
answered. Are we going to go over every
question twice?
BY THE WITNESS:
A I'm going to stand by my last
response.

Page 35
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 Tell me what it varied on.
A It depends. Same type of discipline
they recommend for everybody. It can go from
no violation noted to discharge.
Q To your knowledge, did IAD ever
recommend that you be suspended?
A Yes, probably.
Q How many times?
A I can't tell you.
Q Do you recall why they recommended
you be suspended?
A Once again, you're asking me to make
a determination about the policy and practices
of IAD, which I am not equipped to make.
Q Are you aware that there's an open
IPRA file based on allegations that you used
excessive force on Rita King?
A Yes.
Q Are you aware that originally they
recommended that you be suspended 15 days?
A No, I didn't know that.
Q How did you become aware that IPRA
has an open investigation on you?
A You just said it.

Page 37
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 Can you answer the question?
A I'm going to go by my last response.
I answered your question.
Q Unless your attorney advises you not
to -MR. BATTLE: He just answered your
question, Counsel. You may not like the
answer, but he just answered your question.
MR. THOMAS MORRISSEY: Please don't
raise your voice.
MR. BATTLE: Counsel -MR. THOMAS MORRISSEY: Please don't
raise your voice.
MR. BATTLE: Your attorney just
indicated that this is going to be me and
him. So if he's going to be the one
representing Rita King, then I'm going to
be the one representing Glenn Evans.
MR. MORRISSEY: Well, then I ask -MR. THOMAS MORRISSEY: I'm an
attorney of -MR. BATTLE: And when I asked him not
to raise his voice, he continued to raise

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 36 of 107 PageID #:1344

GLENN EVANS
February 29, 2016
11 (Pages 38 to 41)
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

his. So I'm going to continue to raise
mine. Now, we can all quiet down together.
THE WITNESS: And I'm going to follow
the advice of my counsel.
MR. BATTLE: Hold on. I'm sorry?
MR. THOMAS MORRISSEY: I'm going to
ask you not to raise your voice in my
office.
MR. BATTLE: And I don't mind you
being involved with respect to this
deposition. Similarly, your co-counsel
shouldn't mind my co-counsel being
involved. Now, we're going all be involved
or we're not. He can speak for himself and
tell me not to raise my voice.
MR. THOMAS MORRISSEY: I'm just
raising an objection to your conduct in
raising your voice and screaming at my
co-counsel.
MR. BATTLE: And for the record -MR. THOMAS MORRISSEY: I'm not
intervening in the question of Mr. Evans at
all.
MR. BATTLE: Fair enough. Your

Page 40
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 Mr. Evans, are you aware that during
the Command Channel Review, the recommendation
from IPRA about your 15-day suspension was sent
back to IPRA?
A No, I don't.
Q Do you know the status of the IPRA
investigation relating to allegations of
misconduct by you to Ms. King?
A No.
Q Before we got into this discussion, I
was asking you about times when you've been
suspended by the police department. Do you
remember me asking those questions?
A Yes.
Q And I believe you said you didn't
recall how many times you had been suspended as
a member of the police department?
A That's correct.
Q If I show you some CR files, would
that refresh your memory about the
circumstances and the number of times you have
been suspended by the police department?
A Well, seeing how a lot of them are

Page 39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

objection is duly noted. So hopefully we
won't mind if my co-counsel has an
opportunity to object as well.
MR. MORRISSEY: That's not how this
is going to go. I'm going to continue
asking the questions. You can continue
making the objections.
BY MR. MORRISSEY:
Q Mr. Evans, are you aware that -MR. BATTLE: I do want to make one
thing for the record, Counsel. When he
answers your question, if he says that I
stand by my previous response to your
question, I think that's a fair answer to
your question. You may not like it, but I
think that's fair and I think he has a
right to do that.
MR. MORRISSEY: Well, the objection
would be asked and answered. Typically the
deponent answers again.
MR. BATTLE: He says I stand by my
last answer. I think that's a fair answer.
MR. MORRISSEY: All right.
MR. BATTLE: Okay, go ahead.

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

incorrect and erroneous, they might not.
MR. MORRISSEY: Why don't we mark
this as Exhibit 1.
(WHEREUPON, Evans Exhibit
No. 1 was marked for
identification.)
BY MR. MORRISSEY:
Q Mr. Evans, I'm showing you what's
been marked as Exhibit 1, which is a CR file.
It's a sustained CR file. Why don't you take a
moment to look at this. Let me know when you
are ready to answer questions about it.
MR. BATTLE: Do you want him to take
a look at the whole thing?
MR. MORRISSEY: Sure.
THE WITNESS: Yeah, I'll look at the
whole thing (indicating).
MR. BATTLE: Answer his question
first, and then we can take a break if we
need to.
THE WITNESS: Okay.
MR. BATTLE: Counsel, do you have
general questions or something specific to
a page?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 37 of 107 PageID #:1345

GLENN EVANS
February 29, 2016
12 (Pages 42 to 45)
Page 42
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. MORRISSEY: Well, do you want me
to start asking the questions?
MR. BATTLE: Okay, go ahead. He's
going to ask you a question.
THE WITNESS: Okay, I'm going to take
notes first.
BY MR. MORRISSEY:
Q Mr. Evans, prior to today, did you
have an opportunity to review this CR file?
A Not in its entirety.
Q Which portions of the CR file have
you reviewed?
A Vaguely the front page. Let me see,
a partially blurred out front page from the
18th of January, second page from 18 January,
which is partially blurred out, another
partially blurred out page, that would be page
3, another partially blurred out page I would
think would be page 4, another partially
blurred out page, which is page, I don't know,
7 but it's got Attachment 31, another blurred
out page which is another Attachment 31. It
looks like each one of these pages have
partially obliterated print or blurred out. So

Page 44
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

just make sure we get an understanding.
You and I are going to do the objecting?
MR. MORRISSEY: Correct.
MR. BATTLE: Are you sure?
MR. MORRISSEY: I don't have to
repeat myself. I said yes.
MR. BATTLE: You ask him to repeat
himself all the time, Counsel. I'm just
making sure. With respect to the
objection, what we are objecting to is just
the age of this report. It's irrelevant.
It's 22 years old when the actions took
place, and it's wholly and completely not
calculated to lead to anything
discoverable. It's just an abuse of the
discovery process basically.
MR. MORRISSEY: That's fine.
BY MR. MORRISSEY:
Q Does this Exhibit 1 reflect that you
were originally recommended a 30-day suspension
without options?
MR. BATTLE: Same objection. Also,
the report speaks for itself.

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

it's hard for me to really decipher as to the
entire contents of this report.
Q When did you review these documents?
A Just now.
Q Prior to coming here today, have you
seen this document?
A No, I haven't.
Q From looking at this Exhibit 1, does
it reflect that you -- IPRA originally
recommended that you be provided a 30-day
suspension without options?
MR. SCHUMANN: I'm going to object.
MR. MORRISSEY: We already agreed to
have one attorney for Mr. Evans make the
objections.
MR. BATTLE: Excuse me. No, we
didn't agree on that, and I think you're -Never mind. Hold on a second.
BY THE WITNESS:
A I cannot read and I cannot decipher
this, so I cannot respond.
MR. SCHUMANN: Glenn.
THE WITNESS: I'm sorry.
MR. BATTLE: So moving forward, let's

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

BY THE WITNESS:
A From what I can decipher, and that's
not much, I can see -- I can barely see -- I
could see 30 days and I can't see much else on
this.
BY MR. MORRISSEY:
Q Well, after 30 days bold without
options; do you see that on the second page?
A No. Okay, on the second page I see
that.
Q What does that mean "without
options," to your understanding?
A That means that you don't have any
options to use discretionary time. You just
have to take the whole suspension.
Q Do you recall in January of '95 being
recommended to have a suspension for 30 days
without options?
A Based on that report, yes.
Q What caused you to be suspended for
30 days?
A IPRA's incompetence and OPS'
incompetence.
Q Can you elaborate more?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 38 of 107 PageID #:1346

GLENN EVANS
February 29, 2016
13 (Pages 46 to 49)
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

A They made a mistake investigating
that case. They made a bunch of errors
investigating that case. In fact, to my
recollection, I'm going to say that the
investigator in this case was subsequently
terminated for child molestation, and I cannot
determine -- I cannot decipher a lot of this
but a lot of this is incorrect. A lot of this
is erroneous and let me see. They even got my
name misspelled on one page. So a lot of this
is rife with errors and whatcha call it.
Q You don't have to give me back the
exhibit.
A Okay.
Q Why don't we go to the fourth page of
Exhibit 1, which is a Summary Report and the
Subject, Complaint Register Investigation
Number is 211641, and above that number, it
says Sustained; do you see that?
A Yes.
Q And there's an allegation at the
bottom of the page, and your name is in the
middle of the page as the accused officer; do
you see that?

Page 48
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 I vaguely remember. There's some
parts of this I remember, and that's because
how bad the investigation was and the
investigator.
BY MR. MORRISSEY:
Q What do you recall about these
allegations?
A That due to all of the -- due to the
errors and the issues with the investigator
that they had knocked this down from a 30 to
15-day suspension.
Q Do you recall the allegations from
Mr. Williams on August 27th, 1994?
A Do I recall them?
Q Correct.
A You mean prior to getting here?
Q I'm asking you whether you have any
recollection of August 27th, 1994 and the
allegation Mr. Williams has against you?
A Do I have any recollection -- any
independent recollection outside of this
document?
Q Sure.

Page 47

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 Yes.
Q And under the allegation box, it
talks about Mr. Williams' alleged that on 27
August '94, you physically abused him by
striking him about his body, struck him on his
head with a gun, kicked and punched him and
maced him. It is further alleged that Officer
Evans pointed a gun at two subjects telling
them to, quote, get the fuck back or I will
kill you; do you see that?
A Yes.
Q Do you recall those allegations being
made against you in 1994?
MR. BATTLE: I'm just going to make
the same running objection to the relevancy
of these documents. They're stale.
They're old. They're more than 20 years
old. They have nothing to do with the
Monell claims, the underlying claim that
Rita King has against Mr. Evans, which we
haven't gotten to as of yet. And I think
it's wholly an abuse of the discovery
process. You can answer, if you remember.

Page 49

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 No, just which I see here.
Q It seems like you do have some
independent recollection about how poor the
investigation was by OPS, correct?
A I can look at it and recall how bad
it is.
Q Other than the actual report, which a
portion of it is in front of you, do you have
any other recollection about how poor this
investigation or investigator was?
A Not that I can recall but not at this
time, but I do recall how bad this
investigation was.
Q How do you know the investigator was
charged with child molestation?
A It was in the paper.
Q And who was the OPS investigator?
A According to this, it was William
O'Neil.
Q In your experience as a member of the
police department, did OPS conduct poor
investigations routinely?
A Yes.
Q Tell me why you base that -- you have

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 39 of 107 PageID #:1347

GLENN EVANS
February 29, 2016
14 (Pages 50 to 53)
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
24

that opinion?
A I have the opinion like I have
anything else, predicated on experience and
observation. It doesn't necessarily mean my
assessment is correct. That's just my opinion.
Q Have you talked with other members of
the police department about how poor OPS was at
investigating allegations of misconduct?
A You mean specifically or generally or
what do you mean?
Q Well, let's talk about generally.
Have you had general conversations with other
members of the department about how poor OPS
was at conducting investigations?
A Yes.
Q Who did you talk with?
A I don't recall, thousands of them.
Q When you say thousands of them -A Thousands of officers that I have
encountered over my career. We've had talks
about it.
Q OPS evolved into IPRA, correct?
A If you want to call it evolving, yes.
Q Would you agree that it transformed

Page 52
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 Why do you say they had a lot of
problematic investigations?
A Just based on the volume of the -based on the investigations and the limited
knowledge and the limited information I have
regarding quite a few investigations, and I
mean a limited, a cursory knowledge of what I
have, I think that OPS, just like any other
agency, has room for improvement.
Q Did you talk to other members of the
department about how you thought IPRA had a lot
of problems with investigating police officers?
A Did I talk to any member of who?
Q The police department regarding your
view that IPRA, at times, would conduct lousy
investigations?
MR. BATTLE: Regarding his personal
opinion?
BY THE WITNESS:
A Informally, regarding my personal
opinion, informally, I have done that, yes.
BY MR. MORRISSEY:
Q Did you ever talk with people from
the 6th District about how lousy IPRA was with

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

into IPRA?
A I mean, it was operationally changed
in IPRA. I don't know what you mean by evolved
and transformed, but it was an operational
change to my recollection.
Q To your knowledge, was IPRA an
improvement from OPS?
A I am not in a position to make that
determination if it was an improvement or not.
Q Do you have an opinion that IPRA
conducted poor investigations of police
officers for allegations of misconduct?
MR. BATTLE: Police officers in
general or him?
MR. MORRISSEY: Police officers in
general.
BY THE WITNESS:
A Do I have an opinion?
BY MR. MORRISSEY:
Q Correct.
A I have an opinion that they have
problematic investigations. They have some
good ones, and they have a lot of problematic
ones, just like anything else.

Page 53
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

conducting investigations?
A That's a big broad question. I can't
answer that.
Q Is there anything that would refresh
your memory whether you had conversations with
people from the 6th District regarding the
incompetence of IPRA at times?
A Tape-recorded or documented reports?
Q I'm not talking about tape-recorded.
I'm asking whether you -A I know what you're not talking about.
Despite my gender, I am quite intelligent. Not
my gender, I'm sorry, my race. I am quite
intelligent. I know that you might have a
problem with that, but I am and my response is
I cannot recall making any comment to the 6th
District personnel regarding these
investigations as we sit here.
Q When you worked in the 6th District,
did you have the opinion that IPRA at times
conducted lousy investigations of police
officers?
A What do you mean did I have the
opinion?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 40 of 107 PageID #:1348

GLENN EVANS
February 29, 2016
15 (Pages 54 to 57)
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

Q Well, you said that, at times, IPRA
had a lot of problems with investigating police
officers, correct?
A I said IPRA has operational
challenges and a lot of problems.
Investigations -- a lot of their problems -Investigations were problematic. Just like any
other profession, you have got some real good
ones, and they've got some real bad ones, just
like any other profession.
Q Getting back to the CR that's marked
as Exhibit 1, do you recall the suspension
being reduced from 30 days to 15?
A Yes.
Q Why was it reduced?
A Because of the problems inherent in
this investigation.
Q Did you agree to a 15-day suspension?
A Did I agree to it?
Q Correct.
A That was pretty much out of my hands.
They told me that was the way it was going to
go.
Q Did you have an attorney represent

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

Q Prior to this CR, tell me the other
times when you were suspended as a member of
the department?
A I don't recall.
Q Do you recall being suspended on
multiple times in early 1990?
A No. It's possible but I don't
recall.
MR. MORRISSEY: I have a document
which is marked FCRL 5848 all the way up to
5852 and it's from April of '92. I'm going
to mark it as Exhibit 2.
(WHEREUPON, Evans Exhibit
No. 2 was marked for
identification.)
MR. BATTLE: Are you planning on
asking questions about this?
MR. MORRISSEY: Yes.
MR. BATTLE: All right, I'll just
make a running objection to this exhibit
and any questions about it as being almost
24 years old, stale, irrelevant, has no
bearing on this case, the underlying claims
against Glenn Evans from Rita King or the

Page 55
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

you during this CR investigation?
A I believe I had union representation.
I don't recall an attorney.
Q Did you have the ability to appeal
the 15-day suspension to the police board?
MR. BATTLE: Do you understand the
question?
BY THE WITNESS:
A I don't believe that -- I don't
recall having that option at that time. You're
talking about 20-something years ago.
BY MR. MORRISSEY:
Q Was this the first time you were
suspended from the police department?
A No.
Q Was this the last time you were
suspended from the police department?
A No.
Q And from looking at the first page of
Exhibit 1, does it reflect that the suspension
occurred around March of 1995?
A No.
Q When were you suspended?
A I don't recall.

Page 57
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

underlying Monell claims.
BY MR. MORRISSEY:
Q Sir, do you see this document marked
Exhibit 2, which the first page looks like an
IAD April 8, '92 memo?
A I see a document that's partially
obscured. My name and the contents and the
text are partially obscured on the first page,
and the bottom paragraph I guess that's -- my
name is partially obscured. My star is
partially obscured. The violations are
partially obscured. The word suspended is
partially obscured, and that's on the first
page.
Q All right. What is Rule 6?
A I don't know. I would have to review
the rules.
Q Do you know whether there is a
Chicago Police Department Rule 6?
A Do I know that one exists?
Q Yes.
A Possibly.
Q Do you know what it is?
A Once again, I'm going to say I'll

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 41 of 107 PageID #:1349

GLENN EVANS
February 29, 2016
16 (Pages 58 to 61)
Page 58

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

have to review it.
Q Why don't we look at the fourth page
where it says there's an Allegation Number 1
sustained against you when you were in the 6th
District for violation of Rule 6; do you see
that?
MR. BATTLE: Where exactly are you
pointing?
MR. MORRISSEY: Under the Findings.
BY THE WITNESS:
A Once again, it's partially blocked
out and everything is hard to read.
BY MR. MORRISSEY:
Q Do you see where it says 04 June,
1991?
MR. BATTLE: Do you see it?
THE WITNESS: See how mine is all
blanked out and everything.
MR. BATTLE: Counsel, his copy is not
a good copy.
MR. MORRISSEY: I believe the city
Bates stamped them and watermarked -MR. BATTLE: My copy is actually
better than his copy is what I'm saying to

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

entire context of this suspension. It's
possible.
Q Do you know whether this was the
first time you were suspended as a member of
the police department?
A I don't recall. Don't remember,
don't recall.
Q So far, we have talked about Exhibit 1,
which was the 15-day suspension, and Exhibit 2
which reflects a two-day suspension. Do you
recall any other suspensions as a member of the
police department?
A Do I recall them offhand?
Q Correct.
A No, but I see some reports that can
refresh my recollection.
MR. BATTLE: Are you finished with
this one?
MR. MORRISSEY: Sure.
BY MR. MORRISSEY:
Q Do you recall an incident from May of
1992 where you were alleged to have failed to
follow proper police department procedures
involving the handling and inventorying of

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

you.
MR. MORRISSEY: Why don't you look -MR. BATTLE: Do you want him to look
at my copy?
MR. MORRISSEY: Yes.
MR. BATTLE: Do you want to re-ask
your question just so we have got something
on the record?
BY MR. MORRISSEY:
Q In the Finding section, it says that
you violated Rule 6 because you failed to
appear to testify; do you see that?
A Yes.
Q And it has a date of 04 June 1991; do
you see that?
A Yeah, that's approximately, what,
that's almost 20, 25 years ago. I see it.
Q And it reports that you were
suspended for two days, correct?
A Yes.
Q Do you remember being suspended as a
result of failing to appear in court in June of
1991?
A It's possible, but I don't recall the

Page 61

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

property recovered at the scene of a homicide?
MR. BATTLE: Objection, irrelevant
and not reasonably calculated to lead to
discoverable evidence. It's stale and has
no burying on this case at all or the
underlying allegations Ms. King has against
Mr. Evans or the Monell claims against the
city of Chicago.
BY THE WITNESS:
A No.
BY MR. MORRISSEY:
Q Have you ever been disciplined for
using profanity as a member of the police
department?
MR. BATTLE: Ever?
BY THE WITNESS:
A You mean ever?
BY MR. MORRISSEY:
Q Yeah.
A It's possible.
Q Do you recall ever being disciplined
for using profanity?
A I don't recall but it's possible.
Q Do you know what Department Rule 8

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 42 of 107 PageID #:1350

GLENN EVANS
February 29, 2016
17 (Pages 62 to 65)
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

is?
A No, not offhand.
MR. MORRISSEY: Why don't we mark
this Exhibit 3.
(WHEREUPON, Evans Exhibit
No. 3 was marked for
identification.)
BY MR. MORRISSEY:
Q I'm showing you what's marked Exhibit
3, which is a CR that dates to -- or a
Suspension Notification is the first page from
16 October 1992?
MR. BATTLE: Counsel, I will just
make a running objection now with respect
to relevance. The questions you may ask
are not reasonably calculated to lead to
the discovery of admissible evidence. This
is discovery abuse, harassing in nature and
none of this information will be admitted
at trial. Go ahead.
BY THE WITNESS:
A I can recall this incident now that I
read it. Now that I can read it and I have a
very clear copy for once, I can recall this.

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

Q And you recall that being the
allegation that you said to this court clerk,
correct?
A Based on the report that you gave me,
yes.
Q And did you have an attorney when you
had these allegations against you?
A Not that I can recall. I doubt it.
Q Were you entitled to an attorney
under your police union rules?
A Entitled to representation.
Q Do you know whether you had
representation?
A I don't recall if I had
representation or not.
Q And based on these allegations, you
were suspended for one day?
A Let me see. Yes. Give me a minute.
Q Sir, are you currently married?
A Am I currently married?
Q Correct.
A No.
Q Have you been married before?
A Yes.

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

BY MR. MORRISSEY:
Q It says that there was an incident on
16 March 1992; is that right?
A That's correct.
Q What happened that day relating to
this CR?
A What happened that day? Well, I went
to court, and I was alleged to have used foul
language; and it was an allegation brought
against me.
Q Do you know who brought that
allegation against you?
A Do I know her personally?
Q Do you know who made the allegation
that you used profanity?
A It was a court clerk.
Q Do you personally know this
individual?
A No.
Q And there's an allegation that you
said, quote, this is bullshit. This case has
been going on for two fucking years. I'm sick
of it, correct?
A Okay.

Page 65
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 How many times have you been married?
A Once.
Q Do you know whether your ex-wife or
your estranged wife caused a CR to initiate
against you?
MR. BATTLE: Objection.
BY THE WITNESS:
A Do I recall?
BY MR. MORRISSEY:
A Correct.
MR. BATTLE: There's so many
objections here. Let me start with that
being irrelevant, marital privilege and for
safety concerns.
MR. MORRISSEY: I'm not asking what
the conversation was.
BY MR. MORRISSEY:
Q I'm asking do you know whether there
was a CR initiated by your estranged wife?
A I don't have an estranged wife.
Q Well, at the time.
A What do you mean "at the time"?
Q At one time, you were married,
correct?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 43 of 107 PageID #:1351

GLENN EVANS
February 29, 2016
18 (Pages 66 to 69)
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

A Yes.
Q And at the time, you were a member of
the police department, correct?
A Yes.
Q Were you ever notified that your wife
at the time initiated a CR with the Chicago
Police Department relating to allegations of
misconduct by you?
A Was I ever notified?
Q Correct.
A Yeah, probably.
Q Were you notified what the
allegations were by that woman?
A I don't recall.
Q How were you notified?
A I don't recall that either.
Q Do you know whether you had
representation with this CR?
A I don't remember.
MR. BATTLE: What do you mean by
"representation"?
MR. MORRISSEY: Why don't we mark
this as Exhibit 4.

Page 68
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. BATTLE: Do you want to switch
with the ones you gave me?
MR. MORRISSEY: Sure, why don't we do
that.
MR. BATTLE: I'm going to hold onto
the actual one and remind me to give it to
you.
MR. MORRISSEY: Why don't we switch
the marking, too.
MR. BATTLE: What do you mean by
"switch the marking"? Mark that one Number
4?
MR. MORRISSEY: Right.
(WHEREUPON, Evans Exhibit
No. 4 was remarked for
identification.)
BY MR. MORRISSEY:
Q Mr. Evans, do you recall that around
June of 1993, a CR was initiated based on
allegations that you threatened to come to
Detroit to kill Deliliah Evans?
A Do I recall this information?
Q Correct.
A No, I don't recall it. I just recall

Page 67
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

(WHEREUPON, Evans Exhibit
No. 4 was marked for
identification.)
MR. BATTLE: When you say
"representation," are you speaking of legal
representation?
MR. MORRISSEY: Or union
representation.
MR. BATTLE: Right, you should
clarify just in case.
THE WITNESS: Yeah, because I keep
getting confused because he keeps
commingling legal and union. I get
confused. I'm not that bright.
MR. BATTLE: See how that copy looks?
BY THE WITNESS:
A Once again, the copy that I received,
Exhibit Number 4, is partially obscured, page
1, 2, 3, 4, 5, 6, 7, 8, all 8 pages are
obscured. I can barely make them out.
BY MR. MORRISSEY:
Q Well, part of the reason why it's
somewhat difficult to read is because the City
watermarked it confidential.

Page 69
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

this -- from what I see on this document.
Q Were you ever contacted by the police
department in the summer of 1993 regarding
allegations that you threatened Deliliah Evans?
A Was I contacted by the police
department? That's a broad question.
Q What was your assignment in August of
1993 with the police department?
A Let me see. I was, according to this
report, and none and these reports have -- are
rife with errors. A lot of these reports are
erroneous and rife with errors; but according
to this report, I was assigned to the 3rd
District.
Q Who was your commanding officer
during that time?
A There is no commanding officer in the
district. There was a commander and there was
a watch commander and then there's a lieutenant
as an acting commander -- an acting watch
commander rather. There is no commanding
officer.
Q Do you remember who your commander
was?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 44 of 107 PageID #:1352

GLENN EVANS
February 29, 2016
19 (Pages 70 to 73)
Page 70
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 The commander at that time I'm going
to say was Hubert Holton.
THE REPORTER: Hubert Holton?
THE WITNESS: Holton, H-o-l-t-o-n.
BY THE WITNESS:
A And that's to the best of my
recollection. I'm not going to take a perjury
because I misspoke. I'm just giving the
information that's the best I can recall.
BY MR. MORRISSEY:
Q Do you recall having a conversation
with Commander Holton around the summer of 1993
regarding allegations made by Deliliah Evans?
A No.
Q Who is Deliliah Evans?
A I'm going to assert my rights under
the Marital Privilege Act, and I'm not going to
answer that under advice of my counsel.
Q Is Delilah Evans your ex-wife?
A I'm going to assert my privileges
under marital privileges, and I'm going to
abide by counsel.
MR. MORRISSEY: I don't believe it's
a valid privilege.

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 When was your divorce finalized?
A I don't remember.
Q Why don't we look to the sixth page
of Exhibit 4 which appears to be a statement
that you gave to OPS in August of '93. If you
want to go back to page 6630, I believe that's
the start of the statement.
In looking at that page, does it
reflect that you gave a statement on August 19,
1993 to an investigator from OPS?
A Yes.
Q The second page of the statement,
your first answer reflects that your statement
to OPS is not being given voluntarily but under
duress; do you see that?
A According to this document, yes.
Q Why do you make that statement that
you're not giving the statement voluntarily to
OPS?
A Standard -- a standard statement that
was given when -- that's the standard statement
given when we give queries to internal affairs
or IAD. It's just a standardized response.

Page 71
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 Well, I can't help what you believe
or disbelieve.
MR. BATTLE: He's talking to me.
THE WITNESS: I'm sorry.
MR. BATTLE: What's the objection,
Counsel?
MR. MORRISSEY: I don't believe there
is a privilege about whether this
individual -- It's not a communication.
It's -- The question is whether Delilah
Evans is the former wife of the deponent.
I believe that would be public information.
MR. BATTLE: I believe you're right.
It would be public information. So why are
we arguing about it?
MR. MORRISSEY: Well, because I think
it's improper for the deponent to invoke a
privilege.
(WHEREUPON, the witness
and his counsel had a
discussion off the record.)
BY THE WITNESS:
A Okay, yes.

Page 73
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 anybody tell you to give that
standardized response?
A Did anybody tell me? That's a
standardized response. Nobody had to tell me.
Q Were you telling the truth when you
gave the statement?
A I tell the truth on all sworn
statements. Each and every one.
Q Are you aware that the Chicago Police
Department is currently under an investigation
by the Justice Department?
MS. KUPE-ARION: Objection,
relevance.
MR. BATTLE: I'll join.
MS. HARRIS: Join.
BY THE WITNESS:
A Could you be more specific?
BY MR. MORRISSEY:
Q Yeah. Are you familiar with the
United States Department of Justice?
A Yes.
Q Are you aware that, at times, they
investigate police departments or law
enforcement agencies?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 45 of 107 PageID #:1353

GLENN EVANS
February 29, 2016
20 (Pages 74 to 77)
Page 74
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 And attorneys too, yes.
Q Are you aware that the Department of
Justice is currently conducting an
investigation into the Chicago Police
Department?
MS. KUPE-ARION: I renew my objection
to relevance.
MR. BATTLE: I join. It's not
reasonably calculated to lead to
discoverable evidence. Lack of foundation,
so on so forth.
MS. HARRIS: Join.
THE WITNESS: Respond?
MR. BATTLE: Go ahead. You can
respond, if you can.
BY THE WITNESS:
A The information I got is from the
media, which is rife with misstatements, lies,
innuendos, exaggerations. So if you're asking
me that predicated on information you got from
the media, I don't trust any the responses of
the media, especially the Daily Beast.
BY MR. MORRISSEY:
Q Have you been contacted by any

Page 76
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

lieutenant in the 6th District, where were you
assigned in the police department?
MR. BATTLE: You said before the 6th
District?
MR. MORRISSEY: Yeah.
BY THE WITNESS:
A Assigned to the 5th District.
BY MR. MORRISSEY:
Q In what capacity?
A As a sergeant.
Q Did you take an exam to be promoted
to lieutenant?
A Yes.
Q Was it a written exam?
A Yes.
Q Did you pass the written exam?
A Yes.
Q In addition to being promoted by
taking a test, is there another way to be
promoted from a sergeant to a lieutenant, to
your knowledge?
A You have to take a written exam to
get promoted to be promoted from sergeant to
lieutenant and from PO to lieutenant -- I mean,

Page 75

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

investigator from the Department of Justice to
give a statement?
A No.
MS. KUPE-ARION: Objection to the
scope of that question and relevance as
well.
BY THE WITNESS:
A I mean -MR. BATTLE: No, he didn't ask
anything else.
MS. HARRIS: Join.
MS. KUPE-ARION: I can't instruct
your client, but I don't think that would
be proper to ask him anything regarding his
pending investigation with the DOJ.
BY MR. MORRISSEY:
Q Other than the Exhibit Number 4
regarding the alleged misconduct that was
initiated by Delilah Evans by the Chicago
Police Department, are you aware of any other
allegations by Delilah Evans of misconduct by
you?
A No, not that I recall.
Q Prior to your position as a

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

PO to sergeant. You have to take a written
examination. That's one of the criteria.
Q Are you aware of any other criteria
to make those promotions?
MR. BATTLE: You are asking about his
personal knowledge, correct? He's not a -MR. MORRISSEY: Correct.
MR. BATTLE: Okay, go ahead.
BY THE WITNESS:
A If you are referring to my personal
knowledge, my personal knowledge is you have to
take an examination to get promoted or you get
appointed.
BY MR. MORRISSEY:
Q As a commander, have you ever
recommended that a person be promoted from a
sergeant to lieutenant?
A Have I recommended?
Q Correct.
A It's possible.
Q How did you go about doing that?
A Could you be more specific as to -What do you mean, how did I do it?
Q Well, you said that, at times, you

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 46 of 107 PageID #:1354

GLENN EVANS
February 29, 2016
21 (Pages 78 to 81)
Page 78
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

have recommended somebody to be promoted from a
sergeant to a lieutenant, correct?
A At times I did, yes.
Q How did go about making that
recommendation to the police department?
A In writing.
Q To what office within the police
department would you deliver that written
recommendation for an individual to be promoted
from sergeant to lieutenant?
A There's not a specific office. It's
a process.
Q Tell me about the process.
MR. BATTLE: Objection. Man, this is
irrelevant and has nothing to do with this
case at all. Go ahead, man, tell him the
process.
BY THE WITNESS:
A I am not overly I don't want to say
familiar because of the time passage in which I
did it. The policies and procedures at that
time changed. What I did was I take a name
based on information received and submit it up
the chain of command.

Page 80
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. As a commander, you, at times, would
make a written request for somebody under your
command to be promoted, correct?
A Every commander does, yes.
Q How frequently would you do that?
A I don't know. I couldn't tell you.
It was infrequent. Depends upon whether
they're going to make promotions.
Q How were you made aware as commander
that it was time for promotions in the
department?
A Via written notification.
Q Who would they come from?
A City of Chicago.
Q Would it be the superintendent's
office?
A Might be the supervisor's office,
might be human resources. I'm not overly
acclimated with that process.
Q When you were a commander, you
participated in that process, right?
A Infrequently.
Q When you mean "infrequently," what do
you mean?

Page 79
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 Do you know whether the chain of
command ever accepted any of your suggestions
for an individual to be promoted?
A I don't know.
Q What would you look for when you were
making a recommendation for someone to be
promoted?
A What do I look for?
Q Correct.
A I don't know what that means, what do
you look for?
Q Are there certain qualities or
characteristics that you look for when making a
decision whether to request a police department
to promote an individual?
A Any particular qualities or anything
of that nature, I followed the parameters of
the department's edicts.
Q Do you have any discretion regarding
those parameters?
A What do you mean? Do I deviate from
them?
Q What would you look for -- strike

Page 81
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 It means whenever I get sent memos of
documents regarding promotional opportunities
and I'm assigned to submit somebody in
consideration for a promotion, I follow the
department's edicts, and I do so.
THE REPORTER: You follow the
department's what?
THE WITNESS: Edicts, e-d-i-c-t-s.
Edicts, edicts, I don't know. I flunked
English.
BY MR. MORRISSEY:
Q As a commander, did you have access
to the police department's CLEAR system?
A Yes.
Q As a commander, could you use the
CLEAR system to determine how many CR files an
officer under your command had?
A Internal affairs has that.
Q I'm asking could you, as a commander,
identify that information?
A That information is fed through
internal affairs.
Q So you did not have access to that
information, correct?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 47 of 107 PageID #:1355

GLENN EVANS
February 29, 2016
22 (Pages 82 to 85)
Page 82
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 It goes to internal affairs.
Q Could you request internal affairs
provide you with a number of CRs that an
officer under your command had?
MR. BATTLE: Objection, speculation,
go ahead. You can answer.
BY THE WITNESS:
A I can request it, but I generally
don't recall that being the process.
BY MR. MORRISSEY:
Q Before you made a decision to request
in writing that an officer under your command
be promoted, would you have an interview with
that candidate?
A Do I interview them?
Q Correct.
A Yeah, depends.
Q What would it depend on?
A It depended on what the department
states the policy and procedures are regarding
submitting individuals' names for nomination.
Q And, at times, did the department
require you to conduct an interview with a
candidate?

Page 84
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 had ten CR allegations, would that
disqualify that candidate?
MR. BATTLE: Objection, speculation,
incomplete hypothetical, irrelevant. It
does not lead to discoverable evidence in
this case, and I have no idea on Earth why
you are asking that question.
MS. KUPE-ARION: And also competence
since Mr. Evans is not being produced as a
(30(b)(6) witness to speak on behalf of CPD
procedures.
MS. HARRIS: And I'll join in that
objection, too, to the extent it would
affect the other defendants in the case.
BY THE WITNESS:
A You'll have to repeat that question.
BY MR. MORRISSEY:
Q Assuming there was a period when you
were delegated a task of a commander to
recommend some people under your command for a
promotion.
A Okay, that's one part.
Q If you were aware that that candidate
had ten allegations of misconduct, CR files,

Page 83
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

1
A I don't recall what the directives
2
are. I would have to review the directives,
3
parameters and then I can answer that.
4
Q Did you ever interview somebody
5
before you decided to make a written
6
notification to the superintendent or the HR
7
department for that person to be promoted?
8
A Did I personally make a -- Did I
9
interview someone to see if they are a good or
10
viable candidate for promotion?
11
Q Correct.
12
A Yes.
13
Q Would you take notes based on your
14
interview?
15
A I'm going to say no.
16
Q What would you look for in a
17
candidate that you would request to be
18
promoted?
19
A There are certain performance and
20
behavior dimensions that were outlined in
promotional announcements and notifications. I 21
22
adhere to those standards, and that's what I
23
look for.
24
Q If a member of the department of your

Page 85
would that, based on your assessment,
disqualify the person for a promotion?
MR. BATTLE: Same objection.
MS. KUPE-ARION: I renew my
objection.
MS. HARRIS: Same objection.
BY THE WITNESS:
A Because complaints by themselves
don't constitute disciplinary action, and
that's what you're commingling. You're
commingling disciplinary action with
complaints, and a lot of complaints are
erroneous, invalid, done for political or
retaliatory purposes or done to harass working
officers.
I take everything into account. I
take the negative and the positive into
account. I don't discount anybody because of
complaints, but I don't discount anybody
because they have an outstanding personnel or
an award history as well. You have to balance
everything. So I take everything into
consideration.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 48 of 107 PageID #:1356

GLENN EVANS
February 29, 2016
23 (Pages 86 to 89)
Page 86
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 For approximately what period of time
were you a sergeant assigned to the 5th
District?
A I'm going to say, to the best of my
recollection, and don't hold me to this,
December maybe 2003, 2003 maybe to May or -May 2016 -- May 2006. 2006, I'm sorry.
Q And you already testified, I believe,
that you took a test to be promoted from
sergeant to lieutenant?
A Yes.
Q In addition to that test, did you
have an interview with your commander prior to
your promotion?
A That's a vague question. Interview
as to regards to what?
Q In regards to your promotion or
potential promotion from sergeant to
lieutenant.
A You would even have to be more
specific than that. My commander, because of
my work ethic and productivity, would task me
to perform certain deployments and functions.

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

A Not that I can recall, no.
Q Same question for your deputy chief.
A Not that I can recall.
Q When you were a sergeant assigned to
the 5th District, were you ever suspended?
MR. BATTLE: Objection, relevance.
BY THE WITNESS:
A I don't recall ever being suspended
as a sergeant. It's entirely possible, but I
don't recall.
BY MR. MORRISSEY:
Q When you were a lieutenant assigned
to the 6th District, who was your commander?
A I had multiple commanders.
Q Can you tell me them?
A One was John Doty, D-o-t-y; another
commander was Eddie Johnson, common spelling;
third commander, Eric Carter, common spelling.
Q During that period, who was your
deputy chief?
A I don't recall but I'm going to guess
Dana Alexander and/or Eugene Williams and
possibly Tina Skahill, S-k-a-h-i-l-l.
Q As lieutenant in the 6th District, to

Page 87
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

He would directly come to me and ask
me to deploy my personnel in a most
advantageous fashion; and based on his input
and his direction, I would do so.
So in terms of direct personnel
matters, I've had numerous conversations with
my commander and my deputy chief at that time.
Q Tell me when you were the sergeant in
the 5th District who your commander and deputy
chief were?
A The commander of the 5th District at
that time was Syd Kelly. The deputy chief was
Michael Shields.
Q When you were a sergeant in the 5th
District, did you ever receive any citizen
complaints of excessive force?
MR. BATTLE: Objection to relevance.
BY THE WITNESS:
A I don't remember. It's entirely
possible.
BY MR. MORRISSEY:
Q Did you ever have a conversation with
Commander Kelly during that period regarding
allegations of excessive force by citizens?

Page 89

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 knowledge, were you ever -- did you ever
receive a citizen complaint alleging excessive
force?
A Yes.
Q How many do you recall receiving?
A I don't recall.
Q More than one?
A Possibly.
Q Other than excessive force, do you
recall ever receiving a citizen complaint -Strike that.
Do you know whether IAD investigated
you when you were a lieutenant in the 6th
District?
A Yes.
Q Under what circumstance did IAD
investigate you, to your knowledge, when you
were a lieutenant in the 6th District?
A To the best of my recollection, I
believe it was one investigation regarding a
narcotics investigation I did at a residence.
They did the investigation, and to
the best of my recollection, they determined
that like much -- in a lot these investigations

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 49 of 107 PageID #:1357

GLENN EVANS
February 29, 2016
24 (Pages 90 to 93)
Page 90
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 the individual had lied, falsified
evidence and hid his identity and
misrepresented facts to the department, so they
unfounded it.
Q What were the circumstances regarding
that IAD by that citizen?
A It was a narcotics complaint,
multiple complaints of narcotics into a
residential area.
Q And what misconduct was alleged
against you?
A I don't absolutely recall. It could
be possible regarding the lack of a search
warrant, but I don't recall.
Q Did you discuss that IAD
investigation with any of your commanders in
the 6th District?
A Did I discuss it? It's possible but
I don't recall.
Q Did you discuss that IAD
investigation with any of the deputy chiefs
when you were a lieutenant in the 6th District?
A I'm fairly sure I didn't.
Q Regarding that at least one

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

issues that they do not concur with, indicate
that they do not concur with the findings or
the investigation.
Q When you were a commander, did you
ever not concur with findings from IPRA?
A Yes.
Q Did it happen more than once?
A I'm going to say yes.
Q More than five times?
A I don't know how many times exactly.
Q As you sit here today, do you recall
any times when you reviewed an IPRA
investigation and decided not to concur with
the finding?
A That I personally reviewed the IPRA
investigation?
Q Correct.
A Yes.
Q Can you give me what you remember
about that assessment?
A The assessment and investigation, if
I did not concur, and this is just standard
across the board, that the findings were
incorrect or the investigation was flawed in my

Page 91
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

allegation of excessive force when you were a
lieutenant in the 6th District, did you have a
conversation regarding those allegations with
any of your commanders?
A I'm sorry. Could you repeat that?
Q You said you recall at least one
allegation of excessive force by a citizen when
you were a lieutenant in the 6th District. The
question is did you have a conversation
regarding that allegation with any of your
commanders?
A I'm going to say that if there's an
ongoing investigation, the commanders would be
prohibited from discussing that in order to
retain the integrity of the investigation.
Q How would you know what the commander
is prohibited from talking with you about while
it's ongoing.
A Because I was a commander.
Q And what is your understanding of
what a commander is prohibited from doing when
there's an ongoing CR investigation?
A That they're supposed to let the
investigation go unimpeded; and if there's

Page 93
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

estimation or that the investigation was
flawed, the findings were incorrect.
Q Do you recall the factual allegations
against that officer when you decided to not
concur with the IPRA findings?
A Not as we sit here. If I get the
records and I review them, I can be in a better
position to refer to that -- to defer to that.
I'm sorry.
Q Prior to being a sergeant in the 5th
District, what was your position?
A Police officer.
Q And from what years were you a police
officer?
A From July 1986 to I'm going to say
July 1998.
Q And after July of '98, what was your
position?
A I was a sergeant.
Q Correct me if I'm wrong, but I
believe you testified you were a sergeant in
the 5th District from December of '03 to May of
'06?
A That's correct.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 50 of 107 PageID #:1358

GLENN EVANS
February 29, 2016
25 (Pages 94 to 97)
Page 94

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 Prior to December of 2003, what was
your title with the police department?
A Sergeant.
Q Where were you assigned?
A Public housing.
Q From what years and months were you
assigned to public housing?
A Approximately July 1999 to -- July
1999 to December 2003. It might have been
2002. I don't know. I mean, I'll have to
review my records.
Q During the time when you were a
sergeant in public housing, are you aware of
any IAD investigations against you?
A IAD investigations against me?
Q Correct.
A You're not made aware of all
investigations. It's possible, but I don't
recall any IAD investigations against me.
Q During that same period when you were
a sergeant in public housing, are you aware of
any citizen complaints against you relating to
excessive force?
A From 1998 -- I'm sorry, in public

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 As a police officer from July of 1996
to about July of '98 or '99, tell me the
various assignments you've had.
A As a police officer?
Q Correct.
A 6th District, at least twice; 3rd
District, public housing. That's it.
Q When you held the rank of police
officer, are you aware of any IAD
investigations against you?
A Any IAD investigations?
Q Correct.
A Yes, a couple, I think that I can
recall, a couple that I can recall.
Q Tell me what you recall about those
few IAD investigations?
A I know that the IAD investigations
came back either exonerated or not sustained or
some unfounded. I don't recall anything behind
that.
Q Do you recall any factual allegations
against you?
A Any factual allegations?
Q Correct.

Page 95
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

housing, excessive force?
Q Yeah.
A Yes, but -- yes, but I don't recall
the particulars.
Q Do you recall how many times you were
a recipient of a complaint of excessive force
starting in public housing?
A No.
Q More than once?
A It was more than once.
Q More than two times?
A It was probably more than two times.
Q Three?
A I think that's stretching it. I'm
not sure.
Q Were you disciplined as a result of
those CR investigations?
A As a sergeant?
Q Correct.
A No.
Q When you were a sergeant in public
housing, were you ever suspended?
A As a sergeant in public housing, no,
not that I can recall.

Page 97
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 Factual allegations is not a real
good way to put it because -- I don't know what
you mean by factual allegations. Do you mean
did they have a basis to lodge a complaint or
basis to sustain a complaint?
BY MR. MORRISSEY:
Q I'm asking do you recall -- I will
rephrase the question. What's the difference
between an IAD investigation and a citizen
complaint of excessive force?
A IPRA and it's precursor or its
predecessor, I'm sorry, OPS, investigates
verbal abuse and excessive force; and internal
affairs is tasked with just about all other
allegations with the exception of summary
punishment, which is tasked by the immediate
supervisor, tasked to the immediate supervisor.
Q Are IAD investigations initiated
internally within the CPD?
A Are -- I'm sorry?
Q Are IAD investigations initiated
internally by a member of the CPD.
MS. KUPE-ARION: Objection,
competence since Mr. Evans is not being

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 51 of 107 PageID #:1359

GLENN EVANS
February 29, 2016
26 (Pages 98 to 101)
Page 98
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

produced on behalf of the city and cannot
give any testimony in regards to policies
of the police department.
MR. BATTLE: I will join in that
objection.
MS. HARRIS: I'll join.
MR. BATTLE: Glenn, you can answer as
best you can, based on your personal
knowledge.
BY THE WITNESS:
A I never was assigned to IAD and there
was never any policy making or implementation
at that level, so I can't speak to that.
BY MR. MORRISSEY:
Q When you were a police officer from
July of '86 to either July of '98 or '99, are
you aware of any citizen complaints of either
verbal abuse or excessive force by you?
A Yes.
MR. BATTLE: Objection, we already
went through that just a few seconds ago.
BY THE WITNESS:
A Yeah, you just showed me a report.

Page 100

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

It's Willibrord Catholic.
THE REPORTER: It's what? Just say

it.
(WHEREUPON, the witness
wrote down the name of
the school.)
THE WITNESS: Now, aren't you glad
I'm not saying it?
BY MR. MORRISSEY:
Q Did you go on to college?
A Yes.
Q Where did you attend college?
A I went to multiple colleges.
Q Tell me the first college you went
to.
A I can't tell you the first college I
went to. I went to multiple colleges at once,
City College, University of Illinois Chicago,
Chicago State.
Q Did you ever receive a degree?
A Yes.
Q What did you receive your degree in?
A In liberal arts.
Q From which university?

Page 99

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 How many allegations of abuse, to
your knowledge, were made against you during
that period?
A I don't know.
Q More than one?
A I don't know, possibly. I'm going to
say yes.
Q When did you enter the training
academy?
MR. BATTLE: Oh, Jesus.
BY THE WITNESS:
A July of 1986 to, I believe, November
1986.
BY MR. MORRISSEY:
Q Where did you attend high school?
A Where did I go to high school?
Q Correct.
A I went to a high school on the south
side of Chicago.
Q Do you recall the name of the high
school?
A Yes.
Q What is it?

Page 101
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 From Western Illinois.
Q Which year?
A 1986.
Q What year did you graduate high
school?
A What year did I graduate high school?
Q Correct.
A 1980.
Q Did you ever serve in the military?
A No, not full time, no.
Q Well, did you ever serve in the
reserves?
A Yes.
Q From what year did you serve in the
reserves?
A July 1989 to, I think, I'm going to
say sometime 1994. I don't recall the month.
Q Which reserves did you serve in?
A I was in the coast guard reserves.
Q Did you receive a discharge?
A As far as I know.
Q Tell me what discharge you were given
by the coast guard?
A It was inactive ready reserve, and it

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 52 of 107 PageID #:1360

GLENN EVANS
February 29, 2016
27 (Pages 102 to 105)
Page 102
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

was -- I believe it was -- It was an honorable
or whatcha call it? I'm going to say it was an
honorable discharge because I never was -- had
any adverse affect on my career. I don't have
my records, so I can't answer all of that.
Q Between 1980 and 1986, were you
employed?
A 1980 and 1986?
Q Correct, prior to you joining the
Chicago Police Department?
A Yes.
Q Where did you work?
A I'm sorry?
Q Where did you work?
A From 1980 to 1986 prior to joining
the police department?
Q Yes.
A University of Illinois, I believe.
Q What did you do for the university?
A I did manual labor, and I did patient
transport.
Q Are you familiar with the term of
pressure point technique?
A Am I familiar with the term pressure

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
24

A On a citizen's head? That's just
such a broad question. I don't really know how
to address that.
Q Do you recall receiving any training
regarding physical control measures in the
academy during July of '86 to November of '86
to use on an arrestee's head or face?
A On an arrestee's head or face? We
learned multiple overall physical control
measures.
Q Describe the multiple physical
control measures you learned to apply to a
person's face?
A Including pressure point, and we also
learned how to use holding and restraint, and
we're also taught to control a person's head to
minimize conflict.
Q Describe the pressure point technique
you were taught in the academy to apply to a
person's face?
A What do you mean describe it?
There's multiple techniques they taught us to
use.
Q Was there any technique they taught

Page 103
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

point technique, yes.
Q Did you learn the pressure point
technique when you were in the academy from
July of 1986 to November of 1986?
A You mean a specific pressure point
technique?
Q Correct.
A There weren't specific pressure point
techniques. We learned a variety of control
measures.
Q What types of control measures did
you learn when you were in the academy from
July of '86 to November of '86?
A Physical control methods.
Q Did you have a class on physical
control measures?
A Did we have a class? We had multiple
classes.
Q You had multiple classes on physical
control measures?
A Yes.
Q Tell me what techniques you were
taught during that period relating to using a
physical control measure on a citizen's head.

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

you to use to a person's nose?
A There were techniques to use to a
person's head that included the nose region,
yes.
Q Describe how you were taught that
pressure point technique to the nose?
A By physical demonstration.
Q Can you verbally describe it?
A There are multiple because it's a
fast-paced class. There are multiple modes of
instruction that we were given, and it depended
on situational concerns. It depends on the
person if the person is combative, noncompliant
or an assailant.
Q Tell me about the techniques you've
learned for a noncompliant individual?
A Noncomplaint, it depends on the level
of noncompliance. You want me to give you a
static answer, and I can't give you a static
answer because pain control and compliance are
all situational. It depends on what the
situation is, the level of threat and the level
of noncompliance and other factors.
Q Have you ever been accused of

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 53 of 107 PageID #:1361

GLENN EVANS
February 29, 2016
28 (Pages 106 to 109)
Page 106
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

misconduct to an arrestee in a lockup?
A Yes.
Q More than once, right?
A More than once, I don't recall. It's
possible. I'm going to say yes.
Q And would that be other than
Ms. King's allegation against you?
A Okay, that's what threw me off. Yes,
there might have been one other besides
Ms. King.
Q What other -- Describe the other
allegation you're aware of of misconduct in the
lockup.
A The allegation of misconduct in the
lockup was that an individual claimed and in
doing so, once again, he lied and exaggerated
and falsified the account by claiming that I
improperly Tasered him.
Q Where did this individual say you
improperly Tasered him?
A I believe in the groin and in the
posterior.
Q Were you disciplined for that
allegation?

Page 108
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Halsted.
Q Is that the same location where you
allegedly abused Ms. King?
A Where I was falsely accused of
abusing Ms. King, that's correct.
Q When you were a police officer, were
you also accused of kicking an arrestee in the
groin?
MR. BATTLE: Do you want to give us
some time or some reference?
BY MR. MORRISSEY:
Q Do you recall an alleged incident
that occurred on 27 March of 1993 -A '93?
Q -- where you allegedly, as a police
officer, kicked an individual in the groin, and
the individual's name was Anthony Harris?
A No, I don't.
MR. BATTLE: Objection.
BY MR. MORRISSEY:
Q Do you recall an incident that
allegedly occurred on May 11th, 1994 where you
allegedly struck a woman by the name of
Jennifer Thomas in her left eye?

Page 107
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 No.
Q Do you recall what year that
allegation was?
A Oh, my goodness, maybe 2007. I'm not
really sure.
Q Did that individual sue you?
MR. SCHUMANN: I'm sorry. Did you
say 2007?
THE WITNESS: I'm sorry, 2007.
BY THE WITNESS:
A Yes, he did.
BY MR. MORRISSEY:
Q Do you recall that individual's name?
A I think his last name was Simmons.
Q Do you know whether that case
settled?
A To my recollection, it did.
Q And you were a lieutenant at the
time, correct?
A Yes.
Q Was that in the 6th District?
A Yes.
Q Where is the 6th District?
A The physical structure is 78th and

Page 109
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. BATTLE: Objection to relevance.
BY THE WITNESS:
A No.
BY MR. MORRISSEY:
Q Do you recall during that CR
investigation, OPS required you to be
photographed?
MR. BATTLE: Objection, same.
BY THE WITNESS:
A No, I don't.
BY MR. MORRISSEY:
Q Have you ever shot anybody while on
duty?
MR. BATTLE: Objection to relevance,
case-by-case basis. There is no
allegations of gun play involved in this
case at all. Go ahead and answer, if you
remember.
BY THE WITNESS:
A An individual that fought me, injured
my hand and tried to wrestle my gun from me and
also went to threaten his girlfriend with a gun
and fought me in the stairwell, if that's the
individual you're referring to and that same

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 54 of 107 PageID #:1362

GLENN EVANS
February 29, 2016
29 (Pages 110 to 113)
Page 110
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

individual subsequently shot two people, killed
one and brain damaged a second one, I
absolutely did shoot him.
Q Other than that incident, have you
ever shot anybody or anyone as a member of the
police department?
A Second situation where an individual
that threatened his girlfriend to shoot her
when I was an officer, and he got into a big
fight with me and, once again, that individual
tried to take my gun, in fact, he did at one
point and disarmed me, I shot him, too.
Q Have you ever shot at a citizen's
dog?
A Yes, I did.
Q When did that occur?
A I don't recall. A few times I shot
vicious animals.
Q Do you know whether CR investigations
were opened as a result of those instances?
A No, I don't recall.
Q Do you recall being sued by Joshua
Lott?
A I'm sorry?

Page 112
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. BATTLE: Wait.
BY THE WITNESS:
A My attorney -MR. BATTLE: Stop talking.
THE WITNESS: Okay, no problem.
MR. BATTLE: You're getting into
dangerous territory in terms of
attorney-client privilege.
MR. MORRISSEY: I'm not asking who
his -- I'm asking who was his attorney
prior to you coming in.
MR. BATTLE: Right, what does that
have to do with this case?
BY MR. MORRISSEY:
Q Was Eric Palles your attorney -MR. BATTLE: Counsel, don't instruct -Don't talk to my client when I'm talking to
you. I don't think that's appropriate.
MR. MORRISSEY: I'm the one asking
questions. I'm not being noticed here.
MR. BATTLE: I just asked him to go
off the record so you and I can have a
conversation about it. Do you really want
me to go on the record with that?

Page 111

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 Do you recall being sued by Joshua
Lott in federal court?
A Yes.
Q And the incident occurred or
allegedly occurred in May of 2012, correct?
A Yes.
Q Do you recall what the allegations
were against you?
A I never was served with allegations.
Q Do you know whether you were
represented in that case?
A I never was served with allegations.
Q Who was your attorney prior to
Mr. Battle stepping in for you?
MR. BATTLE: In what case?
BY THE WITNESS:
A In what case?
BY MR. MORRISSEY:
Q In this case.
A In what case is that?
MR. BATTLE: You're talking about the
Rita King case?
MR. MORRISSEY: Yes.
MS. KUPE-ARION: Objection --

Page 113
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. MORRISSEY: Yes.
MR. BATTLE: You want to do that on
the record?
MR. MORRISSEY: Yes.
MR. BATTLE: Because I think that
question you're asking him is abusive,
harassing, and if he understands who's
representing him, that's fine.
I think that's a question you can
actually find out if you look at the court
docket and see what appearances have been
filed for him periodically throughout time.
That's an unfair question.
You're abusing the discovery
process and I don't appreciate -- I was
trying to do this off the record. I'm
going to instruct him not to answer that
question. You can take that to Judge
Gilbert or call him if you'd like.
BY MR. MORRISSEY:
Q Sir, are you taking your attorney's
advice regarding that question?
A I'm taking his advice and he made the
absolute right call and I back him up, and I'm

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 55 of 107 PageID #:1363

GLENN EVANS
February 29, 2016
30 (Pages 114 to 117)
Page 114
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

not answering that question.
MR. SCHUMANN: Excuse me. What's the
relevance of this question?
MR. MORRISSEY: I'm not answering
questions about -MR. SCHUMANN: What's the relevancy
of the question? I'm asking as an attorney
of record?
BY MR. MORRISSEY:
Q Did you have an attorney in the
Joshua Lott matter?
A City of Chicago.
Q And did Eric Palles represent you in
that case?
MS. HARRIS: I'm going to object to
the relevance of this.
MR. BATTLE: I'm getting ready to
call the judge. Go ahead with your
objection. I've got to find the judge's
phone number on this.
MS. HARRIS: I'm making an objection.
I don't understand how this is relevant,
how it leads to discoverable evidence. I
believe it's harassing, argumentative and

Page 116
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. SCHUMANN: If you can explain to
me what the relevance is or how this leads
to some part of your complaint, I would be
willing to listen.
MR. MORRISSEY: We have a Monell
allegation against the city. I prefer to
move forward with this deposition.
MS. KUPE-ARION: If you are raising
this under scope of Monell, then it really
has no -- what's the -- there is no
relevance or connection between who
represented him at what point in his cases.
MR. MORRISSEY: Mr. Battle, what are
you going to have your client do?
MR. BATTLE: Do we need to have the
judge referee this one?
MR. MORRISSEY: I don't understand
what the issue is.
MR. BATTLE: Right, you probably
don't, but you're asking my client who his
attorneys are in various cases, and that's
of record. Do you want me to call the
judge to referee?
MR. MORRISSEY: I don't understand

Page 115
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

badgering the witness.
THE WITNESS: That's all he's been
doing.
MS. KUPE-ARION: The City joins.
MR. MORRISSEY: Mr. Battle, are you
telling your client not to answer?
MR. SCHUMANN: You're needlessly
prolonging the dep -MR. MORRISSEY: Well, I thought we
already talked about Mr. Battle -MR. SCHUMANN: Yeah, well, we're not
now. It is also needlessly -- and you
still haven't given me a rule. So if you
give me a rule, I'll abide by any rule; but
you are needlessly prolonging the
deposition by asking a witness who his
attorney is in past cases when they are of
record.
Who his attorney is has no
relevance to this litigation or can lead to
anything relevant to this litigation.
MR. MORRISSEY: When your client -MR. SCHUMANN: Excuse me. Excuse me.
MR. MORRISSEY: Go ahead.

Page 117
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

why that is privileged.
MR. BATTLE: Do you want me to call
the judge so he can referee that question?
MR. MORRISSEY: I don't believe
that's necessary.
MR. BATTLE: I believe you're totally
off base with this. That's just like me
asking Rita King who her cousin is who has
nothing to do with the case, Counsel.
MR. MORRISSEY: Judge Gilbert said if
there are any issues to bring it before him
in writing.
MR. BATTLE: I think we can call him
right now so we can -MR. SCHUMANN: But before that, we're
supposed to have a 37 -MR. MORRISSEY: All right, let me -MR. SCHUMANN: We can do this right
here. All you have to do is explain to us
what the relevancy is or how this is to
lead to relevant evidence based upon what
is in the complaint that you filed or any
answer or affirmative defense -MR. MORRISSEY: All right, we already

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 56 of 107 PageID #:1364

GLENN EVANS
February 29, 2016
31 (Pages 118 to 121)
Page 118
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

agreed that one -THE REPORTER: I'm sorry. You have
to -MR. SCHUMANN: I would like my answer -question as an attorney of record -- I
mean, my question answered as an attorney
of record and we can move on. You are
slowing this deposition up. We can move on
if you can state for the record to us so we
can advise our client how this is relevant
or how it leads to discoverable information
in this case.
MR. MORRISSEY: I'm not being deposed
here. Why don't we move on.
BY MR. MORRISSEY:
Q Mr. Evans, Joshua Lott sued you,
right?
A Joshua Lott filed a lawsuit against
numerous members of the police department of
which I was one.
Q And you gave a deposition in that
case, right?
A It's possible. I don't recall giving
a deposition.

Page 120
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

my counsel, and I'll stand on it in court. I'm
making that comment against the advice of my
counsel, and I'll stand on it in court.
Q In what capacity were you working
when you allegedly engaged in misconduct
against Mr. Lott?
A Against Mr. Lott the liar, I was a
lieutenant.
Q And what were you doing that day?
A I was assigned to NATO.
Q And was Mr. Lott a photo journalist
that day?
A I don't know what he was. He's a
liar and if he's a photo journalist, he's a
lying one.
MR. BATTLE: Just answer the
question.
THE WITNESS: Well, I got to call it
like I see it.
BY MR. MORRISSEY:
Q Were you working in the capacity as a
lieutenant at NATO that day?
A Yes.
THE WITNESS: I'm sorry, but enough

Page 119
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 We were talking about the allegations
that Mr. Lott had against you, correct?
A I never was served with allegations
by Mr. Lott who was a big liar by the way, and
I'll put that on the record.
Q Why -A Because he made a bunch of false
allegations, and it was pushed by his counsel
so he could get a settlement. He lied, and I'm
going to put that on the record. Mr. Lott
lied.
Q What are Mr. Lott's allegations,
based on your knowledge?
A Based on my knowledge, any allegation
that Mr. Lott alleged, Number 1, physical
misconduct relative to physical contact with
him is an out and out lie. Number 2, any
allegations Mr. Lott alleged stating that I
ignored police misconduct in my presence, he
brought that to attention, is another lie.
He's a liar; and if his counsel pushed it,
they're lying too and I stand on it.
And that didn't come from my counsel.
I'm making this comment against the advice of

Page 121
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 enough of the lies.
MR. BATTLE: Okay.
BY MR. MORRISSEY:
Q Do you know whether that case
settled?
A To my recollection, it did.
Q Was that recent?
A It depends on what you claim is
recent.
Q When do you recall the case settling?
A I don't know. I was never formally
notified.
Q We also talked about Mr. Simmons'
complaint against you; is that correct?
A That's correct.
Q Do you recall what allegations
Mr. Simmons had against you?
A I think I had answered that, but I
will answer it again. He stated that I had
Tasered him in his groin and his buttocks area.
Q Did you settle that case?
A I didn't settle anything. It's not
up to me to settle anything.
Q Is there another case with a Rennie

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 57 of 107 PageID #:1365

GLENN EVANS
February 29, 2016
32 (Pages 122 to 125)
Page 122
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Simmons, a city water inspector?
A Is there another case?
Q Correct, that you're involved with.
A There was another case.
Q So there's two Simmons cases,
correct?
A That's correct.
Q And the Rennie Simmons, R-e-n-n-i-e,
Simmons case, those allegations by Mr. Simmons
occurred in July of 2006, correct? Mr. Evans,
I have a question pending.
MR. BATTLE: I got it, counsel. I
got it, counsel.
BY MR. MORRISSEY:
Q Excuse me -MR. BATTLE: Hold on. I got it.
BY THE WITNESS:
A Can I talk to him for one second?
MR. BATTLE: No, no, no. You got to
answer this question and then we can take a
break.
BY THE WITNESS:
A Repeat it again.
MR. BATTLE: I got this, Counsel.

Page 124

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

had a -- I get these moments where I have
some lucidity and I wanted to -MR. BATTLE: Okay.
THE WITNESS: But we'll talk later.
MR. BATTLE: Yep.
BY MR. MORRISSEY:
Q Is there anything that would prevent
you from testifying truthfully today? Are you
on any medications that would impair your
ability to testify truthfully?
A I testify truthfully every time I'm
under oath, unlike Mr. Lott.
Q Do you recall what the allegations by
Mr. Rennie Simmons were against you?
MR. BATTLE: Is that a man or a
woman?
THE WITNESS: That's a man and his
name is Rennie, not Rennie, Rennie.
MR. BATTLE: I'm sorry to interrupt.
Go ahead.
BY THE WITNESS:
A I never was served with any
allegations of misconduct relative to
Mr. Simmons' case. I never was served.

Page 123
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 WITNESS: You know, can I take a
break?
MR. BATTLE: You've got to answer the
question.
BY MR. MORRISSEY:
Q You have to answer the question
first.
A No problem.
MR. BATTLE: Yeah, go ahead repeat
the question.
BY THE WITNESS:
A Can you repeat it again?
MR. MORRISSEY: Will you repeat it?
MR. BATTLE: He wants her to read it.
(WHEREUPON, the record
was read as requested.)
BY THE WITNESS:
A That depends on what do you mean by
"allegations"?
MR. MORRISSEY: Do you want to take a
break now?
THE WITNESS: No, let's go.
MR. BATTLE: Are you good?
THE WITNESS: Yeah, I'm good. I just

Page 125
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 But you recall there being
allegations against you by Mr. Simmons?
A I was never served with any
allegations of misconduct by Mr. Simmons.
Q I'm not asking you whether you were
served any papers. I'm asking whether you have
any knowledge of any allegations brought
against you for misconduct?
A No, not that -- By Mr. Simmons, no.
Q You testified in court against
Mr. Simmons, correct?
A Yes, I did.
Q And were you testifying truthfully
when you testified in court?
A I testify truthfully at all of my
court appearances.
Q What do you recall happening between
you and Mr. Simmons in July of 2006?
MR. BATTLE: Objection, relevance,
outside the scope, not reasonably
calculated to lead to discoverable
evidence. Are we ever going to get to Rita
King?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 58 of 107 PageID #:1366

GLENN EVANS
February 29, 2016
33 (Pages 126 to 129)
Page 126
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 I'm going to give you the best of my
recollection. Mr. Simmons approached my
property, which was vacant and still is vacant
with a real nasty attitude and demeanor. He
wanted to take a picture of the building, and I
gave him the okay. Then I told him if he had a
water sticker about -- that he wanted to post
on the building. I said you can give it to me
and I'll take the service. He screamed and
cursed at me and was very arrogant and
belligerent.
I ordered him off my property. We
got into an argument. I called 911 on him
because he was being abusive and
confrontational. He went to his vehicle to the
best of my recollection. He came and took a
picture and I took a picture of him with my
cell phone. His words and I don't know the
absolute correct verbiage he used, his words
were I got something for your smart ass.
He ran to the trunk of his vehicle
and took out a wrench or a pipe or something of
that nature. I tackled him. I took him to the

Page 128
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

it again. There was -- I don't know if there
was a complaint lodged officially, but I
believe that he did lodge some kind of
complaint, and it was unfounded.
MR. MORRISSEY: Why don't we mark
this -- Are we on 5?
THE REPORTER: Yes.
(WHEREUPON, Evans Exhibit
No. 5 was marked for
identification.)
BY MR. MORRISSEY:
Q Sir, I'm showing you what has been
marked as Exhibit 5, which is your set of
Answers to Plaintiff's First Set of
Interrogatories, which I believe you verified
in December of 2013. Do you see your signature
on the last page of that document?
A Yes. And this is a clear copy, so I
can see all of this.
Q Do you recall preparing this
document?
A Do I recall preparing it? I didn't
prepare this document per se.
Q Prior to signing or attaching your

Page 127
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

ground. I held him for the police.
He was arrested and charged with
battery, but he should have been charged with
aggravated assault. It was my information that
because he stated that he was connected to
political figures, figures in this ward here,
the 19th Ward, figures in the 21st Ward and
figures in the 8th Ward and some other
political figures that he was not going to -he was going to escape punishment for his
actions.
He subsequently secured the services,
I believe, of Mr. Pinchum who is also a
political icon, and the case was dismissed and
found not guilty.
I believe the judge in that case
admonished us both for acting like children,
which we were because we could have acted a lot
better. He took the case, sued and got a
settlement.
Q Do you know whether there was any CR
investigation by IPRA as a result of that
incident?
A I just answered it, but I will answer

Page 129
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

signature to the last page, did you review the
answers?
A Yes.
Q And was it on or about December 9th,
2013?
A Yes.
Q Did you review this document prior to
coming here to testify?
A Cursory review, yes.
Q Based on your cursory review, is
there any answer that you would like to change?
MR. BATTLE: Take your time.
BY THE WITNESS:
A There probably are answers that I
would like to change but not at this time.
Going forward and reviewing this a little bit
further when I get a chance to review this with
counsel, there probably are items I would like
to change and modify.
BY MR. MORRISSEY:
Q Which answer would you like to
change? Let me rephrase. Strike that
question. Did you have the ability to modify
these answers before you signed it?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 59 of 107 PageID #:1367

GLENN EVANS
February 29, 2016
34 (Pages 130 to 133)
Page 130
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 I'm sorry?
Q Did you have a chance to modify -A No.
Q Why not?
A I don't know what you mean "why not."
Q Why don't we look at Question Number
7. Have you had an opportunity to read
Question Number 7 in Exhibit Number 5?
A Yes.
Q And in response to that question, do
you list the lawsuits where you have been named
a defendant or a plaintiff?
A I see the matters listing where I was
either the plaintiff or the defendant, yes.
Q Would you like to modify this answer?
A Yes.
Q All right. How would you like to
modify this answer?
A Address the broadness, the
burdensome, the lack of foundation and the
additional information required in regards to
each of these complaints.
Q Is there any additional lawsuit that
you would like to add where you were either a

Page 132
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 Yes, it's possible.
Q Which ones are they?
A I don't know offhand because I
haven't been served with a couple of them, but
I'm fairly sure there's one or two out there.
Q Did Ricky Williams sue you?
MR. BATTLE: Jesus, really?
Objection, I think you know the basis. Go
ahead and answer his question.
BY THE WITNESS:
A Yes.
BY MR. MORRISSEY:
Q Were you served that complaint?
A I believe so, yes.
Q Are you aware of the names of any
other lawsuits that are not listed on this
answer?
MR. BATTLE: Same objection that this
is a matter of public record. We've
answered this question three times. His
interrogatory answers were from December of
2013, two years and three months ago.
You've had ample -MR. MORRISSEY: Well, his attorney --

Page 131
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

defendant or a plaintiff?
MR. BATTLE: I'm going to object on
the grounds that the lawsuits that
Mr. Evans is involved in or has been
involved in are a matter of public record.
It's a waste of time to be going through
this. Go ahead and answer, if you can.
BY THE WITNESS:
A That's just -- There's no reason why
I would like to -- or dislike to add any
question (sic). I don't have to lie and
obscure any adversary information against me.
I just want this record to be accurate and
complete; and based on this current
configuration, it's neither accurate nor
complete.
BY MR. MORRISSEY:
Q All right. Are there any additional
lawsuits that have not been included in the
answer to Number 7?
A I'm sorry?
Q Are there any lawsuits that you're
aware of that have not been included in answer
to Number 7?

Page 133
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. BATTLE: Can I finish with my
objection? You've had ample opportunity to
review the public record to determine if
there are any other lawsuits that you would
like to ask about that could have been
added to this.
MR. MORRISSEY: I believe his
attorney has an obligation to supplement
discovery responses, but that's another
issue.
BY MR. MORRISSEY:
Q For the answer in Number 7, which
lawsuits were you named a plaintiff, based on
your understanding?
A I guess the ones with my name on
them.
Q So tell me which lawsuit you were the
plaintiff?
A That I was the plaintiff?
Q Yeah.
A The one that predicates Williams
versus Fudge, Incorporated (sic).
Q Any other ones?
A No, then -- Like I said, this is not

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 60 of 107 PageID #:1368

GLENN EVANS
February 29, 2016
35 (Pages 134 to 137)
Page 134

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 complete list. So I couldn't tell you at
this point.
Q Have you ever met Mayor Emanuel?
MS. KUPE-ARION: Objection,
relevance.
MR. BATTLE: I'll join.
MS. HARRIS: Join.
MR. BATTLE: He said have you ever
met Mayor Emanuel?
BY THE WITNESS:
A Yes.
BY MR. MORRISSEY:
Q How many times have you met with
Mayer Emanuel?
MS. KUPE-ARION: Objection,
relevance.
MR. BATTLE: Same.
MS. HARRIS: Join.
BY THE WITNESS:
A What do you mean, formally or
informally.
BY MR. MORRISSEY:
Q Well, let's first go through the
formal meetings.

Page 136
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 I don't understand that question.
BY MR. MORRISSEY:
Q After criminal charges were brought
against you, did you ever have a conversation
with Mayer Emanuel?
MS. KUPE-ARION: Objection,
relevance.
MS. HARRIS: Join.
MR. BATTLE: Yeah, this is going way
too far. Counsel, I've given you a lot, a
lot of leeway with respect to your
questions about 25-year-old CRs and so on
and so forth, but you're going way beyond
the expanse of Monell claims or any claims
that Rita King may possibly have against my
client. I think you are borderline abusing
the discovery process in this deposition.
I read through the transcript of your
original deposition, and it looked like you
were on track with just getting to the
brunt of -- the meat of this case. I
haven't heard you mention anything about
April of 2011 yet, and we've been in here

Page 135

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 I don't recall how many times I met
him formally.
Q How many times have you met
informally with the mayor?
MS. KUPE-ARION: Objection,
relevance.
MS. HARRIS: Join.
BY THE WITNESS:
A I don't recall.
BY MR. MORRISSEY:
Q Have you ever had a meeting with
Mayor Emanuel regarding your responsibilities
as a member of the police department?
MS. KUPE-ARION: Objection,
relevance. Objection, form of the
question.
MS. HARRIS: Join.
MR. BATTLE: And foundation. Go
ahead, Glenn. You can answer.
BY THE WITNESS:
A I really don't understand that
question.
MR. BATTLE: Tell him you don't
understand the question.

Page 137
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 two and a half hours. I mean, this is
getting ridiculous. Go ahead and restate
your question so he can respond.
BY MR. MORRISSEY:
Q Do you remember my question?
A I believe your question was did I
meet with the mayor regarding -- or after the
falsified, contrived, perjured criminal charges
that were placed again me. The answer is no.
Q Under what circumstances would you
have a formal meeting with Mayor Emanuel prior
to the criminal charges being brought against
you?
MS. KUPE-ARION: Objection to the
form of the question, relevance.
MS. HARRIS: Join.
MR. BATTLE: Let's lay some
foundation. Are you speaking of as his
time as commander? as his time as a
lieutenant? his time as a police officer?
You have no foundation to your question.
So that's my objection to foundation. If
you lay a proper foundation, maybe we can
get in and out of here.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 61 of 107 PageID #:1369

GLENN EVANS
February 29, 2016
36 (Pages 138 to 141)
Page 138
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. MORRISSEY: Well, if the deponent
has a problem with my question -MR. BATTLE: I have a problem with
the question, Counsel. Are you going to
lay a proper foundation or do you want me
to -- Do you want to go through this the
hard way?
MR. MORRISSEY: I would rather just
see if the witness can answer the question.
You've made your objection.
MR. BATTLE: Fair enough. Go ahead
and see if you can answer the question.
BY THE WITNESS:
A I met with -- or I had contact with
the mayor. I wouldn't characterize them as
meetings because I don't recall ever having a
formal meeting with him. We met at events and
we met at social functions regarding public
safety.
BY MR. MORRISSEY:
Q Have you ever had a conversation with
Mayer Emanuel regarding IPRA?
MS. KUPE-ARION: Objection,
relevance.

Page 140

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

there is for attorneys, physicians,
politicians, 19th Ward personnel.
MR. MORRISSEY: Let's take a break.
(WHEREUPON, a short
break was had.)
BY MR. MORRISSEY:
Q Do you know Officer Kevin Rodgers?
A Do I know an officer who?
Q Kevin Rodgers?
A Yes.
Q Is he retired presently?
A I don't know what the status is.
Q In April of 2011, did you work with
Officer Rodgers?
A We were assigned to the same
district.
Q That would be the 6th District?
A Yes.
Q What was his assignment during that
period?
MR. BATTLE: His assignment or -BY MR. MORRISSEY:
Q Officer Rodgers' assignment during
that period?

Page 139
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MS. HARRIS: Join.
1
MR. BATTLE: Same.
2
BY THE WITNESS:
3
4
A I don't recall having any
conversation with the mayor regarding IPRA. In 5
6
fact, I'm going to say, at this point, no, I
7
didn't.
BY MR. MORRISSEY:
8
Q Did you ever have any conversation
9
with Mayer Emanuel regarding the code of
10
silence in the police department?
11
MS. KUPE-ARION: Objection, relevance
12
and this is really getting at being
13
harassing, not just to the deponent but
14
also the mayor of the city.
15
MS. HARRIS: I'm going to object,
16
assumes facts not in evidence, foundation.
17
MR. BATTLE: And I'm going to object
18
to foundation.
19
THE WITNESS: Answer?
20
MR. BATTLE: Go ahead.
21
BY THE WITNESS:
22
23
A I don't believe there is a code of
24
silence in the police department, no more than

Page 141

A To my recollection, he had multiple
assignments.
Q What do you recall his assignments
were?
A Patrol and lockup.
Q In April of 2011, what were the
responsibilities of a lockup keeper in the 6th
District?
MS. KUPE-ARION: Objection,
competence.
MS. HARRIS: I'll join.
MR. BATTLE: And he's not a (30(b)(6)
witness. You're asking him for his
personal knowledge, correct?
BY MR. MORRISSEY:
Q All of these questions, sir, are
based on your personal knowledge.
A Personal knowledge? Manage lockup
operations and manage the prisoners.
Q Would the lockup keeper in the 6th
District have a post?
A Have a what?
Q Have a post.
A A stationary post?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 62 of 107 PageID #:1370

GLENN EVANS
February 29, 2016
37 (Pages 142 to 145)
Page 142
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 Correct.
A No.
Q Would that individual have a
designated desk?
A A designated desk?
Q Correct.
A I don't know what designated desk -I don't know how to answer that. I wouldn't -I don't know how to answer that.
MR. BATTLE: So ask him to rephrase
the question because usually that helps.
BY THE WITNESS:
A Yeah, could you rephrase that?
BY MR. MORRISSEY:
Q Was there a desk in the 6th District
lockup in April of 2011?
A There's multiple desks in the lockup,
6th District lockup.
Q How many desks?
A I don't recall but at least two, two
or three. I don't know if you call them desks,
more like work stations.
Q Would each work station have a
computer?

Page 144
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 I have been out of that district
going on five years, so I don't recall at this
point.
Q Do you know whether that camera was
operational?
A I have been out of that district five
years. I don't recall at this point.
Q If equipment was not operational in
the 6th District, to your knowledge, would
there be records generated to reflect that
information?
A As a matter of policy, I believe so.
Q What is that log called?
A I'm sorry?
Q Based on your understanding of the
policy at the time, how would the 6th District
make a record that equipment was not
operational?
A Various ways. You can notify the
command office or equipment and supplies or our
IT section depending upon the nature of the
outage and the damage.
Q If a surveillance camera was not
operational in April of 2011, to your

Page 143

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 I don't recall. Some do. Some
don't.
Q Did each work station have a
telephone?
A I don't recall if each work station
has a telephone.
Q In April of 2011, to your knowledge,
did the 6th District lockup have a camera?
A Yes.
Q Where was the camera located?
A The camera was in the processing
area, I believe.
Q To your knowledge, what was the
purpose of that camera?
A Photograph prisoners. Photograph
processed individuals. I don't want to call
them prisoners. Photograph processed
individuals.
Q Was there a surveillance camera in
the lockup of the 6th District in April of
2011, to your knowledge?
A I'm going to say possibly.
Q Where was that surveillance camera
possibly located?

Page 145
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

knowledge, who would you report that to?
A It depends on the nature of the
outage. If it was a physical nature, it would
be general services. If it was a technical
nature, it would be IT -- I mean, a
software-based database issue.
Q When you were assigned to the 6th
District, did you ever patrol with Officer
Rodgers?
A Not that I can recall, no. It's
possible we have been on the street; but in
terms of patrolling together, you mean working
together or being out in the district at the
same time being on the street at the same time.
Q What about in the same car with
Officer Rodgers patrolling the streets?
A No, no.
Q When you were a lieutenant in the 6th
District, did you ever work lockup?
A Lockup duties were a part of my
function.
Q As a lieutenant in the 6th District,
what would you do in the lockup?
A Check the facility, check the

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 63 of 107 PageID #:1371

GLENN EVANS
February 29, 2016
38 (Pages 146 to 149)
Page 146

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

operations and monitor prisoners.
Q In April of 2011, did the 6th
District lock up female arrestees?
A Yes.
Q Where in the 6th District would the
CPD lock up female arrestees?
A I'm sorry?
Q What part of the -- Strike that. In
April of 2011, where in the 6th District would
female arrestees be locked up?
A Why would they be locked up?
Q Where would they be locked up?
A In the facilities, in the general
prisoner processing facilities.
Q In April of 2011, would the 6th
District house female arrestees overnight in
the 6th District?
A It depends on operational needs. I
don't know if they get overnight as a policy,
so I can't answer that.
Q In April of 2011, did you work with
Officer Sutton?
A We were assigned to the same watch
temporarily.

Page 148
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MR. MORRISSEY: Training officer.
MR. BATTLE: A training officer.
BY MR. MORRISSEY:
Q Was Officer Sutton a training officer
in April of 2011?
MS. HARRIS: I'm going to object on
foundation, speculation and form.
MR. BATTLE: You can answer, if you
know.
BY THE WITNESS:
A I don't know, a formal training
officer or informal training officer.
BY MR. MORRISSEY:
Q What's the difference between a
formal and informal training officer?
MS. HARRIS: Objection, foundation,
speculation.
MS. KUPE-ARION: And competence as a
(30(b)(6) witness, for not being one.
MR. BATTLE: And I'll join in those
objections. Go ahead and answer, if you
can.
BY THE WITNESS:
A If she was designated as a field

Page 147

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 Which watch was that?
A I believe it was the second watch.
Q What hours of the second watch?
A They varied.
Q Can you give me the range?
A From approximately 4:00 o'clock in
the morning until 6:00 o'clock in the
afternoon, early evening.
Q Did you ever patrol with Officer
Sutton?
A No.
Q To your recollection, what were
Officer Sutton's duties in April of 2011?
MS. HARRIS: I'm going to object on
speculation, foundation.
BY THE WITNESS:
A I believe she was assigned to a beat
car on that day.
BY MR. MORRISSEY:
Q Was she a training officer in April
of 2011?
MR. BATTLE: What's that?
MS. HARRIS: Counsel, what did you
say?

Page 149

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

training officer, she would be a formal
training officer. If she was not designated,
she would be an acting or a temporary field
training officer.
BY MR. MORRISSEY:
Q Do you know an officer by the name of
Clifford?
A No, I don't know him personally.
Q Did you supervise Officer Clifford in
April of 2011?
A I supervised an entire watch, and I
would say he's one of them.
Q On April 10th, 2011, were you the
watch commander in the 6th District?
A I was the acting watch commander.
Q What were your responsibilities as
the acting watch commander?
A Managed the duties of subordinate
personnel.
Q As a lieutenant in the 6th District,
how frequently would you act as the watch
commander?
A You have to give me a baseline to
formulate a response on.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 64 of 107 PageID #:1372

GLENN EVANS
February 29, 2016
39 (Pages 150 to 153)
Page 150

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 it occur once a week?
A It varied.
Q On April 10th, 2011, were you
familiar with how to function in the capacity
as the acting watch commander in the 6th
District?
A Yes.
Q In April of 2011, to your knowledge,
were there any general orders or special orders
regarding how department members should
interact with arrestees known to have mental
illness?
MR. BATTLE: Basing that on your
personal knowledge, go ahead.
BY THE WITNESS:
A There were directives that addressed
that, I believe.
BY MR. MORRISSEY:
Q After April of 2011, are you aware of
a CPD general order relating to that issue?
A That's kind of broad, could you be a
little bit more specific.
Q What's the difference between a GO
and a directive?

Page 152

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 What did it vary on?
A There's written directives. There's
on-the-job training, there's video directives
and there was a combination of all three in
addition to classroom didactic.
Q In April of 2011, were you aware of
any training by the CPD with how to interact
with an arrestee in the department, in the
police department, known to have mental
illness?
MR. BATTLE: I'm going to object to
that. You have characterized mental health
issues or mentally ill persons, but that's
rather vague and overly broad and it
doesn't really -- There's no real
definition of it. You could be
schizophrenic. You could be psychotic.
You could be borderline, you know, PTSD.
There's no real definition of that type of
person. So we're not sure exactly what
you're targeting.
MR. MORRISSEY: Okay.
MR. BATTLE: Go ahead. You can

Page 151
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 A GO is an acronym. A directive is a
standing order dispersed through an
organization.
Q Is there any difference to your
knowledge -- based on your knowledge between a
general order and a directive?
A General order is, by nature, a
directive but not all directives are general
orders.
Q What CPD directive was in effect in
April of 2011 relating to arrestees with mental
illness?
A Sir, I would have to review the order
in order to formulate a correct response.
Q Are you familiar with the training
that CPD members had in April of 2011 when they
encountered an arrestee with mental illness?
MS. KUPE-ARION: Based on his own
knowledge?
MR. MORRISSEY: Yes.
BY THE WITNESS:
A Speaking on my own knowledge and not
the city of Chicago department policy, it
varied.

Page 153
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

answer, if you can.
BY THE WITNESS:
A I concur with counsel. If you're
talking about mental illness within the
capacity of an aberration, you have individuals
with attention deficit disorders, you've got
gifted individuals and you've got other
individuals that have high levels of interface
interaction with those of emotional
intelligence, and you've got those that have a
deficit in those cognitive skills. So you have
to be more specific as to that training.
BY MR. MORRISSEY:
Q Were you given training about how a
department member would interact with people
with those various mental illnesses
differently?
A If you could be more specific with
the mental illness, I would be in a better
position to answer it, I believe.
Q Well, did the city give you training
about circumstances where you would treat
certain individuals differently with mental
illness than other individuals?

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 65 of 107 PageID #:1373

GLENN EVANS
February 29, 2016
40 (Pages 154 to 157)
Page 154
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 The city is not in a position in my
estimation to train me as a psychologist or
psychiatrist. I don't think that's a response
I can formulate.
Q Do you remember giving a statement to
IPRA relating to your involvement with Rita
King?
A Yes.
Q When was the last time you reviewed
that statement?
A I did a cursory review of it a couple
of days ago but nothing in depth.
Q Have you ever reviewed that statement
in depth?
A No.
Q Did you have an attorney present when
you gave that statement?
A No.
Q Did you have the option to have one?
A Did I have the option to have an
attorney at that time? In the command level,
essentially, no, you don't get an attorney.
Q Who told you you didn't have the
ability to have an attorney present?

Page 156
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

cursory review.
BY THE WITNESS:
A I would have to review the statement
in order to make that determination.
BY MR. MORRISSEY:
Q Were you provided the opportunity to
review the statement after you gave the
statement to IPRA?
A You mean directly there?
Q Correct.
A No.
Q Are you aware that the statement was
written up by a court reporter?
A If that's what you have in your hand,
I would assume it was.
Q Do you remember on April 10th, 2011
Officer Sutton asking you to come to lock up to
assist with Ms. King?
A I don't recall who asked me to come
to the lockup to assist with Ms. King. I
really don't recall.
Q Would you agree your memory was more
fresh when you gave the statement to IPRA than
it is today relating to the incidents with

Page 155
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 It's based on if you retain your
union status as a lieutenant and pay the
requisite dues, the union from which you
received your appointment would give you an
attorney but; if you didn't, then they
wouldn't.
Q Could you have paid out of pocket to
retain a lawyer to represent you during that
statement?
A I could have.
Q Would you agree that you gave the
statement on November 7, 2013 to Investigator
Franko?
A I would have to review the documents.
Q When you gave that statement, were
you telling the truth?
A I tell the truth in all of my sworn
statements whether court or administrative
hearings. I stand by what I say.
Q Is there anything in your statement
that you would like to change?
MR. BATTLE: Objection, do you want
him to review the entire statement and then
ask that question? He said he gave it a

Page 157
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Ms. King?
MR. BATTLE: Related to the questions
as in that statement?
BY THE WITNESS:
A Are you saying that the statement -my recollection was better at the time I gave
that statement than it is now?
BY MR. MORRISSEY:
Q Correct.
A No, I'm going to say that because of
the relative innocuous events, when I mean
innocuous, I'm not downplaying the severity of
her alleged injuries that did not occur at my
hand. I'm just saying that in the totality
because I do not recall all of the minutia of
that statement at that time or the statement I
gave to IPRA. I do not recall all of the -all of the -- the entire incident. I just have
a salient recollection.
Q Do you remember being asked these
questions and giving these answers, Question:
On 10 April 2011, Ms. Rita King was arrested by
Officers Roslyn Sutton and Dennis Clifford and
transported into the 6th District station.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 66 of 107 PageID #:1374

GLENN EVANS
February 29, 2016
41 (Pages 158 to 161)
Page 158

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Please tell me the circumstances regarding your
initial contact with Ms. King while in the 6th
District station.
Answer: I went to the lockup because
the officer stated that she was drunk or high
and had mental issues, and they were having
problems processing her and controlling her.
Question: So both officers talked
with you? Answer: Yes. Question: Officer
Sutton? Answer: Primarily Officer Sutton but
both of them pretty much echoed each other's
statements and assessments. Do you remember
being asked those questions and giving those
answers?
MR. BATTLE: I'm going to object
because it's improper impeaching.
MR. MORRISSEY: I'm not impeaching
him.
MR. BATTLE: Yeah, you're not
impeaching him. You're asking him -MR. MORRISSEY: It's -MR. BATTLE: Let me finish my
objection, Counsel. You wonder why I talk
over you and I raise my voice. That's why.

Page 160
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

objection.
MR. BATTLE: That's what I'm trying
to do, but you stopped me.
MR. MORRISSEY: Are you going to
instruct your client not to answer?
MR. BATTLE: I'm going to make my
objection.
MR. MORRISSEY: That's fine.
MR. BATTLE: Do you want me to do
that first before you finish?
MR. MORRISSEY: That's fine. That's
fine.
MR. BATTLE: Can I make it now?
MR. MORRISSEY: You can do whatever
you want.
MR. BATTLE: I object because I think
that's improperly impeaching. I think
you're trying to get him to verify a
statement that he's already verified and
indicated that it was truthful, and I think
that that's an improper question and it
doesn't have foundation.
MR. MORRISSEY: That's fine.
MR. BATTLE: That's all I wanted to

Page 159
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

I'm trying to make an objection. Whether
you agree with it or not, I understand.
MR. MORRISSEY: I never asked him a
question to impeach him. I asked him
whether he -- It's not impeachment.
MR. SCHUMANN: So what is it?
MR. MORRISSEY: What is it?
MR. SCHUMANN: Yeah.
MR. MORRISSEY: It's a statement by a
party.
MR. SCHUMANN: Yeah, but you have the
statement in your hands.
MR. BATTLE: So the statement speaks
for itself.
MR. SCHUMANN: So why are you asking
him about the statement?
MR. MORRISSEY: Because I'm asking
him whether he was asked those questions
and gave those answers. That's my only
question.
MR. BATTLE: Right, do you understand
that that's an improper question for a
deposition?
MR. MORRISSEY: You can make that

Page 161
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

do.
MR. MORRISSEY: That's fine.
MR. BATTLE: You can answer, if you
can.
BY THE WITNESS:
A That's my recollection. If I made a
statement to IPRA and I signed the statement or
I agreed to it, I stand by the content of my
responses, each and every one; but if you're
going to ask me do I have a better recollection
then as I do now, and I'm going to tell you I
don't recall the incident any better now than I
did then.
BY MR. MORRISSEY:
Q The only question was do you recall
being asked those questions and giving those
answers to IPRA?
A Those specific questions, no, I don't
recall being asked those specific questions.
Q Would you like me to show you the
transcript where you were asked those questions
and you gave those answers?
A Yeah, I'm not denying it but I have
given lots of statements, and I don't recall

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 67 of 107 PageID #:1375

GLENN EVANS
February 29, 2016
42 (Pages 162 to 165)
Page 162
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

each and every one.
Q Did Officer Sutton tell you Ms. King
was either high, drunk or had mental issues?
A That's the information I got from
both of them.
Q Where did both of these officers tell
you that information?
A What do you mean "where"? In the 6th
District police station.
Q Correct. Where in the 6th District?
A I don't recall exactly where. It
might have been in an office, might have been
in the hallway, might have been in the lockup
area. Might have been in the processing area,
might have been a combination of all four. I
don't recall specifically where.
Q Did either Officer Sutton or Officer
Clifford tell you why they were having problems
processing and controlling Ms. King in the
lockup?
A Did they tell me why they were having
problems processing her?
Q Correct.
A I guess due to --

Page 164
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 room.
BY THE WITNESS:
A Possibly.
BY MR. MORRISSEY:
Q What do you remember either Officer
Sutton or Clifford telling you about their
efforts to encourage Ms. King to cooperate in
the lockup?
A I don't recall the entire context of
the conversation. It was just a general
conversation. They brought her in the lockup,
tried to process her. She wasn't cooperating.
Q Did either Officer Sutton or Clifford
tell you how long Ms. King had been in the
lockup and was not cooperating?
A I don't recall if they did. It's
entirely possible.
Q Is there anything that could refresh
your memory about that issue?
A You can present me with any documents
regarding that specific incident. I'll do my
best.
Q Did you take any notes after Officer
Sutton or Clifford approached you?

Page 163

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 I'm not asking you to guess. I'm
asking did they -- did Officer Sutton -A I was responding to your question.
If you want to be -MR. BATTLE: Just answer his
question.
BY THE WITNESS:
A -- rude about it, I'll -- Okay,
repeat your question.
BY MR. MORRISSEY:
Q Did either Officer Sutton or Officer
Clifford tell you -A I don't remember.
Q -- why they were having problems
processing and controlling Ms. King in the
lockup?
A I don't remember.
Q Did either Officer Sutton or Clifford
tell you the efforts they made to encourage
Ms. King to cooperate in the lockup?
MR. BATTLE: You're talking about
prior to?
MR. MORRISSEY: Prior to coming in.
MR. BATTLE: Prior to you going in

Page 165

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 Did I take any notes?
Q Correct.
A Not that I can recall.
Q Did you have an office in the 6th
District in April of 2011?
A The watch commander had an office,
and I was working out of there.
Q Where is the watch commander's
office?
A Inside the 6th District station.
Q Where specifically in the 6th
District?
A First floor, south end of the
building.
Q Where within that building is the
lockup area in the 6th District?
A South end of the building.
Q Based on your experience -A First floor.
Q How far is the watch commander's
office from the lockup in 6th District?
A Are you talking about the lockup
facility? Across the hall. I don't know the
exact square footage.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 68 of 107 PageID #:1376

GLENN EVANS
February 29, 2016
43 (Pages 166 to 169)
Page 166
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 How long would it take you in April
of 2011 to walk from the watch commander's
office to the lockup?
A It depends, generally within a
minute.
Q When you were first approached by
Officer Clifford, did he tell you whether
Ms. King was being physically abusive?
A I don't recall any conversation or
any contact I had with Mr. Clifford, Officer
Clifford, at this time.
Q And would the same answer be true for
Officer Sutton at this time?
A I don't recall the specifics of the
conversation, just the generalities.
Q And does that generality include the
fact that there was an arrestee in the lockup
that was either drunk, high or had mental
illness and there were problems processing and
controlling her?
A I'm going to say that was factual.
Q Did Officer Sutton or Clifford tell
you how they were having problems controlling
Ms. King in the lockup?

Page 168
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

and they're prohibited by law and department
policy, and they can't search. It depends on
the legalities and nature of the stop.
Q Did either Officer Clifford or
Officer Sutton tell you they were fearful for
their safety when you were initially approached
by them?
A Fearful for his safety? They had
apprehensions about engaging her.
Q Did they tell you they had
apprehensions about engaging Ms. King in the
lockup when you were initially approached by
them?
A Yes.
Q What did they tell you specifically?
A I can't tell you specifically. That
was five years ago.
Q Did they explain their apprehensions
about engaging Ms. King?
A They gave me the generalities
regarding their apprehensions, but I observed
her behavior for myself.
Q Did either Officer Sutton or Clifford
tell you Ms. King was crying in the lockup?

Page 167
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 Specifically?
Q Specifically.
A I guess overall physically
handcuffing and physically handling -- I
misspoke. Physically handling and handcuffing.
Q Did they tell you whether Ms. King
was handcuffed in the 6th District lockup?
A Don't recall that.
Q Are arrestees typically handcuffed
when they are in the lockup being processed?
A It depends on the circumstances.
Q Under what circumstances would he or
she be handcuffed?
A The level of combativeness or the
inherent threat to the officers or other
prisoners.
Q Are arrestees typically searched
before they are brought into the 6th District
lockup for processing?
A Yes.
Q And that search would include a
search for weapons, correct?
A It depends on the circumstances of
the search. Some of the searches are intrusive

Page 169
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 Both of them I think at one point
said she was engaging in behavior which
entailed, at one point, crying.
Q Was your district short on staff that
day?
A That's really not a question I can
answer because it all depends on operational
needs.
Q As you sit here today, do you recall
any operational needs that day that strained
your staff?
A I'm going to say that the district
was ensconced within one of the highest crime -THE REPORTER: Was what?
MR. BATTLE: Ensconced.
THE WITNESS: E-n -THE REPORTER: I got it.
THE WITNESS: I've been to college.
I can help.
BY THE WITNESS:
A During that time, during that frame -During that frame of time, we had significant
issues with public violence and that in order
to address the public violence, I made the

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 69 of 107 PageID #:1377

GLENN EVANS
February 29, 2016
44 (Pages 170 to 173)
Page 170
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

effort to ensure adequate manpower and coverage
to our affected areas in order to mitigate the
violence.
BY MR. MORRISSEY:
Q Prior to April 10 of 2011, had you
ever encountered Ms. King before?
A I'm going to say yes.
Q How many times prior to April 10,
2011 did you encounter Ms. King?
A To the best of my recollection, a
minimum of three times.
Q Can you tell me the first time you
encountered her?
A I can't recall the first time I
encountered her. I don't recall.
Q The second time?
A I can tell you previous occasions. I
can't give you the first, second or third time.
Q Tell me -- Explain your recollection
of the encounters you have had with Ms. King
prior to April 10, 2011?
A There were at least one or two
occasions where I observed her outside on the
street engaging in acts of suspected

Page 172
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 Do you know whether Ms. King's name
was on any of those lists?
A I don't know. Don't recall.
Q After April 10, 2011, did you ever
encounter Ms. King?
A If I did, I don't recall.
Q Do you know whether Ms. King smoked
cigarettes in April of 2011?
A I don't know what her habits were in
terms of smoking.
Q Did you ever observe her associate
with your officers smoking?
A I don't recall her socializing with
any officers smoking. I don't recall that.
Q Prior to Officers Sutton or Clifford
approaching you on April 10th, 2011, did you
know whether Ms. King was in custody in your
district?
A No.
Q As the acting watch commander -Strike that. Did either Officers Sutton or
Clifford tell you that they had Rita King in
your lockup?
MR. BATTLE: At what point?

Page 171
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

prostitution.
There was another time where she was
frequently a guest of our lobby, and she would
stay there and sleep and frequent during times
of inclement weather.
Q Do you recall whether that was in
2011 when you observed Mr. -- Ms. King on the
streets engaging in alleged acts of
prostitution?
A I don't recall the exact dates and
times.
Q Would your district allow people to
come in and get out of the cold?
A Absolutely.
Q Was there a specific area in the
district where people could congregate to get
out of the cold?
A A specific area, they pretty much had
free rein over the public area of the lobby.
Q Did your district record the names of
who stayed at times in the public area of the
district?
A For those who were seeking permanent
or long-term shelter, I believe they did.

Page 173
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 they initially approached you.
A When they initially approached me?
Q Yes.
A You mean did they name her by name?
Q Correct.
A Not that I could recall. It's
possible.
Q Prior to April 10, 2011, did you know
Ms. King had mental illness?
A Depending upon what your definition
of mental illness is, I would have to ask you
for clarification.
Q Well, did you use the term "mental
issues" when you gave a statement to IPRA?
A That's entirely possible. I would
have to review my IPRA statement.
Q What do you mean by "mental issues"
when you use it?
A That's pretty much like I inferred
earlier. It's a pretty broad standard. It
could be somebody with a high level of
intelligence, high level of emotional
intelligence. It could be somebody with

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 70 of 107 PageID #:1378

GLENN EVANS
February 29, 2016
45 (Pages 174 to 177)
Page 174
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

bipolar manic depressive. It could be somebody
who is suicidal. It could be somebody with
dyslexia.
Q On the one or two occasions where you
observed Ms. King prior to April 10, 2011, did
you think she had mental issues?
MR. BATTLE: Objection. That
mischaracterizes his testimony. Go ahead
and answer.
BY THE WITNESS:
A She previously -- I didn't think she
had anything until she told me.
BY MR. MORRISSEY:
Q Prior to April 10th, 2011, did she
ever tell you that she had mental issues?
A When I stopped her on the street, she
made comments that she had mental health issues
among her substance abuse and her general
unlawfulness, which she sometimes masked her
unlawfulness with the pretense of it being
mental health issues.
Q When you stopped Ms. King on the
streets, did you arrest her?
A Did I arrest Ms. King?

Page 176
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

streets and reported to have mental health
issues along with other concerns like substance
abuse problems, correct?
A She had other concerns like she was
breaking the law, being belligerent, being
confrontational and being uncooperative.
Q Did she explain the mental health
issues that she suffered from that day?
A She said I'm bipolar depressive, but
I got other things going.
Q That's bipolar depressive?
A She said she was bipolar and manic.
Q Manic depressive?
A She said bipolar and manic. She was
all over the place. I believe the one time I
contacted her, she was involved in some kind of
confrontation and she was agitated based on
that confrontation.
Q Do you know whether any officer did a
search of her when she was engaged by the CPD?
MR. BATTLE: At which time?
BY MR. MORRISSEY:
Q At the time when you were present and
she was stopped on the street.

Page 175
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 Correct.
A No.
Q Did you review her identification
card when you stopped her on the streets prior
to April 10, 2011?
A No. That would have been for a
subordinate officer to do. It's entirely
possible that one was done, but I don't recall.
Q Were you in the same vehicle as a
subordinate officer?
A I don't recall if I was in a vehicle
with a subordinate officer or not.
Q Do you know whether the subordinate
officer created a contact card?
A I know that she's had contact cards
previously done on her.
Q Have you ever been present when an
officer or a member of the CPD generated a
contact card for Ms. King?
A On her specifically, I cannot recall
being present when anybody did a field contact
card on Ms. King.
Q So you were present on at least one
occasion when Ms. King was stopped on the

Page 177
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 I would have to review department
records to make that determination.
Q Was she acting crazy during that
time?
A I wouldn't -- Define "crazy."
Q So what else do you recall when you
stopped Ms. King prior to April of 20 -- April 10,
2011 when she reported that she was bipolar and
manic?
A There was a couple of times I think I
had encounters with her. A couple of times she
was in the station where we keep her and feed
her and take care of her and keep her off the
street. Then she would get confrontational
with other patrons and homeless individuals,
then she would be ejected.
Q So prior to April 10, 2011, there was
more than one occasion when Ms. King was asked
to leave the 6th District because she was being
confrontational while she was seeking services?
A She wasn't seeking services. She was
seeking shelter; and I mean seeking shelter,
I'm talking about a place to sleep and hang
out.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 71 of 107 PageID #:1379

GLENN EVANS
February 29, 2016
46 (Pages 178 to 181)
Page 178
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 So prior to April 10, 2011, there
were multiple times when Ms. King was asked to
leave the 6th District when she was seeking
shelter because she was confrontational?
A No, you're making it sound like we
threw her out because she was confrontational.
She had other issues. She wasn't seeking
shelter. She already had shelter. She was
being confrontational and impairing the
operational needs in the facility, security and
the security of patrons and the security of
other individuals seeking services as well.
That being said, that's why she asked
to be ejected, and I'm not talking about just
ejected. She had the option of getting in the
wagon and getting mental health treatment if we
transported her there; and she would decline
and storm out the station on her own.
Q And this occurred more than once
prior to April 10, 2011?
A I'm going to say to the best of my
recollection, yes, it did.
Q More than two times?
A I don't know exactly because I didn't

Page 180
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

shelter. She was laying in the lobby sleeping
or getting into conflicts in the station.
Q So you knew prior to April 10, 2011
she had been in the 6th District as a free
person sleeping in the lobby?
A Yes.
Q Did you ever observe her being asked
to leave by members of the department in the
6th District prior to April 10th, 2011?
A I believe I might have been there on
one occasion, but she was there so regularly.
It's hard to discern that information.
Q When she was asked to leave on the
possible one occasion when she was in the 6th
District, did she self-report to members of the
6th District that she was bipolar and manic?
A Every time she indicated those issues
in my presence, we said we'll take you to
Jackson Park Hospital, and she would decline.
She would storm out the station.
Q Would she be banned from the station
permanently?
A No.
Q Did you observe Ms. King engage in

Page 179
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

focus on Ms. King per se. So I don't know
absolutely everything or every situation every
circumstance. I just have a cursory
recollection of Ms. King hanging around the
station and Ms. King pursuant to this event
right here.
Q But prior to April 10th, 2011 you
knew her name?
A I knew her name?
Q Correct, is that fair to say?
A Did I know her entire name? I'm
going to say I did know her first name. I
don't know if I knew her entire name.
Q And it was in your presence that she
was asked to leave the 6th District prior to
April 10, 2011 because she was being
confrontational?
A No, that was not in my presence.
That was information that I received from
officers regularly assigned to the desk.
Q Were you ever present when Ms. King
was in the 6th District seeking shelter prior
to April 10, 2011?
A I seen her -- She wasn't seeking

Page 181
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

prostitution prior to April 10, 2011?
A Suspected prostitution, yes.
Q Do you recall -- What do you recall
from that suspected prostitution?
A She was standing on the corner or on
the street sometimes with minimum garb flagging
down vehicles occupied by solitary males.
Q Did you have the ability to arrest
her during that time?
A And charge her with soliciting, yes.
Q And you decided against charging her?
A Yes.
Q Why?
A Because, Number 1, it's discretion.
Number 2, I consider a lot of prostitution to
be more of a victimization, a self-victimization,
as opposed to an overt criminal act. Number 3,
she had substantive mental health issues that
outweighed the need for directed enforcement.
We can make a determination if -- We can make a
determination to bypass charging and direct
people to mental health services, but they have
to agree for the most part.
Q So after you were approached by

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 72 of 107 PageID #:1380

GLENN EVANS
February 29, 2016
47 (Pages 182 to 185)
Page 182
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

either Officer Sutton or Clifford, how soon did
you go into the lockup?
A I don't know all of the specifics,
maybe within a couple of minutes.
Q And when you walked into the lockup,
where was Ms. King positioned?
A To the best of my recollection, she
was on the bench sitting down; and then she'd
stand up and then she'd walk around for a bit
and then she would sit back down.
Q When you first stepped into the
lockup, was Officer Rodgers present?
A I couldn't tell you. I can't recall
if he was present or not.
Q When you stepped into the lockup, was
Officer Sutton present in the lockup?
A I'm going to say, yes.
Q When you first stepped into the
lockup, was Officer Rodgers -- was Officer
Clifford present in the lockup?
A It's possible, but I don't recall
what Clifford looks like.
Q When you stepped foot in the lockup
on April 10, 2011, did you immediately

Page 184
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 Could you rephrase that, please?
BY MR. MORRISSEY:
Q All right. I'm going to -- Do you
remember being asked these questions and giving
these answers when you gave your statement to
IPRA, Question: Okay, so what is the protocol
if someone comes back there into the lockup
area and they are refusing to cooperate?
Answer: What I usually do -- What we
usually do is we try to persuade them to
cooperate. Eventually, they do. If they do
not cooperate by -- generally by the tour of
the duty or by the time that the relieving
watch commander comes on, we note that in our
records and let the relieving watch commander
know that this person will not be fingerprinted
or photographed, so we have to hold them over;
but during the tour of duty, if they allow us
to fingerprint and photograph them, then we
just process them. We get a lot of people that
initially don't want to cooperate; but when
they calm down, they subsequently do.
Do you remember being asked those

Page 183
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

recognize the arrestee was Rita King?
A Did I immediately recognize her from
the lobby, yes. From being in the lobby and
getting shelter and us feeding her and taking
care of her and giving her shelter, I recall
her being in the 6th District lockup, yes.
Q When you first saw Ms. King, was she
crying?
A She was -- To the best of my
recollection, she was crying and she was
yelling and then she was screaming and then she
was argumentative.
Q In April of 2011, was there a
protocol at the 6th District if somebody is in
the lockup and they are refusing to cooperate?
MR. BATTLE: Objection, incomplete
hypothetical.
MS. HARRIS: I will join in that.
MR. BATTLE: Do you understand what
he's asking?
THE WITNESS: No.
MR. BATTLE: You need to ask him to
rephrase.

Page 185
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

questions and giving those answers?
BY THE WITNESS:
A You characterized that as a protocol
when it's pretty much an operational -- you
said it's a 6th District protocol, but it's not
a 6th District protocol. It's a department-wide
procedure.
BY MR. MORRISSEY:
Q Do you remember being asked those
questions and giving those answers when you
gave a statement to IPRA?
A I would have to look at my IPRA
statement in order to refresh my recollection.
Q If I showed you that question and
answer, would you be able to answer that
question? I'm from Page 390 and Line 7 down to
Line 22.
And my question is were you asked
those questions and did you give those answers
when you gave a statement to IPRA?
A Yeah, that's a very badly worded
question, what is the protocol if someone comes
back there in the lockup area and they're
refusing to cooperate? There is no set

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 73 of 107 PageID #:1381

GLENN EVANS
February 29, 2016
48 (Pages 186 to 189)
Page 186
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

protocol. The general orders are -Q Well, Mr. Evans -MR. BATTLE: Objection. Allow him to
finish the question (sic) and then you can -MR. MORRISSEY: He's not being
responsive.
MR. BATTLE: You can clarify and say
it wasn't responsive, but you do have to
allow him an opportunity to finish his
answer.
MR. MORRISSEY: But the question
was -MR. BATTLE: I understand the
question. If he's not responsive, you can
ask him to clarify, but you do have to give
every witness an opportunity to answer your
question.
MR. MORRISSEY: I don't believe
that's normal protocol. You can ask him on
your examination of Mr. Evans.
MR. BATTLE: Okay, listen. I don't
know if you have ever tried a case but the
protocol -MR. MORRISSEY: I've tried several

Page 188
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

general orders are a misnomer.
The general orders are not a hard and
fast rule. They provide a basis, guideline and
parameter for operational procedure within the
police department. Just because -- You can
deviate from department directives as long as
you have a justified reason for doing so.
You have to look at the spirit of the
incident as opposed to the letter of the law
relevant to implementing a lot of those
department orders. The department orders are a
guideline and nothing more.
BY MR. MORRISSEY:
Q Why don't we go back to the question
I had, and I can read this portion and the only
question is were you asked these questions and
did you provide these answers? Do you want me
to reread the question?
A No, I'm going to, just for
expeditious' sake, I'm going to say based on
the documentation in your hand, those are my
responses to the best of my recollection.
Q Did you review Officer Rodgers'
deposition transcript prior to coming here

Page 187
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

cases.
MR. BATTLE: Okay, well, I've tried a
bunch more than several. The protocol
typically is you have to allow him to
answer your question whether it's a
deposition or whether it's at a trial
proceeding.
If he doesn't answer properly,
you can turn around and go back in and say,
listen, that was not responsive. Here's my
question. However, if he doesn't start off
the way you want him to, you can't cut him
off at the point of a deposition and cut
off and say that's not what I want you to
say. That is very improper. That's very
improper.
MR. MORRISSEY: Let's see what the
client has to say.
MR. BATTLE: Finish your answer.
BY THE WITNESS:
A There is no district protocol. There
is a citywide or police department-wide
operational procedure, and it's predicated upon
the edicts of the general orders, and the

Page 189
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

today to testify?
A No.
Q Have you ever reviewed his deposition
testimony in this case?
A No.
Q Have you reviewed Officer Clifford's
deposition testimony prior to coming here today
to testify?
A No.
Q Did I ask you about Sutton's
deposition testimony yet?
A No, you didn't.
Q Have you reviewed her deposition
testimony prior to coming here today?
A No.
Q Are you aware that each of those
officers -- Well, I think just Sutton and
Clifford gave a statement to IPRA. Did you
review their statement to IPRA?
A No.
Q Is the general protocol in the 6th
District if a female arrestee is brought there
that your officers when you worked there in
April of 2011 would fingerprint them, process

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 74 of 107 PageID #:1382

GLENN EVANS
February 29, 2016
49 (Pages 190 to 193)
Page 190
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

them and then send them to the 5th District,
which would be Area 2?
A What do you mean, is that a general
protocol? It depends on the circumstances.
Sometimes females are processed in the 6th
District. Sometimes they are sent to 111th
Street.
Q And is 111th Street the 5th District?
A It's an area-wide facility, yes.
Q And do they have female-designated
lockups?
A Yes.
Q Where in the 6th District is there a
secure area to place a female arrestee?
A Within the physical facility of the
6th District lockup?
Q Correct.
A They are separated rooms and
separated -- rooms separated and you can place
a female arrestee in one of those separated
processing rooms.
Q And when a female arrestee is placed
in one of those rooms, is she generally
handcuffed to a ring on the wall?

Page 192
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 To the best of my recollection, I
asked him what was going on and what's wrong
with her.
Q Did Officer Clifford respond to you?
A I think both of the officers
responded.
Q And is this the second conversation
you had with these two officers?
A I don't recall how many conversations
I've had. I might have had multiple smaller
conversations on the way to the lockup.
Q What did the officers say when you
asked what's going on?
MS. HARRIS: Objection, form, vague.
Go ahead.
THE WITNESS: Answer?
MS. HARRIS: You can answer.
MR. BATTLE: You can answer.
BY THE WITNESS:
A What did they say in regards to
Ms. King's behavior.
BY MR. MORRISSEY:
Q What did they say in response to your
question when you arrived in the lockup and

Page 191

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 Yes. Sometimes she is. Sometimes
she isn't. It depends on her risk factors and
her cooperativeness.
Q On April 10, 2011, do you know
whether those rooms were occupied in the
morning?
A Some of them were occupied, I
believe. I don't recall. Some of them
weren't.
Q When you arrived in the lockup and
you observed Ms. King there, did you have a
conversation with Officer Clifford regarding
the arrestee?
A A specific conversation?
Q Correct.
A Not that I can recall, not a specific
conversation.
Q Did you have a general conversation
with Officer Clifford when you immediately
arrived in the 6th District lockup and saw
Ms. King?
A I asked him a question or two, and he
responded.
Q What did you ask Officer Clifford?

Page 193
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

said what's going on?
A In a general search, she was
uncooperative, high on narcotics mostly and
acting irrational.
Q Do you know specifically who gave you
that response?
A No, I don't.
Q When you entered the lockup and you
first observed Ms. King, do you know who
responded to your question what's wrong with
her?
A That was five years ago. I don't
recall all of the minute details of that
exchange.
Q Did any officer present in the lockup
explain to you when you arrived the steps they
took to encourage Ms. King to cooperate?
A They said they tried to get her to
submit to fingerprinting and photograph her.
Q Who gave you that response?
A Multiple officers.
Q Can you tell me which ones?
A Once again, five-year window, I
cannot be specific as to -- but both of them

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 75 of 107 PageID #:1383

GLENN EVANS
February 29, 2016
50 (Pages 194 to 197)
Page 194
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

were pretty much echoing the sentiments of the
other.
Q Was Officer Rodgers also echoing this
message?
A I think Officer Rodgers was standing
nearby. I don't recall any verbal exchange
that he and I had.
Q Did Officer Clifford or Sutton tell
you how long they tried to encourage Ms. King
to submit to photographs and fingerprints?
A I don't remember.
Q Did either Officer Clinton or Sutton
explain to you the efforts they took to
encourage Ms. King to submit to photographs and
fingerprints?
A We had a very quick, brief and
concise and fluid exchange due to the
irrational and erratic behavior exhibited by
Ms. King.
We had an expeditious exchange
because she was posing a threat and she was
obstructing the operations of the facility. So
we didn't have a long, drawn-out-Monday-morningtype conversation with each other. It was very

Page 196

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

If they told me, and they probably did, but I
don't recall. I do not recall at this time.
Q When you entered the lockup, did you
immediately approach Ms. King?
A No, I talked to the officers first.
Q And how long did that conversation
take?
A Very quick. Maybe less than a
minute.
Q And we've already discussed the
content of the conversations, correct?
A Yes.
Q After this quick conversation with
the officers, did you immediately approach
Ms. King?
A Immediately? I would say I
approached her after we spoke.
Q When you spoke to Officer Clifford
and Sutton, how far away was Ms. King?
A I don't recall the exact distance.
Q Was it more than five feet away?
A I'm going to say it depends because
we are moving around the facility and so is
she, so that varied.

Page 195
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

quick, very brief, very concise.
Q So the answer to my question, is it
fair to say, you don't recall if Officer Sutton
or Clifford told you the actions they took to
encourage Ms. King to submit to photographs and
fingerprints?
MR. BATTLE: Objection. He just
answered the question.
BY THE WITNESS:
A Both of them pretty much corroborated
each of their accounts. They both said the
same thing.
BY MR. MORRISSEY:
Q But do you recall Sutton or Clifford
telling you what steps each of them took to
encourage Ms. King to submit to photographs and
fingerprints?
MR. BATTLE: Objection, asked and
answered.
BY THE WITNESS:
A What specific steps?
BY MR. MORRISSEY:
Q Correct.
A No, I don't recall specific steps.

Page 197
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 observe Ms. King when you had
this conversation with Officer Sutton and Clifford?
A I observed her, yes.
Q And was she crying?
A She was -- To my recollection, she
would cry for a minute, and then she would get
hostile; and then she would get agitated. She
was displaying a variety of emotions.
Q When you approached Ms. King, did you
observe what Officer Sutton and Clifford did?
A They were standing nearby.
Q So did they approach Ms. King with
you after this brief conversation?
A No.
Q When you initially approached
Ms. King, how many feet were you from her body?
A When I initially approached her, it
varied, maybe three to five feet. I'm going to
say under three feet, to the best of my
recollection.
Q And when you initially approached
Ms. King, where was Officer Sutton?
A I cannot tell you exactly where
Officer Sutton was at this time. This was five

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 76 of 107 PageID #:1384

GLENN EVANS
February 29, 2016
51 (Pages 198 to 201)
Page 198
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 ago.
Q Where was Officer Clifford when you
initially approached Ms. King?
A I couldn't tell you where Officer
Clifford was at this point. It was five years
ago. In fact, I don't even remember what
Officer Clifford looks like.
Q Where was Officer Rodgers?
A To the best of my recollection,
Officer Rodgers may have been either at a work
station or in the general area.
Q When you approached Ms. King, did you
ask her why she was crying?
A I asked her why she was acting so
irrational.
Q Did she respond to your question?
A She responded to some of them. A lot
of her responses were incoherent, and she
screamed and yelled and was agitated. So if
you want me to say she gave a direct measure
calm response, no, she did not.
Q But she did respond to your question?
A She didn't respond to all of my
questions, no.

Page 200
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

operational, feasible, for us to go in there
process her as quickly as we can and get her
out of our control.
Do you remember being asked those
questions and giving those answers to the IPRA
investigator?
A Yes, I remember that line of
questioning.
Q When you said we made a determination
that because of her mental state and her
admission that she was under narcotics that you
wanted to get her out of the lockup as soon as
possible, who were you referring to?
A I was referring to Rita King.
Q But you said "we made a
determination," right? I can show you what you
said.
A Yeah, if I said that we made a
determination, and that's my actual IPRA
statement because a lot of them are rife with
errors and partial information, if I said it
and that's the IPRA statement that I gave, then
I stand by any statement I gave to IPRA.
Q Well, I'll show you. It's marked at

Page 199
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 Do you remember being asked these
questions and giving these answers to the IPRA
investigator, Question: And did she say why
she was crying? Answer: Yeah, because she was
mad at her boyfriend and she didn't want to go
to jail, and then she said she was high on
cocaine. She said she was high on cocaine.
She had a fight with her boyfriend, and all she
wanted to do was go home, and she was just
crying and caterwauling and carrying on.
Question: Okay, what did you do? Answer:
Eventually, we made a determination that
because of her mental state, because of her
admission that she was under narcotics, the
influence of narcotics, that because she had
some mental issues -- Question: She said that?
Answer: That's what she said. Question: Okay.
Answer: We did not want to keep her in the
lockup because there was a liability with it.
So we tried to get her up, process her, get her
out as quick as we can because we did not want
to put her in the lockup especially for minor
offenses like this and keep them locked up for
a prolonged period of time. It's just more

Page 201
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

393 and it's like 22 where you said "we made
the determination;" do you see that?
A Yes.
Q Who were you referring to when you
said "we"? Was that Officer Clifford and
Sutton?
A It was probably Officer Clifford,
Sutton and Rodgers.
Q And you also said that we did not
want to keep her in the lockup because there's
a liability with it?
A That's correct.
Q What did you mean by that?
A Liability means that she poses a
physical threat not only to the officers but
she poses a physical threat to other arrestees
and individuals -- arrestees and staff in the
lockup as well. She's liable to physically
attack them and anybody else in that District.
So it was a risk management move.
Q And you will agree that she was
arrested for a minor offense?
A I don't consider -- I'm going to
consider that since it was a simple assault and

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 77 of 107 PageID #:1385

GLENN EVANS
February 29, 2016
52 (Pages 202 to 205)
Page 202
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

I forget what the other charge was, but they
were two relatively minor offenses. Minor, I
mean, they are not felony offenses.
Q Did you make physical contact with
Ms. King in the lockup on April 10, 2011?
A Yes.
Q How long after you first walked into
the 6th District lockup did you make physical
contact with Ms. King? And I'm talking about
the time period.
A I don't recall the time period.
Q Do you recall whether it was a long
time or a short time?
A That's all relative.
Q Do you know whether more than ten
minutes passed between the time you walked into
the 6th District lockup and the time you made
physical contact with Ms. King?
MR. BATTLE: Objection, speculation.
You're asking him to guess. Go ahead and
answer if you can.
BY THE WITNESS:
A Sir, I don't recall the exact
timeframe I made physical contact with

Page 204
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 Where was Officer Clifford when you
made contact with Ms. King?
MS. HARRIS: Objection -A I don't remember exactly -MR. BATTLE: Hold on. Let her
object.
MS. HARRIS: I just want to object on
vague and form. Go ahead.
THE WITNESS: I'm sorry.
MR. BATTLE: Go ahead. You can
answer now.
BY THE WITNESS:
A I don't recall exactly where Officer
Clifford was.
BY MR. MORRISSEY:
Q Do you know where Officer Sutton was
when you made physical contact with Ms. King?
MS. HARRIS: Objection, vague, form,
go ahead.
MR. BATTLE: Go ahead.
BY THE WITNESS:
A The only thing I could say was they
were both in the same proximity. As to exactly
where they were standing or where they were

Page 203
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Ms. King.
BY MR. MORRISSEY:
Q After you made physical contact with
Ms. King, did she agree to be fingerprinted?
A I'm sorry?
Q After you made physical contact with
Ms. King, did she agree to be fingerprinted and
photographed?
A That's a question -- It depends on
what you mean by physical contact and the
ensuing timeframe.
Q Did you make physical contact more
than one time on April 10, 2011 in the
6th District lockup with Ms. King's body?
A I made numerous contacts, both
attempted and actual.
Q And after you made the numerous
contacts with Ms. King, did she get
fingerprinted and photographed?
A I stated I made numerous attempts of
contact with Ms. King, both actual and
attempted. And after that process commenced,
she subsequently agreed to be fingerprinted and
photographed.

Page 205
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

posted, I can't tell you.
BY MR. MORRISSEY:
Q Do you know where Officer Rodgers was
when you made physical contact with Ms. King?
A In the 6th District -MS. HARRIS: Objection, vague, form.
Go ahead.
THE WITNESS: I'm sorry.
MS. HARRIS: Okay, go on.
MR. BATTLE: I kind of anticipated
those coming. Go ahead.
BY THE WITNESS:
A In the 6th District lockup.
BY MR. MORRISSEY:
Q Did Officer Clifford assist you when
you made physical contact with Rita King?
A I don't recall what Officer Clifford
looked like. So I can't really answer that
question.
Q Do you recall whether Officer Sutton
assisted you when you made physical contact
with Ms. King?
A If you're saying assist in terms of a
police presence and -- a police presence, yes.

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 78 of 107 PageID #:1386

GLENN EVANS
February 29, 2016
53 (Pages 206 to 209)
Page 206
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

They provided a police presence and security,
so I'm going to say yes.
Q Did you observe Officer Sutton make
physical contact with Ms. King?
A Physical contact? I believe at one
point she walked her over, but I don't recall
anything outside of that.
Q Where did she walk Ms. King over to?
A I think she helped us walk Ms. King
over to the -- I think she helped us walk
Ms. King over to either the fingerprint or the
photographing, the booking photo machine.
Q Was that after you made physical
contact with Ms. King?
A I was making physical contact with
Ms. King during the time that -- during, to and
up to that time I walked her to the processing
area, and that contact was both actual and
attempted.
Q Did you make physical contact on
April 10, 2011 to Ms. King's head?
A Yes.
Q Did you also make physical contact to
her arms?

Page 208

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

screams, lucidity, crying and that would just
be an ongoing cycle.
Q During or after you used force to
Ms. King, did she ever tell you that you caused
her pain?
A Did she tell me directly that I
caused her pain?
Q Correct.
A No, she did not.
Q In addition to Officer Sutton,
Clifford and Rodgers, was there any other
member of the police department present in the
lockup when you approached Ms. King?
A I don't recall. I don't believe so.
Q When did you make the determination
that after Ms. King was photographed and
fingerprinted, she would be released from
custody?
A I don't know the exact timeframe in
which I made that determination.
Q Was it before or after you went to
the lockup?
A I'm sorry. Was it -Q Was it before or after you went to

Page 207
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

Yes.
MR. BATTLE: Let's take a break for
one second. Your question is done, right?
MR. MORRISSEY: Yeah.
(WHEREUPON, a short
break was had.)
BY MR. MORRISSEY:
Q When you used physical force to
Ms. King's head, was she crying?
A She was acting irrational and
engaging in -- She was crying prior to and
afterwards.
Q And is it fair to say during she was
also crying?
A You mean during?
Q During the use of force to her head?
A Entirely possible. I know she was
acting really irrational during the entire
process.
Q And when you used physical force to
her head, was she also screaming?
A What do you mean was she screaming?
She was screaming throughout the entire
experience. Her behavior was intermittent,

Page 209
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 lockup and approached Ms. King?
A I don't know. I'm going to say it
had to be sometime afterwards.
Q Why did you make a decision to
release Ms. King?
A It wasn't a felony offense. She was
not wanted on a warrant. Her fingerprints were
clear. There were no pending investigative
alerts or any other reason to detain her. She
was known to us. So if we had to bring her
back into custody, we would pretty much know
where to find her or she would find us; and
because there was probably some incipient or
ongoing public violence in that district, in
order to minimize the downtime of my personnel,
I made that determination.
Q Do you know what a TRR is?
A If that's the acronym for a Tactical
Response Report, yes.
Q Did you complete a TRR after you used
force on Ms. King?
A I don't know if you want to -- if
that constitutes a force per se but, no, I did
not do a TRR after my physical contact with

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 79 of 107 PageID #:1387

GLENN EVANS
February 29, 2016
54 (Pages 210 to 213)
Page 210
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
22
23
24

Ms. King.
Q Did you create any report that you
engaged Ms. King in the 6th District lockup on
April 10, 2011?
A Not that I can recall, no.
Q Do you know whether any officer
present in the lockup, Sutton, Clifford or
Rodgers -- Strike that.
Did you tell the IPRA investigator in
November of 2013 that Ms. King was not acting
like an active resisting arrestee when she was
in the 6th District lockup?
A Yes.
Q What is an active resisting arrestee?
A Active resisting is she engages in
physical -- She engages or demonstrates
physical behavior which constitutes or can be
construed as a threat.
Q Were you present when Ms. King was
ph
21
A I don't recall if I was. I don't
think so. It's possible but I don't recall
being there.
Q What do you next recall that day?

Page 212
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 When I reported to him, he was chief
of patrol.
Q Is chief of patrol responsible for
all of the districts?
MS. KUPE-ARION: Objection to the
form of the question and competence as
well.
BY THE WITNESS:
A The chief of patrol is the primary
law enforcement entity or primary law
enforcement authority for Chicago Police
Department patrol division.
BY MR. MORRISSEY:
Q When you were commander, do you know
how many officers were assigned to the patrol
division?
A No, I don't.
Q Is it the majority of the CPD
officers?
A Yes, that's safe to say.
MR. MORRISSEY: I have nothing
further.
MR. BATTLE: Anybody have anything?
MS. HARRIS: No.

Page 211
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 What do I next recall that day?
Q Correct.
A Leaving the lockup, performing the
rest of my duties as an acting watch commander
and reporting off duty.
Q After Ms. King was photographed and
fingerprinted, do you know whether she was
escorted by one of the officers to a room and
secured to a ring?
A I don't -- I will say that that would
be the procedure that we do. I don't know
which officer did it, if any officer did it. I
don't know which officer did it, but I'm going
to say some officer did escort and maintain a
presence with her.
Q Do you know Chief Gulliford?
A Yes.
Q Did you report to him?
A At that time?
Q Not at that time but after this time.
A A couple of years down the line, I
reported to him.
Q What was Chief Gulliford -- what was
his title when you reported to him?

Page 213
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

MS. KUPE-ARION: No.
MR. BATTLE: I don't think I have
anything to clarify. Just for the record,
Pat, you know he's not taking the Fifth on
anything, correct? You've asked all the
questions you have for him?
MR. MORRISSEY: I thought you told me
he wasn't going to answer questions about
his financial condition.
MR. BATTLE: Right, that's the only
portion. Everything else he's -- I mean,
he's not pleading the Fifth as to the
financial portion. He's just not answering
questions that you and I are disagreeing
on.
MR. MORRISSEY: You told me earlier
that he wouldn't be answering questions
about his assets and net worth, right?
MR. BATTLE: Yes. You understand
that that's -- you understand why -- what
I'm saying is that's not based on him
pleading the Fifth Amendment. I'm saying
that's based on the Court's previous order
that you and I have discussed earlier

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 80 of 107 PageID #:1388

GLENN EVANS
February 29, 2016
55 (Pages 214 to 217)
Page 214
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

today. We have a fundamental disagreement
about that. I think we can go back before
the Judge and figure out what that
disagreement is at the next status.
It has nothing to do with him
pleading the Fifth. It has more to do with
we think that the Judge said do that 90
days out from trial; and since we don't
have a trial date, that's why we're not
talking about that.
But all the questions you have
with respect to pleading the Fifth as to
the factual background, I want to make sure
you've exhausted everything because he's
not going to plead the Fifth at all at
trial.
MR. MORRISSEY: Do you want me to ask
more questions?
MR. BATTLE: I do not want you to ask
any more questions. I just want to make
sure you don't have any more questions.
MR. SCHUMANN: The point is we don't
want to see either later in a motion or
later on down the line to a particular

Page 216
1
2
3

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
RITA KING,
Plaintiff,

question he's taking the Fifth. We are
giving you an opportunity to ask all
questions however you want to do it, either
here or submit it in an interrogatory
later, but he is not taking the Fifth at
this point.
MR. BATTLE: And for the record, I
think you have exhausted every question you
can possibly ask this guy.
MR. MORRISSEY: No, I'm done.
MR. BATTLE: You're done?
MR. MORRISSEY: Yeah.
MR. BATTLE: Show signature is
reserved. All right, we're good.
MR. MORRISSEY: All right, thanks.
FURTHER DEPONENT SAITH NOT.....

)
)

5

vs.

6
7
8
9
10
11
12
13
14
15
16
17

) No. 13 C 1937
)
GLENN EVANS, et al.,
)
)
Defendants.
)
I, GLENN EVANS, being first duly
sworn, on oath, say that I am the deponent in
the aforesaid deposition, that I have read the
foregoing transcript of my deposition,
consisting of pages 1-216 inclusive, taken at
the aforesaid time and place and that the
foregoing is a true and correct transcript of
my testimony so given.
____________________________
GLENN EVANS

18
19
20
21
22

SUBSCRIBED AND SWORN TO
me before this ________ day
of ___________________, A.D. 2016.
_________________________
Notary Public

23
24

Page 215
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

)
)

4

Page 217
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 )
) ss:
COUNTY OF C O O K )
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

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 81 of 107 PageID #:1389

GLENN EVANS
February 29, 2016
56 (Page 218)
Page 218
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 WITNESS WHEREOF, I do hereunto set
my hand at Chicago, Illinois, this _______ day
of ____________________, 2016.

______________________________________
Peggy A. Anderson
Certified Shorthand Reporter
License No. 084-003813

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 82 of 107 PageID #:1390

GLENN EVANS
February 29, 2016
Page 219
A
aberration 153:5
abide 70:22 115:14
ability 19:23 20:17
55:4 124:10
129:23 154:24
181:8
able 185:15
absolute 113:24
126:20
absolutely 90:12
110:3 171:14
179:2
abuse 44:15 47:22
62:18 97:13 98:18
99:2 174:18 176:3
abused 47:4 108:3
abusing 108:5
113:14 136:17
abusive 113:6
126:15 166:8
academy 99:10
103:3,12 104:6,19
accepted 79:3
access 81:12,23
acclimated 80:19
account 85:16,18
106:17
accounts 195:11
accurate 131:13,15
accurately 12:1
accused 46:23
105:24 108:4,7
acronym 32:1
151:1 209:18
acronyms 31:24
act 70:17 149:21
181:17
acted 127:18
acting 69:20,20
127:17 149:3,15
149:17 150:5
172:20 177:3
193:4 198:14

207:10,18 210:10
211:4
action 24:17 85:9
85:11 217:24
actions 44:12
127:11 195:4
active 8:23 210:11
210:14,15
acts 170:24 171:8
actual 49:7 68:6
200:19 203:16,21
206:18
add 130:24 131:10
added 133:6
addition 76:18
86:13 152:6
208:10
additional 130:21
130:23 131:18
address 29:11
104:3 130:19
169:24
addressed 150:16
adequate 170:1
adhere 83:22
adjourned 217:19
administrative
6:11 8:14 9:19
155:18
admissible 62:17
admission 199:14
200:11
admitted 62:19
admonished
127:17
advantageous 87:3
adversary 131:12
adverse 102:4
advice 15:19 38:4
70:18 113:22,23
119:24 120:2
advise 32:19
118:10
advises 37:5
affairs 32:6 72:23

81:18,22 82:1,2
97:14
affect 84:14 102:4
affirmative 117:23
aforesaid 216:11
216:14
afternoon 147:8
age 44:11
agencies 73:24
agency 52:9
aggravated 13:11
13:17 127:4
agitated 176:17
197:7 198:19
ago 55:11 59:17
98:21 132:22
154:12 168:17
193:12 198:1,6
agree 43:17 50:24
54:18,19 155:11
156:22 159:2
181:23 201:21
203:4,7
agreed 43:13 118:1
161:8 203:23
ahead 14:13 39:24
42:3 62:20 74:14
77:8 78:16 82:6
109:17 114:18
115:24 123:9
124:20 131:7
132:9 135:19
137:2 138:11
139:21 148:21
150:14 152:24
174:8 192:15
202:20 204:8,10
204:19,20 205:7
205:11
al 1:6 216:6
alerts 209:9
alexander 88:22
alfonzo 18:24
allegation 46:21
47:2 48:20 58:3

63:9,12,14,20
16:18 17:13 22:22
64:2 91:1,7,10
23:6,8 24:21
106:7,12,14,24
31:19 37:2,9
107:3 116:6
39:14,22,22 41:12
119:14
41:18 47:23 53:3
allegations 13:15
70:18 72:14 82:6
13:16,17 29:24
83:3 98:7 102:5
33:16 34:2 35:16
105:19,20 109:17
36:10 40:8 47:12
113:17 115:6
48:8,13 50:8
117:23 118:4
51:12 61:6 64:7
120:16 121:19
64:16 66:7,13
122:20 123:3,6
68:20 69:4 70:13
127:24 129:11,21
75:21 84:1,24
130:15,18 131:7
87:24 91:3 93:3
131:20,23 132:9
96:21,23 97:1,3
132:17 133:12
97:15 99:2 109:16
135:19 137:9
111:7,9,12 119:1
138:9,12 139:20
119:3,8,12,18
142:8,9 146:20
121:16 122:9
148:8,21 153:1,20
123:19 124:13,23
158:4,9,10 160:5
125:3,5,8
161:3 163:5
alleged 47:3,7
166:12 169:7
60:22 63:8 75:18
174:9 184:10
90:10 108:12
185:15,15 186:10
119:15,18 157:13
186:16 187:5,8,19
171:8
192:16,17,18
allegedly 108:3,15
195:2 199:4,11,17
108:22,23 111:5
199:18 202:21
120:5
204:11 205:18
alleging 89:2
213:8
allow 171:12
answered 36:19
184:19 186:3,9
37:4,7,9 39:19
187:4
118:6 121:18
allowed 20:9
127:24 132:20
amendment 213:22
195:8,19
ample 132:23
answering 114:1,4
133:2
213:13,17
anderson 1:14
answers 39:12,20
217:3 218:8
128:14 129:2,14
animals 110:18
129:24 132:21
announcements
157:21 158:14
83:21
159:19 161:17,22
answer 7:16,21
184:6 185:1,10,19
14:12,14 16:11,17
188:17 199:2

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 83 of 107 PageID #:1391

GLENN EVANS
February 29, 2016
Page 220
200:5
anthony 3:13
108:17
anticipated 205:10
anybody 28:22
73:1,3 85:18,19
109:12 110:5
175:21 201:19
212:23
appeal 55:4
appear 59:12,22
appearances
113:11 125:17
appeared 2:7,15
3:8,17
appears 72:5
apply 104:12,19
appointed 77:13
appointment 155:4
appreciate 113:15
apprehensions
168:9,11,18,21
approach 196:4,14
197:12
approached 126:3
164:24 166:6
168:6,12 173:2,3
181:24 196:17
197:9,15,17,21
198:3,12 208:13
209:1
approaching
172:16
appropriate 112:18
approximately
27:9 59:16 86:2
94:8 147:6
april 56:11 57:5
136:24 140:13
141:6 142:16
143:7,20 144:24
146:2,9,15,21
147:13,20 148:5
149:10,13 150:3,8
150:19 151:11,16

152:7 156:16
157:22 165:5
166:1 170:5,8,21
172:4,8,16 173:9
174:5,14 175:5
177:7,7,17 178:1
178:20 179:7,16
179:23 180:3,9
181:1 182:24
183:13 189:24
191:4 202:5
203:13 206:21
210:4
area 25:9 90:9
121:20 143:12
162:14,14 165:16
171:15,18,19,21
184:9 185:23
190:2,14 198:11
206:18
areas 170:2
areawide 190:9
arent 100:7
arguing 71:16
argument 126:14
argumentative
114:24 183:12
arising 31:3
arms 206:24
arrest 174:23,24
181:8
arrested 127:2
157:22 201:22
arrestee 106:1
108:7 151:17
152:9 166:17
183:1 189:22
190:14,20,22
191:13 210:11,14
arrestees 104:7,8
146:3,6,10,16
150:11 151:11
167:9,17 201:16
201:17
arrived 191:10,20

192:24 193:16
arrogant 126:11
article 11:11
articles 10:9
articulate 7:18
23:4
arts 100:23
asked 6:23 19:17
22:7 29:6 36:18
37:23 39:19
112:21 156:19
157:20 158:13
159:3,4,18 161:16
161:19,21 177:18
178:2,13 179:15
180:7,13 184:5,24
185:9,18 188:16
191:22 192:2,13
195:18 198:14
199:1 200:4 213:5
asking 17:21 32:20
32:21,24 35:12
39:6 40:12,14
42:2 48:18 53:10
56:17 65:15,18
74:19 77:5 81:19
84:7 97:7 112:9
112:10,19 113:6
114:7 115:16
116:20 117:8
125:6,7 141:13
156:17 158:20
159:15,17 163:1,2
183:20 202:20
ass 126:21
assailant 105:14
assault 127:4
201:24
assert 70:16,20
assessment 50:5
85:1 92:20,21
assessments 158:12
assets 213:18
assigned 6:4,7,10
8:12 12:4,12,13

25:11 32:18 33:7
69:13 76:2,7 81:3
86:3 88:4,12 94:4
94:7 98:11 120:10
140:15 145:7
146:23 147:17
179:20 212:15
assignment 6:2
26:21,23 69:7
140:19,21,23
assignments 12:3
96:3 141:2,3
assist 156:18,20
205:15,23
assisted 205:21
associate 172:11
assume 156:15
assumes 139:17
assuming 84:18
attaching 128:24
attachment 42:21
42:22
attack 201:19
attempted 203:16
203:22 206:19
attempts 203:20
attend 99:16
100:12
attention 119:20
153:6
attitude 126:5
attorney 6:12,23,24
7:7 8:10 15:5,9,14
15:22 37:5,15,22
43:14 54:24 55:3
64:6,9 111:13
112:3,10,15 114:7
114:10 115:17,19
118:5,6 132:24
133:8 154:16,21
154:22,24 155:5
217:21,22
attorneyclient
112:8
attorneys 15:18

TOOMEY REPORTING
312-853-0648

36:13 74:1 113:21
116:21 140:1
august 6:8 8:17,18
10:4 12:16,17
26:1 27:9 30:11
47:4 48:14,19
69:7 72:6,10
authority 212:11
avenue 1:16 2:5
average 25:1
award 85:21
aware 11:14 33:20
34:1 35:15,19,22
36:2,8,16 39:9
40:2 73:9,22 74:2
75:20 77:3 80:9
84:23 94:13,17,21
96:9 98:17 106:12
131:23 132:15
150:19 152:7
156:12 189:16
B
b 4:6 84:10 141:12
148:19
back 40:5 46:12
47:9 54:11 72:7
96:18 113:24
182:10 184:8
185:23 187:9
188:14 209:11
214:2
background
214:13
bad 48:4 49:5,12
54:9
badgering 115:1
badly 185:21
balance 85:21
banned 180:21
barely 45:3 67:20
barrel 17:6
base 49:24 117:7
based 12:1 16:24
24:13 35:16 36:10

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 84 of 107 PageID #:1392

GLENN EVANS
February 29, 2016
Page 221
45:19 52:3,4 64:4
64:16 68:19 78:23
83:13 85:1 87:3
98:8 117:21
119:13,14 129:10
131:14 133:13
141:17 144:15
151:5,18 155:1
165:18 176:17
188:20 213:21,23
baseline 149:23
basically 44:16
basing 150:13
basis 97:4,5 109:15
132:8 188:3
bates 58:22
battery 13:11,18
127:3
battle 3:13,16 6:14
6:17 7:3,9 8:4
11:20 14:7,13,20
15:7,24 16:14,18
17:2 19:3 21:15
28:5 32:23 34:17
36:18 37:7,12,15
37:23 38:5,9,20
38:24 39:10,21,24
41:13,18,22 42:3
43:16,24 44:4,7
44:22 47:14 51:13
52:17 55:6 56:16
56:19 58:7,16,19
58:23 59:3,6
60:17 61:2,15
62:13 65:6,11
66:20 67:4,9,15
68:1,5,10 71:4,6
71:14 73:14 74:8
74:14 75:9 76:3
77:5,8 78:14 82:5
84:3 85:3 87:17
88:6 98:4,7,20
99:11 108:9,19
109:1,8,14 111:14
111:15,21 112:1,4

112:6,12,16,21
113:2,5 114:17
115:5,10 116:13
116:15,19 117:2,6
117:13 120:16
121:2 122:12,16
122:19,24 123:3,9
123:14,23 124:3,5
124:15,19 125:20
129:12 131:2
132:7,18 133:1
134:6,8,17 135:18
135:23 136:10
137:17 138:3,11
139:2,18,21
140:21 141:12
142:10 147:22
148:2,8,20 150:13
152:12,24 155:22
157:2 158:15,19
158:22 159:13,21
160:2,6,9,13,16
160:24 161:3
163:5,21,24
169:15 172:24
174:7 176:21
183:16,19,22
186:3,7,13,21
187:2,19 192:18
195:7,18 202:19
204:5,10,20
205:10 207:2
212:23 213:2,10
213:19 214:19
215:7,11,13
bearing 56:23
beast 11:11 74:22
beat 147:17
behalf 2:7,15 3:8
3:17 84:10 98:1
behavior 83:20
168:22 169:2
192:21 194:18
207:24 210:17
believe 26:1 40:16

55:2,9 58:21
70:23 71:2,8,13
71:14 72:7 86:9
89:20 93:21 99:13
102:1,18 106:21
114:24 117:4,6
127:13,16 128:3
128:15 132:14
133:7 137:6
139:23 143:12
144:12 147:2,17
150:17 153:20
171:24 176:15
180:10 186:18
191:8 206:5
208:14
belligerent 126:12
176:5
bench 182:8
best 70:6,9 86:5
89:19,23 98:8
126:2,17 164:22
170:10 178:21
182:7 183:9
188:22 192:1
197:19 198:9
better 58:24 93:7
127:19 153:19
157:6 161:10,12
beyond 136:14
big 53:2 110:9
119:4
bipolar 174:1
176:9,11,12,14
177:8 180:16
bit 129:16 150:22
182:9
blanked 58:18
blocked 58:11
blurred 42:14,16
42:17,18,20,21,24
board 55:5 92:23
body 47:5 197:16
203:14
bold 45:7

booking 206:12
borderline 136:17
152:19
bottom 46:22 57:9
box 47:2
boyer 3:12
boyfriend 199:5,8
brain 110:2
break 7:20,23 8:2
41:19 122:21
123:2,21 140:3,5
207:2,6
breaking 176:5
brendan 32:15
brief 29:8 194:16
195:1 197:13
bright 67:14
bring 117:11
209:10
broad 22:21 33:13
53:2 69:6 104:2
150:21 152:15
173:21
broadness 130:19
brought 20:11 63:9
63:11 119:20
125:8 136:4
137:12 164:11
167:18 189:22
brunt 136:22
building 126:6,9
165:14,15,17
bullshit 63:21
bunch 46:2 119:7
187:3
burdensome
130:20
burying 61:5
buttocks 121:20
bypass 181:21
C
c 1:5 2:1 3:1 5:13
216:5 217:2
calculated 15:2

TOOMEY REPORTING
312-853-0648

44:14 61:3 62:16
74:9 125:22
call 46:11 50:23
102:2 113:19,24
114:18 116:22
117:2,13 120:18
142:21 143:16
called 1:10 5:10
126:14 144:13
calm 184:23 198:21
camera 143:8,10
143:11,14,19,23
144:4,23
candidate 82:14,24
83:10,17 84:2,23
cant 10:15,17 22:1
31:19 35:9 45:4
53:2 71:2 75:12
98:13 100:16
102:5 105:19
146:20 168:2,16
170:14,18 182:13
187:12 205:1,18
capacity 76:9 120:4
120:21 150:4
153:5
car 145:15 147:18
card 175:4,14,19
175:22
cards 175:15
care 177:13 183:5
career 11:20 20:21
50:20 102:4
carla 3:5,7
carry 19:23 20:3,5
20:9
carrying 199:10
carter 88:18
case 10:11,14,20
14:8,22 46:2,3,5
56:23 61:5 63:21
67:10 78:16 84:6
84:14 107:15
109:17 111:11,15
111:17,19,20,22

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 85 of 107 PageID #:1393

GLENN EVANS
February 29, 2016
Page 222
112:13 114:14
117:9 118:12,22
121:4,10,21,24
122:2,4,9 124:24
127:14,16,19
136:22 186:22
189:4
casebycase 109:15
cases 115:17
116:12,21 122:5
187:1
caterwauling
199:10
catholic 100:1
caused 16:23 17:6
36:9,12,15 45:20
65:4 208:4,7
cell 126:19
certain 79:13 83:19
86:24 153:23
certified 1:14 217:3
218:9
certify 217:5
chain 78:24 79:2
challenges 54:5
chance 129:17
130:2
change 51:5 129:11
129:15,19,22
155:21
changed 51:2 78:22
channel 21:13,22
22:5,10,19 23:2
26:16,18 40:3
characteristics
79:14
characterize
138:15
characterized
152:13 185:3
charge 13:8,21
14:2 181:10 202:1
charged 13:9,10,11
13:14 14:4 18:14
49:15 127:2,3

charges 13:20,24
20:10,12,14,15,16
34:6 136:4 137:8
137:12
charging 181:11,21
check 9:20 145:24
145:24
chicago 1:16 2:5,10
2:13 3:3,6,9,15
5:21 9:1,9,13,21
21:4,6 22:8 23:24
32:5 57:19 61:8
66:6 73:9 74:4
75:19 80:14 99:20
100:18,19 102:10
114:12 151:23
212:11 218:2
chicagos 11:12
chief 19:17 87:7,10
87:12 88:2,20
211:16,23 212:1,3
212:9
chiefs 90:21
child 46:6 49:15
children 127:17
cigarettes 172:8
circumstance
89:16 179:3
circumstances
13:20 33:19,23
40:22 90:5 137:10
153:22 158:1
167:11,12,23
190:4
citizen 11:19 87:15
89:2,10 90:6 91:7
94:22 97:9 98:17
citizens 21:9 29:16
30:1 87:24 103:24
104:1 110:13
city 2:10 3:3,9 5:21
9:1,12,16,21 10:2
15:16 22:8 23:24
58:21 61:8 67:23
80:14 98:1 100:18

114:12 115:4
116:6 122:1
139:15 151:23
153:21 154:1
cityofchicago 2:14
3:7
citywide 187:22
civil 1:11 2:10 3:3
claim 47:19 121:8
claimed 106:15
claiming 106:17
claims 14:10,23
47:19 56:23 57:1
61:7 136:15,15
clarification
173:13
clarify 67:10 186:7
186:15 213:3
class 103:15,17
105:10
classes 103:18,19
classroom 152:6
clear 62:24 81:13
81:16 128:18
209:8
clerk 63:16 64:2
client 75:13 112:17
115:6,22 116:14
116:20 118:10
136:17 160:5
187:18
clifford 2:16 149:7
149:9 157:23
162:18 163:12,18
164:6,13,24 166:7
166:10,11,22
168:4,23 172:15
172:22 182:1,20
182:22 189:18
191:12,19,24
192:4 194:8 195:4
195:14 196:18
197:2,10 198:2,5
198:7 201:5,7
204:1,14 205:15

205:17 208:11
210:7
cliffords 189:6
clinton 194:12
coast 101:19,23
cocaine 199:7,7
cocounsel 38:11,12
38:19 39:2
code 139:10,23
cognitive 153:11
cold 171:13,17
college 100:10,12
100:14,16,18
169:18
colleges 100:13,17
com 2:6 3:16
combative 105:13
combativeness
167:14
combination 152:5
162:15
come 68:20 80:13
87:1 119:23
156:17,19 171:13
comes 23:19 184:8
184:15 185:22
coming 43:5
112:11 129:8
163:23 188:24
189:7,14 205:11
command 21:13,22
22:5,9,19 23:1
26:16,17 29:6
40:3 78:24 79:3
80:3 81:17 82:4
82:12 84:1,20
144:20 154:21
commander 5:23
5:24 6:6,10 8:12
9:4 12:12 18:18
19:18 21:7,12,20
22:3,11,14,16
23:1,9,20 24:2,24
25:7,22,24 26:11
26:14 27:11,13,18

TOOMEY REPORTING
312-853-0648

27:22 30:21 32:8
32:9,10 33:10
69:18,19,20,21,23
70:1,12 77:15
80:1,4,9,20 81:12
81:15,19 84:19
86:14,22 87:7,9
87:11,23 88:13,17
88:18 91:16,19,21
92:4 137:19
149:14,15,17,22
150:5 165:6
172:20 184:15,16
211:4 212:14
commanders 32:12
32:13 88:14 90:16
91:4,11,13 165:8
165:20 166:2
commanding 27:16
69:15,17,21
commenced 203:22
commencement
217:6
comment 53:16
119:24 120:2
comments 174:17
commingling 67:13
85:10,11
common 88:17,18
communicate 7:7
communicating 7:9
7:12
communication
71:10
compensated 9:3
compensation 9:6
9:12,16
competence 84:8
97:24 141:10
148:18 212:6
complained 29:15
complaint 21:9
46:17 89:2,10
90:7 95:6 97:4,5
97:10 116:3

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 86 of 107 PageID #:1394

GLENN EVANS
February 29, 2016
Page 223
117:22 121:14
128:2,4 132:13
complaints 11:19
21:11 85:8,12,12
85:19 87:16 90:8
94:22 98:17
130:22
complete 23:15
131:14,16 134:1
209:20
completed 24:21
24:22
completely 14:22
44:13
compliance 105:20
comprehending
24:5
computer 142:24
concerning 217:9
concerns 65:14
105:12 176:2,4
concise 194:17
195:1
concur 92:1,2,5,13
92:22 93:5 153:3
condense 23:7
condition 213:9
conditions 29:12
conduct 22:5,9
33:14 38:17 49:21
52:15 82:23
conducted 33:11
33:20 36:2 51:11
53:21
conducting 50:14
53:1 74:3
conducts 32:16
confidential 67:24
configuration
131:15
conflict 104:17
conflicts 180:2
confrontation
176:17,18
confrontational

126:16 176:6
177:14,20 178:4,6
178:9 179:17
confused 67:12,14
congregate 171:16
connected 127:5
connection 116:11
consider 181:15
201:23,24
consideration 81:4
85:23
consisting 216:13
constitute 85:9
constitutes 209:23
210:17 217:13
construed 210:18
contact 119:16
138:14 158:2
166:10 175:14,15
175:19,21 202:4,9
202:18,24 203:3,6
203:10,12,21
204:2,17 205:4,16
205:21 206:4,5,14
206:15,18,20,23
209:24
contacted 69:2,5
74:24 176:16
contacts 203:15,18
content 161:8
196:11
contents 43:2 57:7
context 31:23 60:1
164:9
continuation 5:4
continue 38:1 39:5
39:6
continued 37:24
contrived 17:12
137:8
control 103:9,11,14
103:16,20,24
104:5,9,12,16
105:20 200:3
controlling 158:7

162:19 163:15
166:20,23
conversation 12:23
17:14,17 18:9,15
20:22 28:14,23
29:13,23 30:2,4
30:10,14,18,20,24
31:5,15 65:16
70:11 87:22 91:3
91:9 112:23 136:5
138:21 139:5,9
164:10,11 166:9
166:15 191:12,14
191:17,18 192:7
194:24 196:6,13
197:2,13
conversations
17:19,24 29:18
50:12 53:5 87:6
192:9,11 196:11
convoluted 21:24
23:3
cooperate 163:20
164:7 183:15
184:9,12,13,22
185:24 193:17
cooperating 164:12
164:15
cooperativeness
191:3
cop 11:13
copy 58:19,20,23
58:24 59:4 62:24
67:15,17 128:18
corner 181:5
correct 9:23 11:21
11:24 12:14,20
17:18 18:20 19:8
20:13 21:18 22:13
22:15 25:14,18
26:6 27:1,14
30:17 31:6,17
32:11 40:19 44:3
48:16 49:4 50:5
50:22 51:20 54:3

54:20 59:19 60:14
63:4,23 64:3,21
65:10,24 66:3,10
68:23 77:6,7,19
78:2 79:10 80:3
81:24 82:16 83:11
92:17 93:20,24
94:16 95:19 96:5
96:12,24 99:18
101:7 102:9 103:7
107:19 108:5
111:5 119:2
121:14,15 122:3,6
122:7,10 125:12
126:20 141:14
142:1,6 151:14
156:10 157:9
162:10,23 165:2
167:22 173:6
175:1 176:3
179:10 190:17
191:15 195:23
196:11 201:12
208:8 211:2 213:5
216:15
corroborated
195:10
cottage 25:19,20,20
couldnt 17:12
24:21 25:3 28:18
80:6 134:1 182:13
198:4
counsel 15:20
16:15 34:18 37:8
37:12 38:4 39:11
41:22 44:8 58:19
62:13 70:18,22
71:7,21 112:16
117:9 119:8,21,23
120:1,3 122:12,13
122:24 129:18
136:11 138:4
147:23 153:3
158:23 217:21,22
county 217:2

TOOMEY REPORTING
312-853-0648

couple 96:13,14
132:4 154:11
177:10,11 182:4
211:21
court 1:1 5:6 59:22
63:8,16 64:2
111:2 113:10
120:1,3 125:11,15
125:17 155:18
156:13 216:1
courts 1:12 213:23
cousin 117:8
coverage 170:1
cpd 84:10 97:19,22
146:6 150:20
151:10,16 152:8
175:18 176:20
212:18
cr 11:3,5,14 21:14
21:23 22:10,20
23:11,16,21 24:3
24:6,10,14 25:2
26:19 32:17,22
40:20 41:9,10
42:9,11 54:11
55:1 56:1 62:10
63:6 65:4,19 66:6
66:18 68:19 81:16
84:1,24 91:22
95:17 109:5
110:19 127:21
crazy 177:3,5
create 210:2
created 175:14
crime 29:11 169:13
criminal 13:8
136:4 137:8,12
181:17
criteria 77:2,3
crs 82:3 136:13
cry 197:6
crying 168:24
169:3 183:8,10
197:4 198:13
199:4,10 207:9,11

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 87 of 107 PageID #:1395

GLENN EVANS
February 29, 2016
Page 224
207:14 208:1
current 131:14
currently 5:18 8:24
9:6 64:19,20
73:10 74:3
cursed 126:11
cursory 52:7 129:9
129:10 154:11
156:1 179:3
custody 172:17
208:18 209:11
cut 187:12,13
cycle 208:2

decline 178:17
180:19
deemed 23:22
deenihan 32:15
defendant 3:9,17
31:2,9,15 130:12
130:14 131:1
defendants 1:7
2:16 15:13 84:14
216:7
defense 117:23
defer 93:8
deficit 153:6,11
define 177:5
D
definition 152:17
d 2:16 4:1 5:13
152:20 173:11
216:21
degree 100:20,22
daily 11:11 74:22
delegated 84:19
damage 144:22
delilah 70:19 71:11
damaged 110:2
75:19,21
dana 88:22
deliliah 68:21 69:4
dangerous 112:7
70:13,15
database 145:6
deliver 78:8
date 59:14 214:9
demeanor 126:5
dates 62:10 171:10 demonstrates
day 63:5,7 64:17
210:16
120:9,12,22
demonstration
147:18 169:5,10
105:7
176:8 210:24
dennis 157:23
211:1 216:20
denying 161:23
218:2
dep 115:8
days 35:20 36:17
department 6:1 9:9
45:4,7,17,21
17:8,16,23 18:6
54:13 59:19
20:1,7 21:1,4,6
154:12 214:8
22:9 32:2,5 34:9
december 86:7
40:13,18,23 49:21
93:22 94:1,9
50:7,13 52:11,14
128:16 129:4
55:14,17 56:3
132:21
57:19 60:5,12,23
decided 83:5 92:13
61:14,24 66:3,7
93:4 181:11
69:3,6,8 73:10,11
decipher 43:1,20
73:20 74:2,5 75:1
45:2 46:7
75:20 76:2 78:5,8
decision 24:13
79:15 80:11 82:19
79:15 82:11 209:4
82:22 83:7,24

90:3 94:2 98:3
102:10,16 110:6
118:19 135:13
139:11,24 150:10
151:23 152:9,10
153:15 168:1
177:1 180:8 188:5
188:6,11,11
208:12 212:12
departments 73:23
79:19 81:5,7,13
departmentwide
185:6 187:22
depend 82:18
depended 82:19
105:11
depending 144:21
173:11
depends 24:11
31:23 33:15 35:2
80:7 82:17 105:12
105:17,21 121:8
123:18 145:2
146:18 166:4
167:11,23 168:2
169:7 190:4 191:2
196:22 203:9
deploy 87:2
deployments 86:24
deponent 39:20
71:12,18 138:1
139:14 215:17
216:10
deposed 118:13
deposition 1:9 5:4
10:8 11:6,9 15:4
16:9 38:11 115:16
116:7 118:8,21,24
136:18,20 159:23
187:6,13 188:24
189:3,7,11,13
216:11,12 217:10
217:16,18
depositions 1:13
depressive 174:1

176:9,11,13
depth 154:12,14
deputy 18:22,23
19:2,12,13,15
87:7,9,12 88:2,20
90:21
describe 22:18
104:11,18,21
105:5,8 106:11
designated 142:4,5
142:7 148:24
149:2
desk 23:19 142:4,5
142:7,15 179:20
desks 142:17,19,21
despite 53:12
details 193:13
detain 209:9
determination
35:13 51:9 156:4
177:2 181:20,21
199:12 200:9,16
200:19 201:2
208:15,20 209:16
determine 46:7
81:16 133:3
determined 89:23
detroit 68:21
deviate 79:22 188:6
didactic 152:6
didnt 6:22 7:1 18:7
18:8 35:21 40:16
43:17 75:9 90:23
119:23 121:22
128:22 139:7
154:23 155:5
174:11 178:24
189:12 194:23
198:23 199:5
difference 97:8
148:14 150:23
151:4
differently 153:17
153:23
difficult 67:23

TOOMEY REPORTING
312-853-0648

dimensions 83:20
direct 4:3 87:5
181:21 198:20
directed 181:19
direction 87:4
217:13
directive 20:6,8
150:24 151:1,6,8
151:10
directives 23:23
24:1 83:1,2
150:16 151:8
152:3,4 188:6
directly 12:15 87:1
156:9 208:6
217:23
dirtiest 11:12
disagreeing 213:14
disagreement
214:1,4
disarmed 110:12
disbelieve 71:3
discern 180:12
discharge 35:4
101:20,22 102:3
disciplinary 34:6
85:9,11
discipline 23:12
34:13,22 35:2
disciplined 61:12
61:21 95:16
106:23
discount 85:18,19
discoverable 44:15
61:4 74:10 84:5
114:23 118:11
125:22
discovery 44:16
47:22 62:17,18
113:14 133:9
136:18
discretion 79:20
181:14
discretionary
45:14

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 88 of 107 PageID #:1396

GLENN EVANS
February 29, 2016
Page 225
discuss 90:15,18,20
discussed 29:1
196:10 213:24
discussing 6:16
91:14
discussion 40:11
71:22
dislike 131:10
dismissed 127:14
disorders 153:6
dispersed 151:2
displaying 197:8
disqualify 84:2
85:2
disrespectful 34:20
distance 196:20
district 1:1,1,12
12:7,9,12 17:7,22
18:4,4,5 21:8,11
21:12,21 22:4,12
22:14,17 23:10
25:1,7,11,13,15
25:16,23 26:1,11
26:13,15,22,24
27:3,5 29:11,12
52:24 53:6,17,19
58:5 69:14,18
76:1,4,7 86:4 87:9
87:11,15 88:5,13
88:24 89:14,18
90:17,22 91:2,8
93:11,22 96:6,7
107:21,23 140:16
140:17 141:8,21
142:15,18 143:8
143:20 144:1,6,9
144:16 145:8,13
145:19,22 146:3,5
146:9,16,17
149:14,20 150:6
157:24 158:3
162:9,10 165:5,10
165:12,16,21
167:7,18 169:4,12
171:12,16,20,22

172:18 177:19
178:3 179:15,22
180:4,9,15,16
183:6,14 185:5,6
187:21 189:22
190:1,6,8,13,16
191:20 201:19
202:8,17 203:14
205:5,13 209:14
210:3,12 216:1,1
districts 212:4
division 1:2 2:11
3:4 32:6 212:12
212:16 216:2
divorce 72:2
dna 14:18 16:22
17:5
docket 113:11
document 43:6
48:23 56:9 57:3,6
69:1 72:17 128:17
128:21,23 129:7
documentation
31:17,19 188:21
documented 53:8
documents 10:9,10
10:16,18 43:3
47:16 81:2 155:14
164:20
doesnt 23:23 50:4
152:16 160:22
187:8,11
dog 110:14
doing 16:1 77:21
91:21 106:16
115:3 120:9 188:7
doj 75:15
dont 7:6 9:7 10:3,6
11:13,16 12:15
17:10 22:22 26:2
26:4 27:6,19 28:3
28:17,24 29:17,19
29:20 30:6,6,7,8
30:18,22,22 31:10
31:12 33:13,23

34:12,15,18 36:12
36:14 37:10,13
38:9 40:6 41:2,10
42:20 44:5 45:13
46:12,15 50:17
51:3 55:3,9,9,24
56:4,7 57:16 58:2
59:2,24 60:6,6,7
61:23 62:3 64:14
65:20 66:14,16,19
66:22 68:3,8,24
70:23 71:8 72:3,4
74:21 75:13 78:19
79:5,11 80:6 81:9
82:9 83:1 85:9,18
85:19 86:6 87:19
88:8,10,21 89:6
90:12,14,19 92:10
94:10,18 95:3
96:19 97:2 99:5,7
101:17 102:4
104:2 106:4
108:18 109:10
110:17,21 112:16
112:17,18 113:15
114:22 116:17,20
116:24 117:4
118:14,23 120:13
121:11 126:19
128:1,5 130:5,6
131:11 132:3
135:1,9,21,23
136:2 138:16
139:4,23 140:12
142:7,8,9,20,21
143:1,2,5,16
144:2,7 146:19
148:11 149:8
154:3,22 156:19
156:21 161:12,18
161:24 162:11,16
163:13,17 164:9
164:16 165:23
166:9,14 167:8
170:15 171:10

172:3,3,6,9,13,14
175:8,11 178:24
179:1,13 182:3,21
184:22 186:18,21
188:14 191:8
192:9 193:7,12
194:6,11 195:3,24
196:2,20 198:6
201:23 202:11,23
204:4,13 205:17
206:6 208:14,14
208:19 209:2,22
210:20,20,22
211:10,11,13
212:17 213:2
214:8,21,22
doty 88:16,16
doubt 30:6 64:8
downplaying
157:12
downtime 209:15
drawnoutmonda...
194:23
drive 3:14
drunk 158:5 162:3
166:18
due 20:10 48:9,9
162:24 194:17
dues 155:3
duly 5:2,11 39:1
216:9 217:8
duration 28:19
duress 72:16
duties 145:20
147:13 149:18
211:4
duty 8:23 109:13
184:14,19 211:5
dyslexia 174:3
E
e 2:1,1 3:1,1 4:1,6
5:13,13
ear 16:1,2
earlier 173:21

TOOMEY REPORTING
312-853-0648

213:16,24
early 56:6 147:8
earth 84:6
eastern 1:2 216:2
echoed 158:11
echoing 194:1,3
eddie 88:17
edicts 79:19 81:5,8
81:8,9,9 187:24
effect 151:10
effort 170:1
efforts 163:19
164:7 194:13
either 66:16 96:18
98:16,17 130:14
130:24 162:3,17
163:11,18 164:5
164:13 166:18
168:4,23 172:21
182:1 194:12
198:10 206:11
214:23 215:3
ejected 177:16
178:14,15
elaborate 45:24
eligible 19:20
emanuel 134:3,9,14
135:12 136:6
137:11 138:22
139:10
emotional 153:9
173:23
emotions 197:8
employed 5:18
102:7
employee 217:20
217:22
en 169:16
encounter 170:9
172:5
encountered 50:20
151:17 170:6,13
170:15
encounters 170:20
177:11

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 89 of 107 PageID #:1397

GLENN EVANS
February 29, 2016
Page 226
encourage 36:14
163:19 164:7
193:17 194:9,14
195:5,16
enforcement 73:24
181:19 212:10,11
engage 180:24
engaged 120:5
176:20 210:3
engages 210:15,16
engaging 168:9,11
168:19 169:2
170:24 171:8
207:11
english 81:10
ensconced 169:13
169:15
ensuing 203:11
ensure 25:8 170:1
entailed 169:3
enter 99:9
entered 193:8
196:3
entire 28:19 34:8
43:2 60:1 149:11
155:23 157:18
164:9 179:11,13
207:18,23
entirely 87:19 88:9
164:17 173:16
175:7 207:17
entirety 42:10
entitled 64:9,11
entity 212:10
equipment 144:8
144:17,20
equipped 35:14
eric 88:18 112:15
114:13
erratic 194:18
erroneous 31:18
41:1 46:9 69:12
85:13
errors 46:2,11
48:10 69:11,12

200:21
escalante 19:16,18
20:23
escape 127:10
escort 211:14
escorted 211:8
especially 74:22
199:22
essentially 154:22
estimation 93:1
154:2
estranged 65:4,19
65:20
et 1:6 216:6
ethic 86:23
eugene 88:22
evans 1:6,9 2:16
3:17 4:2,9,10,11
4:12,13 5:5,9,17
7:5,15 15:5,22
16:11 17:5 19:1
19:17 34:16 37:19
38:22 39:9 40:2
41:4,8 42:8 43:14
47:8,20 56:13,24
61:7 62:5 67:1
68:14,18,21 69:4
70:13,15,19 71:12
75:19,21 84:9
97:24 118:16
122:10 128:8
131:4 186:2,20
216:6,9,18
evening 147:8
event 179:5
events 138:17
157:11
eventually 184:12
199:12
everybody 35:3
evidence 17:10,12
17:12 61:4 62:17
74:10 84:5 90:2
114:23 117:21
125:23 139:17

evolved 50:22 51:3
evolving 50:23
exact 165:24
171:10 196:20
202:23 208:19
exactly 10:13,15,17
26:7 32:23 58:7
92:10 152:21
162:11 178:24
197:23 204:4,13
204:23
exaggerated
106:16
exaggerations
74:19
exam 76:11,14,16
76:22
examination 1:10
4:3 77:2,12
186:20 217:7
examined 5:11
exception 97:15
excessive 29:16
30:1 35:17 87:16
87:24 89:2,9 91:1
91:7 94:23 95:1,6
97:10,13 98:18
exchange 193:14
194:6,17,20
excuse 43:16 114:2
115:23,23 122:15
exhausted 214:14
215:8
exhibit 4:9,10,11
4:12,13 41:3,4,9
43:8 44:19 46:13
46:16 54:12 55:20
56:12,13,20 57:4
60:8,9 62:4,5,9
66:23 67:1,18
68:14 72:5 75:17
128:8,13 130:8
exhibited 194:18
exists 57:20
exonerated 96:18

expanse 136:15
expectations 29:9
29:10
expeditious 188:20
194:20
experience 49:20
50:3 165:18
207:24
expired 24:18,20
explain 116:1
117:19 168:18
170:19 176:7
193:16 194:13
extent 18:15 84:13
extraneous 23:3
exwife 65:3 70:19
eye 108:24
F
face 104:7,8,13,20
facilities 146:13,14
facility 145:24
165:23 178:10
190:9,15 194:22
196:23
fact 46:3 110:11
139:6 166:17
198:6
factors 105:23
191:2
facts 13:19,21 90:3
139:17
factual 13:23 14:2
93:3 96:21,23
97:1,3 166:21
214:13
failed 59:11 60:22
failing 59:22
fair 38:24 39:14,16
39:22 138:11
179:10 195:3
207:13
fairly 90:23 132:5
false 13:22,23 14:1
119:7

TOOMEY REPORTING
312-853-0648

falsely 13:10,12,13
20:11 108:4
falsified 17:11 90:1
106:17 137:8
familiar 73:19
78:20 102:22,24
150:4 151:15
far 60:8 101:21
136:11 165:20
196:19
fashion 23:7 87:3
fast 188:3
fastpaced 105:10
father 16:1
favor 20:13
fcrl 56:10
fearful 168:5,8
feasible 200:1
february 1:16
fed 81:21
federal 1:11 2:10
3:3 111:2
feed 177:12
feeding 183:4
feet 196:21 197:16
197:18,19
felony 202:3 209:6
female 146:3,6,10
146:16 189:22
190:14,20,22
femaledesignated
190:10
females 190:5
field 148:24 149:3
175:21
fifth 213:4,12,22
214:6,12,15 215:1
215:5
fight 110:10 199:8
figure 214:3
figures 127:6,6,7,8
127:9
file 21:9,23 22:10
22:20 23:11 24:3
24:6,10,14 35:16

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 90 of 107 PageID #:1398

GLENN EVANS
February 29, 2016
Page 227
41:9,10 42:9,11
filed 113:12 117:22
118:18
files 11:3,5,14
21:14 25:2 26:19
32:17,22 40:20
81:16 84:24
finalized 72:2
financial 213:9,13
find 113:10 114:19
209:12,12
finding 23:16,22
59:10 92:14
findings 58:9 92:2
92:5,23 93:2,5
fine 16:4 44:17
113:8 160:8,11,12
160:23 161:2
fingerprint 184:20
189:24 206:11
fingerprinted
184:17 203:4,7,19
203:23 208:17
211:7
fingerprinting
193:19
fingerprints 194:10
194:15 195:6,17
209:7
finish 133:1 158:22
160:10 186:4,9
187:19
finished 60:17
firearm 20:9
first 5:2,10 18:21
18:23 19:2,11,13
19:15 41:19 42:6
55:13,19 57:4,8
57:13 60:4 62:11
72:14 100:14,16
123:7 128:14
134:23 160:10
165:13,19 166:6
170:12,14,18
179:12 182:11,18

183:7 193:9 196:5
202:7 216:9
five 92:9 144:2,6
168:17 193:12
196:21 197:18,24
198:5
fiveyear 193:23
flagging 181:6
flawed 92:24 93:2
floor 3:14 165:13
165:19
fluid 194:17
flunked 81:9
focus 179:1
follow 38:3 60:23
81:4,6
followed 79:18
follows 5:12
foot 182:23
footage 165:24
force 29:16 30:1
35:17 87:16,24
89:3,9 91:1,7
94:23 95:1,6
97:10,13 98:18
207:8,16,20 208:3
209:21,23
foregoing 216:12
216:15 217:10
forget 202:1
form 9:11 135:15
137:15 148:7
192:14 204:8,18
205:6 212:6
formal 22:23
134:24 137:11
138:17 148:11,15
149:1
formally 121:11
134:20 135:2
former 71:12
formulate 149:24
151:14 154:4
forth 74:11 136:14
forward 43:24

116:7 129:16
fought 109:20,23
foul 63:8
found 14:18 16:23
17:6,11 20:15,15
127:15
foundation 74:10
130:20 135:18
137:18,21,22,23
138:5 139:17,19
147:15 148:7,16
160:22
four 162:15
fourth 46:15 58:2
frame 169:21,22
franko 155:13
free 171:19 180:4
frequent 171:4
frequently 80:5
149:21 171:3
fresh 156:23
front 42:13,14 49:8
fuck 47:9
fucking 63:22
fudge 133:22
full 101:10
function 8:14
145:21 150:4
functions 86:24
138:18
fundamental 214:1
further 47:7
129:17 212:22
215:17
G
g 2:3,4
garb 181:6
gauge 12:1
gender 53:12,13
general 41:23
50:12 51:14,16
145:4 146:13
150:9,20 151:6,7
151:8 164:10

174:18 186:1
187:24 188:1,2
189:21 190:3
191:18 193:2
198:11
generalities 166:15
168:20
generality 166:16
generally 23:18
50:9,11 82:8
166:4 184:13
190:23
generated 144:10
175:18
geographic 25:9
getting 48:17 54:11
67:12 112:6
114:17 136:21
137:2 139:13
178:15,16 180:2
183:4
gifted 153:7
gilbert 113:19
117:10
girlfriend 109:22
110:8
give 18:7 25:4
46:12 64:18 68:6
72:23 73:1 75:2
92:19 98:2 105:18
105:19 108:9
115:14 126:2,9
147:5 149:23
153:21 155:4
170:18 185:19
186:15
given 72:15,22,23
101:22 105:11
115:13 136:11
153:14 161:24
216:16 217:14
giving 70:8 72:19
118:23 154:5
157:21 158:13
161:16 183:5

TOOMEY REPORTING
312-853-0648

184:5 185:1,10
199:2 200:5 215:2
glad 100:7
glenn 1:6,9 2:16
3:17 4:2 5:4,9,17
37:19 43:22 56:24
98:7 135:19 216:6
216:9,18
gmail 2:6
go 14:13 18:14 35:3
36:19 37:3 39:5
39:24 42:3 46:15
54:23 62:20 72:7
74:14 77:8,21
78:4,16 82:6
91:24 99:17
100:10 109:17
112:21,24 114:18
115:24 123:9,22
124:20 131:7
132:8 134:23
135:18 137:2
138:6,11 139:21
148:21 150:14,23
151:1 152:24
174:8 182:2 187:9
188:14 192:15
199:5,9 200:1
202:20 204:8,10
204:19,20 205:7,9
205:11 214:2
goes 30:7 82:1
going 7:16 8:5
15:19,21 24:15
26:8,8 27:8 29:19
33:2,6 36:19,22
37:3,16,17,18
38:1,3,6,13 39:5,5
42:4,5 43:12 44:2
46:4 47:14 54:22
56:11 57:24 63:22
68:5 70:1,7,16,17
70:20,21 80:8
83:15 86:5 88:21
91:12 92:8 93:15

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 91 of 107 PageID #:1399

GLENN EVANS
February 29, 2016
Page 228
99:7 101:16 102:2
106:5 113:17
114:15 116:14
119:10 125:23
126:2 127:9,10
129:16 131:2,6
136:10,14 138:4
139:6,16,18
143:22 144:2
147:14 148:6
152:12 157:10
158:15 160:4,6
161:10,11 163:24
166:21 169:12
170:7 176:10
178:21 179:12
182:17 184:4
188:19,20 192:2
192:13 193:1
196:22 197:18
201:23 206:2
209:2 211:13
213:8 214:15
good 51:23 54:8
58:20 83:9 97:2
123:23,24 215:14
goodness 107:4
gotten 47:21
graduate 101:4,6
gray 2:18
groin 106:21 108:8
108:16 121:20
ground 127:1
grounds 131:3
grove 25:19,20,21
guard 101:19,23
guess 10:19 57:9
88:21 133:15
162:24 163:1
167:3 202:20
guesstimate 26:3
guest 171:3
guideline 188:3,12
guilty 20:15 127:15
gulliford 211:16,23

gun 14:4,19 16:23
16:23 17:6 47:6,8
109:16,21,22
110:11
guy 215:9

148:16 183:18
192:14,17 204:3,7
204:18 205:6,9
212:24
harrison 12:5
havent 43:7 47:21
H
115:13 132:4
h 4:6
136:23
habits 172:9
head 47:6 103:24
half 137:1
104:1,7,8,16
hall 165:23
105:3 206:21
hallway 162:13
207:9,16,21
halsted 108:1
headquarters 6:5,7
hand 109:21
6:10 8:13,19 12:4
156:14 157:14
12:18 13:1 17:8
188:21 218:2
17:16,23 18:6,14
handcuffed 167:7,9
18:18
167:13 190:24
health 152:13
handcuffing 167:4
174:17,21 176:1,7
167:5
178:16 181:18,22
handling 60:24
heard 136:23
167:4,5
hearings 155:19
hands 54:21 159:12 held 96:8 127:1
hang 177:23
help 71:2 169:19
hanging 179:4
helped 206:9,10
happen 92:7
helps 142:11
happened 29:19
heres 187:10
63:5,7
hereto 217:23
happening 125:18 hereunto 218:1
harass 85:14
hes 30:8 37:17 42:3
harassing 62:18
71:4 77:6 115:2
113:7 114:24
119:21 120:13,14
139:14
120:14 141:12
hard 43:1 58:12
149:12 160:19
138:7 180:12
183:20 186:5,14
188:2
213:4,11,12,13
harris 2:12,14
214:14 215:1
15:12 73:15 74:12 hid 90:2
75:11 84:12 85:6 high 99:16,17,19
98:6 108:17
99:21 101:4,6
114:15,21 134:7
153:8 158:5 162:3
134:18 135:7,17
166:18 173:22,23
136:9 137:16
193:3 199:6,7
139:1,16 141:11
highest 169:13
147:14,23 148:6
history 85:21

hold 17:2,2 20:19
26:4 27:6 34:17
38:5 43:18 68:5
86:6 122:16
184:18 204:5
holding 104:15
holton 70:2,3,4,4
70:12
home 199:9
homeless 177:15
homicide 61:1
honest 27:19
honorable 102:1,3
hopefully 39:1
hospital 180:19
hostile 197:7
hours 137:1 147:3
house 146:16
housing 94:5,7,13
94:21 95:1,7,22
95:23 96:7
hr 83:6
hubert 70:2,3
human 80:18
hypothetical 84:4
183:17

identity 90:2
ignored 119:19
ill 7:23 16:2 31:21
41:16 56:19 57:24
73:14 84:12 94:10
98:6 115:14 119:5
120:1,3 126:10
134:6 141:11
148:20 152:14
163:8 164:21
200:24
illinois 1:1,15,16
2:5,13 3:6,15
100:18 101:1
102:18 216:1
217:1,4 218:2
illness 150:12
151:12,17 152:11
153:4,19,24
166:19 173:10,12
illnesses 153:16
im 7:16,18 8:10,20
8:23 10:23 11:12
15:18,21 16:6,12
17:21 21:2 24:15
26:8,8 27:7 29:19
32:20,21 33:2,6
I
36:22 37:3,18,21
iad 31:21,22 32:8,9
38:1,3,5,6,16,21
32:10,12,16,18,22
39:5 41:8 42:5
33:8,11,20 34:1,5
43:12,23 44:8
34:14,22 35:5,14
46:4 47:14 48:18
57:5 72:24 89:12
53:9,10,13 56:11
89:16 90:6,15,20
57:24 58:24 62:9
94:14,15,19 96:9
63:22 65:15,18
96:11,16,17 97:9
67:14 68:5 70:1,7
97:18,21 98:11
70:8,16,17,20,21
icon 127:14
71:5 80:18 81:3
id 24:8
81:19 83:15 86:5
idea 84:6
86:8 88:21 90:23
identification 41:6
91:5,12 92:8 93:9
56:15 62:7 67:3
93:15,20 94:24
68:16 128:10
95:14 97:7,12,20
175:3
99:7 100:8 101:16
identify 81:20
102:2,13 106:5

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 92 of 107 PageID #:1400

GLENN EVANS
February 29, 2016
Page 229
107:4,7,9 110:24
112:9,10,17,19,20
113:16,23,24
114:4,7,15,17,21
118:2,13 119:9,24
120:1,24 123:24
124:11,19 125:6,7
126:2 128:12
130:1 131:2,21
132:5 139:6,16,18
143:22 144:14
146:7 147:14
148:6 152:12
157:10,12,14
158:15,17 159:1
159:17 160:2,6
161:11,23 163:1,1
166:21 169:12
170:7 176:9
177:23 178:14,21
179:11 182:17
184:4 185:16
188:19,20 196:22
197:18 201:23
202:9 203:5 204:9
205:8 206:2
208:23 209:2
211:13 213:21,22
215:10
immediate 97:16
97:17
immediately
182:24 183:2
191:19 196:4,14
196:16
impair 124:9
impairing 178:9
impeach 159:4
impeaching 158:16
158:17,20 160:17
impeachment
159:5
implementation
98:12
implementing

188:10
improper 71:18
158:16 159:22
160:21 187:15,16
improperly 106:18
106:20 160:17
improvement 51:7
51:9 52:9
inactive 101:24
inception 10:20
incident 60:21
62:22 63:2 108:12
108:21 110:4
111:4 127:23
157:18 161:12
164:21 188:9
incidents 156:24
incipient 209:13
inclement 171:5
include 166:16
167:21
included 105:3
131:19,23
including 104:14
inclusive 216:13
incoherent 198:18
incompetence
45:22,23 53:7
incomplete 84:4
183:16
incorporated
133:22
incorrect 41:1 46:8
92:24 93:2
independent 48:22
49:3
indicate 92:1
indicated 37:16
160:20 180:17
indicating 41:17
indirectly 217:24
individual 2:16
63:18 71:10 78:9
79:4,16 90:1
105:16 106:15,19

107:6 108:16
109:20,24 110:1,7
110:10 142:3
individuals 82:21
107:13 108:17
143:16,18 153:5,7
153:8,23,24
177:15 178:12
201:17
inferred 173:20
influence 199:15
informal 148:12,15
informally 52:20
52:21 134:21
135:4
information 6:18
6:20 7:2 15:2
52:5 62:19 68:22
70:9 71:13,15
74:17,20 78:23
81:20,21,24
118:11 127:4
130:21 131:12
144:11 162:4,7
179:19 180:12
200:21
infrequent 80:7
infrequently 80:22
80:23
inherent 54:16
167:15
initial 158:2
initially 168:6,12
173:2,3 184:22
197:15,17,21
198:3
initiate 65:4
initiated 65:19 66:6
68:19 75:19 97:18
97:21
injured 109:20
injuries 157:13
innocuous 157:11
157:12
innuendos 74:19

input 87:3
inside 165:10
inspector 122:1
instances 110:20
instruct 75:12
112:16 113:17
160:5
instruction 105:11
integrity 91:15
intelligence 153:10
173:23,24
intelligent 7:18
53:12,14
interact 150:11
152:8 153:15
interaction 153:9
interested 217:23
interface 153:8
intermittent
207:24
intermittently
10:19
internal 32:6 72:23
81:18,22 82:1,2
97:13
internally 97:19,22
interrogatories
128:15
interrogatory
132:21 215:4
interrupt 124:19
intervening 38:22
interview 28:4,20
29:2 34:3 82:13
82:15,23 83:4,9
83:14 86:14,16
interviewed 27:21
28:1
intrusive 167:24
invalid 85:13
inventorying 60:24
investigate 73:23
89:17
investigated 34:2
89:12

TOOMEY REPORTING
312-853-0648

investigates 97:12
investigating 46:1
46:3 50:8 52:12
54:2
investigation 33:12
33:15,21 35:23
36:2,3,5,10 40:8
46:17 48:4 49:4
49:10,13 54:17
55:1 73:10 74:4
75:15 89:20,21,22
90:16,21 91:13,15
91:22,24 92:3,13
92:16,21,24 93:1
97:9 109:6 127:22
investigations
24:23 49:22 50:14
51:11,22 52:2,4,6
52:16 53:1,18,21
54:6,7 89:24
94:14,15,18,19
95:17 96:10,11,16
96:17 97:18,21
110:19
investigative 209:8
investigator 46:5
48:5,10 49:10,14
49:17 72:11 75:1
155:12 199:3
200:6 210:9
invoke 71:18
involved 11:15
38:10,13,13
109:16 122:3
131:4,5 176:16
involvement 154:6
involving 60:24
ipra 23:11,21,23
24:7 35:16,22
36:2,9,16 40:4,5,7
43:9 50:22 51:1,3
51:6,10 52:11,15
52:24 53:7,20
54:1,4 92:5,12,15
93:5 97:11 127:22

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 93 of 107 PageID #:1401

GLENN EVANS
February 29, 2016
Page 230
138:22 139:5
154:6 156:8,23
157:17 161:7,17
173:15,17 184:7
185:11,12,20
189:18,19 199:2
200:5,19,22,23
210:9
ipras 45:22
irrational 193:4
194:18 198:15
207:10,18
irrelevant 14:22
44:11 56:22 61:2
65:13 78:15 84:4
isnt 27:7 191:2
issue 23:23,24
116:18 133:10
145:6 150:20
164:19
issues 48:10 92:1
117:11 152:14
158:6 162:3
169:23 173:15,18
174:6,15,17,21
176:2,8 178:7
180:17 181:18
199:16
items 129:18
ive 17:19,24 87:6
114:19 136:11
169:18 186:24
187:2 192:10

98:4,6 134:6,7,18
135:7,17 136:9
137:16 139:1
141:11 148:20
183:18
joining 102:9,15
joins 115:4
joshua 110:22
111:1 114:11
118:16,18
journalist 120:11
120:14
judge 113:18
114:18 116:16,23
117:3,10 127:16
214:3,7
judges 114:19
july 21:6 93:15,16
93:17 94:8,8 96:1
96:2 98:16,16
99:13 101:16
103:4,13 104:6
122:10 125:19
june 27:8 58:14
59:14,22 68:19
justice 73:11,20
74:3 75:1
justified 188:7

K
k 2:17 217:2
kedzie 12:5
keep 8:4 67:11
177:12,13 199:18
J
199:23 201:10
jackson 180:19
keeper 141:7,20
jail 199:6
keeps 67:12
january 42:15,15
kelly 87:12,23
45:16
kenneth 3:13,16
jennifer 108:24
kevin 140:7,9
jesus 99:11 132:7
kicked 47:6 108:16
john 88:16
kicking 108:7
johnson 88:17
kill 47:10 68:21
join 73:14,15 74:8
killed 110:1
74:12 75:11 84:12 kind 17:10 128:3

150:21 176:16
knocked 48:11
205:10
know 9:7 11:16
king 1:3 5:7 10:22
16:15 17:10 22:22
11:1 35:17 36:3,9
27:16,19 28:17
36:12,15 37:18
30:4,6,7,8,13
40:9 47:20 56:24
31:21 32:7,10,16
61:6 106:10 108:3
32:21 33:11,14
108:5 111:22
34:5,11,13,22
117:8 125:24
35:21 36:4,6,12
136:16 154:7
36:14 40:7 41:11
156:18,20 157:1
42:20 49:14 51:3
157:22 158:2
53:11,14 57:16,18
162:2,19 163:15
57:20,23 60:3
163:20 164:7,14
61:24 63:11,13,14
166:8,24 167:6
63:17 64:12 65:3
168:11,19,24
65:18 66:17 79:2
170:6,9,20 171:7
79:5,11 80:6 81:9
172:5,7,17,22
89:12 91:16 92:10
173:10 174:5,22
94:10 96:17 97:2
174:24 175:19,22
99:5,7 101:21
175:24 177:7,18
104:2 107:15
178:2 179:1,4,5
110:19 111:10
179:21 180:24
120:13 121:4,11
182:6 183:1,7
123:1 126:19
191:11,21 193:9
127:21 128:1
193:17 194:9,14
130:5 132:3,8
194:19 195:5,16
140:7,8,12 142:7
196:4,15,19 197:1
142:8,9,21 144:4
197:9,12,16,22
146:19 148:9,11
198:3,12 200:14
149:6,8 152:19
202:5,9,18 203:1
165:23 172:1,3,7
203:4,7,18,21
172:9,17 173:9
204:2,17 205:4,16
175:13,15 176:19
205:22 206:4,8,9
178:24 179:1,11
206:11,14,16
179:12,13 182:3
208:4,13,16 209:1
184:17 186:22
209:5,21 210:1,3
191:4 193:5,9
210:10,19 211:6
202:15 204:16
216:3
205:3 207:17
kings 106:7 172:1
208:19 209:2,11
192:21 203:14
209:17,22 210:6
206:21 207:9
211:7,11,13,16
klinus 32:14
212:14 213:4
knew 179:8,9,13
knowledge 17:9
180:3
21:8 32:21 35:5

TOOMEY REPORTING
312-853-0648

51:6 52:5,7 76:21
77:6,11,11 89:1
89:17 98:9 99:3
119:13,14 125:8
141:14,17,18
143:7,13,21 144:9
145:1 150:8,14
151:5,5,19,22
known 150:11
152:10 209:10
kupearion 3:5,7
15:15 73:12 74:6
75:4,12 84:8 85:4
97:23 111:24
115:4 116:8 134:4
134:15 135:5,14
136:7 137:14
138:23 139:12
141:9 148:18
151:18 212:5
213:1
L
l 2:17 3:13
labor 102:20
lack 74:10 90:13
130:20
language 63:9
lapitan 2:17
lasalle 2:12 3:5
law 2:2,9 3:2,11
73:23 168:1 176:5
188:9 212:10,10
lawsuit 118:18
130:23 133:17
lawsuits 31:2
130:11 131:3,19
131:22 132:16
133:4,13
lawyer 155:8
lay 137:17,23 138:5
laying 180:1
lead 15:2 44:14
61:3 62:16 74:9
84:5 115:20

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 94 of 107 PageID #:1402

GLENN EVANS
February 29, 2016
Page 231
117:21 125:22
leads 114:23 116:2
118:11
learn 103:2,12
learned 103:9
104:9,12,15
105:16
leave 8:15,16,20,22
177:19 178:3
179:15 180:8,13
leaving 211:3
leeway 136:12
left 108:24
legal 67:5,13
legalities 168:3
letter 188:9
level 98:13 105:17
105:22,22 154:21
167:14 173:22,23
levels 153:8
liability 199:19
201:11,14
liable 201:18
liar 119:4,21 120:7
120:14
liberal 100:23
license 218:10
lie 26:8 119:17,20
131:11
lied 90:1 106:16
119:9,11
lies 16:24 74:18
121:1
lieutenant 20:20
27:2,5 69:19 76:1
76:12,20,24,24
77:17 78:2,10
86:11,20 88:12,24
89:13,18 90:22
91:2,8 107:18
120:8,22 137:20
145:18,22 149:20
155:2
limit 24:12,16,20
limited 52:4,5,7

line 185:16,17
200:7 211:21
214:24
list 130:11 134:1
listed 132:16
listen 116:4 186:21
187:10
listing 130:13
lists 172:2
litigation 2:11 3:4
115:20,21
little 129:16 150:22
lloyd 2:18
lobby 171:3,19
180:1,5 183:3,3
located 143:10,24
location 108:2
lock 146:3,6 156:17
locked 146:10,11
146:12 199:23
lockup 106:1,13,15
141:5,7,18,20
142:16,17,18
143:8,20 145:19
145:20,23 156:20
158:4 162:13,20
163:16,20 164:8
164:11,15 165:16
165:21,22 166:3
166:17,24 167:7
167:10,19 168:12
168:24 172:23
182:2,5,12,15,16
182:19,20,23
183:6,15 184:8
185:23 190:16
191:10,20 192:11
192:24 193:8,15
196:3 199:19,22
200:12 201:10,18
202:5,8,17 203:14
205:13 208:13,22
209:1 210:3,7,12
211:3
lockups 190:11

lodge 97:4 128:3
lodged 128:2
log 144:13
long 6:6 8:16 20:24
21:3,5 24:1,9
25:22 30:20
164:14 166:1
188:6 194:9,23
196:6 202:7,12
longterm 171:24
look 41:11,14,16
49:5 58:2 59:2,3
72:4 79:6,9,12,14
79:24 83:16,23
113:10 130:6
185:12 188:8
looked 136:20
205:18
looking 43:8 55:19
72:9
looks 42:23 57:4
67:15 182:22
198:7
lot 11:23 17:11
31:18 40:24 46:7
46:8,8,10 51:23
52:1,11 54:2,5,6
69:11 85:12 89:24
127:18 136:11,12
181:15 184:21
188:10 198:17
200:20
lots 161:24
lott 110:23 111:2
114:11 118:16,18
119:2,4,10,15,18
120:6,7,11 124:12
lotts 119:12
lousy 52:15,24
53:21
lucidity 124:2
208:1
lump 23:5
lying 119:22
120:15

M
m 1:17 5:13
maced 47:7
machine 206:12
mad 199:5
madeleine 3:5
maintain 211:14
majority 212:18
making 9:3 15:10
39:7 44:9 53:16
78:4 79:7,14
98:12 114:21
119:24 120:2
178:5 206:15
males 181:7
man 78:14,16
124:15,17
manage 25:8 29:11
29:12 141:18,19
managed 149:18
management
201:20
manic 174:1
176:12,13,14
177:9 180:16
manner 24:23
manpower 170:1
manual 102:20
march 12:16 26:2
55:21 63:3 108:13
marital 65:13
70:17,21
mark 41:2 56:12
62:3 66:22 68:11
128:5
marked 4:8 41:5,9
54:11 56:10,14
57:3 62:6,9 67:2
128:9,13 200:24
marking 68:9,11
married 64:19,20
64:23 65:1,23
masked 174:19
matter 114:11

TOOMEY REPORTING
312-853-0648

131:5 132:19
144:12
matters 87:6
130:13 217:9
mayer 134:14
136:6 138:22
139:10
mayor 134:3,9
135:4,12 137:7,11
138:15 139:5,15
mccarthy 17:15
28:12,15,22 29:14
29:24 31:1,5,16
mean 8:21 33:14
45:11 48:17 50:4
50:9,10 51:2,3
52:7 53:23 61:17
65:22 66:20 68:10
75:8 76:24 77:23
79:22 80:23,24
94:10 97:3,3
103:5 104:21
118:6 123:18
130:5 134:20
137:1 145:5,12
156:9 157:11
162:8 173:5,18
177:22 190:3
201:13 202:3
203:10 207:15,22
213:11
means 8:23 45:13
79:11 81:1 201:14
measure 103:24
198:20
measures 103:10
103:11,16,20
104:5,10,12
meat 136:22
media 74:18,21,22
medications 124:9
meet 137:7
meeting 135:11
137:11 138:17
meetings 134:24

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 95 of 107 PageID #:1403

GLENN EVANS
February 29, 2016
Page 232
138:16
member 40:18
49:20 52:13 56:2
60:4,11 61:13
66:2 83:24 97:22
110:5 135:13
153:15 175:18
208:12
members 50:6,13
52:10 118:19
150:10 151:16
180:8,15
memo 57:5
memory 11:18 27:7
29:23 31:14 40:21
53:5 156:22
164:19
memos 81:1
mental 150:11
151:11,17 152:10
152:13 153:4,16
153:19,23 158:6
162:3 166:18
173:10,12,14,18
174:6,15,17,21
176:1,7 178:16
181:18,22 199:13
199:16 200:10
mentally 152:14
mention 136:23
message 194:4
met 134:3,9,13
135:1,3 138:14,17
138:18
methods 103:14
michael 87:13
middle 46:23
military 101:9
mind 11:10 38:9,12
39:2 43:18
mine 38:2 58:17
minimize 104:17
209:15
minimum 170:11
181:6

minor 199:22
morrissey 2:3,4,4
201:22 202:2,2
4:4 5:3,6,14 6:21
minute 64:18 166:5
7:4,14 8:8 11:21
193:13 196:9
12:2 14:11,17
197:6
15:3,8,21 16:4,8
minutes 182:4
16:10,21 17:4
202:16
19:7 21:17 28:6,9
minutia 157:15
33:4 34:21 37:1
mischaracterizes
37:10,13,20,21
174:8
38:6,16,21 39:4,8
misconduct 11:19
39:18,23 40:1
13:12,18 33:16
41:2,7,15 42:1,7
34:2 36:11 40:9
43:13 44:3,5,17
50:8 51:12 66:8
44:18 45:6 48:6
75:18,21 84:24
51:15,19 52:22
90:10 106:1,12,14
55:12 56:9,18
119:16,19 120:5
57:2 58:9,13,21
124:23 125:5,9
59:2,5,9 60:19,20
misnomer 188:1
61:11,18 62:3,8
misrepresented
63:1 65:9,15,17
90:3
66:22 67:7,21
misspelled 46:10
68:3,8,13,17
misspoke 70:8
70:10,23 71:8,17
167:5
72:1 73:18 74:23
misstatements
75:16 76:5,8 77:7
74:18
77:14 79:1 81:11
mistake 46:1
82:10 84:17 86:1
mitigate 170:2
87:21 88:11 97:6
modes 105:10
98:14 99:1,15
modify 129:19,23
100:9 107:12
130:2,15,18
108:11,20 109:4
molestation 46:6
109:11 111:18,23
49:15
112:9,14,19 113:1
moment 6:13 41:11
113:4,20 114:4,9
moments 124:1
115:5,9,22,24
monell 14:9,23
116:5,13,17,24
47:19 57:1 61:7
117:4,10,17,24
116:5,9 136:15
118:13,15 120:20
monetary 9:11
121:3 122:14
monitor 146:1
123:5,13,20 124:6
month 25:1 101:17
125:1 128:5,11
months 12:11,13
129:20 131:17
94:6 132:22
132:12,24 133:7
morning 147:7
133:11 134:12,22
191:6
135:10 136:3

108:23 124:18
133:15 149:6
172:1 173:5,5
179:8,9,11,12,13
named 31:2,4,9,15
130:11 133:13
names 82:21
132:15 171:20
narcotics 89:21
90:7,8 193:3
199:14,15 200:11
nasty 126:5
nato 120:10,22
nature 62:18 79:18
126:24 144:21
145:2,3,5 151:7
168:3
nearby 194:6
197:11
necessarily 50:4
necessary 117:5
need 7:23 41:20
116:15 181:19
183:22
needlessly 115:7,12
115:15
needs 146:18 169:8
169:10 178:10
negative 85:17
neither 131:15
net 213:18
never 32:18 33:7
43:18 98:11,12
102:3 111:9,12
119:3 121:11
124:22,24 125:4
159:3
news 10:9 11:8
N
night 16:3
n 2:1 3:1 4:1 5:13
nine 20:16
5:13
nomination 82:21
name 5:6,15 46:10 noncomplaint
46:22 57:7,10
105:17
78:22 99:21 100:5 noncompliance
107:13,14 108:17
105:18,23
137:4 138:1,8,20
139:8 140:3,6,22
141:15 142:14
147:19 148:1,3,13
149:5 150:18
151:20 152:1,23
153:13 156:5
157:8 158:17,21
159:3,7,9,17,24
160:4,8,11,14,23
161:2,14 163:10
163:23 164:4
170:4 173:1
174:13 176:22
184:3 185:8 186:5
186:11,18,24
187:17 188:13
192:22 195:13,22
203:2 204:15
205:2,14 207:4,7
212:13,21 213:7
213:16 214:17
215:10,12,15
motion 214:23
move 7:3 116:7
118:7,8,14 201:20
moving 43:24
196:23
multifaceted 24:4
multiple 17:19,24
23:5 56:6 88:14
90:8 100:13,17
103:17,19 104:9
104:11,22 105:9
105:10 141:1
142:17 178:2
192:10 193:21

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 96 of 107 PageID #:1404

GLENN EVANS
February 29, 2016
Page 233
14:20 15:15 36:18
38:17 39:1,18
44:10,22 47:15
56:20 61:2 62:14
65:6 71:6 73:12
74:6 75:4 78:14
82:5 84:3,13 85:3
85:5,6 87:17 88:6
97:23 98:5,20
108:19 109:1,8,14
111:24 114:19,21
125:20 132:8,18
133:2 134:4,15
135:5,14,15 136:7
137:14,22 138:10
138:23 139:12
141:9 148:16
155:22 158:23
159:1 160:1,7
174:7 183:16
186:3 192:14
195:7,18 202:19
204:3,18 205:6
212:5
objections 15:5,10
15:23 39:7 43:15
65:12 148:21
obligated 16:17
obligation 133:8
obliterated 42:24
obscure 131:12
obscured 57:7,8,10
57:11,12,13 67:18
O
67:20
o 5:13 217:2,2
observation 50:4
oath 26:5 124:12
observe 172:11
216:10
180:7,24 197:1,10
object 16:2 39:3
206:3
43:12 114:15
observed 168:21
131:2 139:16,18
170:23 171:7
147:14 148:6
174:5 191:11
152:12 158:15
193:9 197:3
160:16 204:6,7
obstructing 194:22
objecting 44:2,10
occasion 175:24
objection 6:14 14:7
177:18 180:11,14

noncompliant
105:13,16
normal 186:19
north 2:12 3:5
northern 1:1 216:1
nose 105:1,3,6
notary 216:22
note 184:15
noted 35:4 39:1
notes 42:6 83:13
164:23 165:1
noticed 112:20
notification 62:11
80:12 83:6
notifications 83:21
notified 66:5,9,12
66:15 121:12
notify 144:19
november 99:13
103:4,13 104:6
155:12 210:10
number 12:9 29:14
40:22 46:18,18
58:3 67:18 68:11
75:17 82:3 114:20
119:15,17 130:6,8
130:8 131:20,24
133:12 181:14,15
181:17
numerous 10:9,11
87:6 118:19
203:15,17,20

occasions 170:17
170:23 174:4
occupied 181:7
191:5,7
occur 28:4 110:16
150:1 157:13
occurred 30:11,15
55:21 108:13,22
111:4,5 122:10
178:19
oclock 147:6,7
october 62:12
offense 201:22
209:6
offenses 199:23
202:2,3
offhand 9:7 11:16
60:13 62:2 132:3
office 11:12 18:21
19:11,15 27:17
28:8,16,18 30:8
38:8 78:7,11
80:16,17 144:20
162:12 165:4,6,9
165:21 166:3
officer 22:24 23:2
24:3 27:16 31:3
46:23 47:7 69:15
69:17,22 81:17
82:4,12 93:4,12
93:14 96:1,4,9
98:15 108:6,16
110:9 137:20
140:7,8,14,23
145:8,16 146:22
147:9,13,20 148:1
148:2,4,4,12,12
148:15 149:1,2,4
149:6,9 156:17
158:5,9,10 162:2
162:17,17 163:2
163:11,11,18
164:5,13,23 166:7
166:10,13,22
168:4,5,23 175:7

175:10,12,14,18
176:19 182:1,12
182:16,19,19
188:23 189:6
191:12,19,24
192:4 193:15
194:3,5,8,12
195:3 196:18
197:2,10,22,24
198:2,4,7,8,10
201:5,7 204:1,13
204:16 205:3,15
205:17,20 206:3
208:10 210:6
211:12,12,13,14
officers 21:16,23
22:10,20 32:17
50:19 51:12,13,15
52:12 53:22 54:3
85:15 157:23
158:8 162:6
167:15 172:12,14
172:15,21 179:20
189:17,23 192:5,8
192:12 193:21
196:5,14 201:15
211:8 212:15,19
offices 2:2,9 3:2,11
official 13:11,18
officially 128:2
oh 99:11 107:4
okay 7:8,17,22 15:6
39:24 41:21 42:3
42:5 45:9 46:14
63:24 71:24 77:8
84:22 106:8 112:5
121:2 124:3 126:7
152:23 163:8
184:7 186:21
187:2 199:11,17
205:9
old 44:12 47:17,18
56:22
once 35:12 57:24
58:11 62:24 65:2

TOOMEY REPORTING
312-853-0648

67:17 92:7 95:9
95:10 100:17
106:3,4,16 110:10
150:1 178:19
193:23
oneil 49:19
ones 51:23,24 54:9
54:9 68:2 132:2
133:15,23 193:22
ongoing 91:13,18
91:22 208:2
209:14
onthejob 152:4
open 35:15,23 36:3
36:4,9
opened 110:20
operation 9:18
operational 9:18
51:4 54:4 144:5,8
144:18,24 146:18
169:7,10 178:10
185:4 187:23
188:4 200:1
operationally 51:2
operations 141:19
146:1 194:22
opinion 50:1,2,5
51:10,18,21 52:18
52:21 53:20,24
opportunities 81:2
opportunity 39:3
42:9 130:7 133:2
156:6 186:9,16
215:2
opposed 181:17
188:9
ops 45:22 49:4,17
49:21 50:7,13,22
51:7 52:8 72:6,11
72:15,20 97:12
109:6
option 55:10
154:19,20 178:15
options 43:11
44:21 45:8,12,14

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 97 of 107 PageID #:1405

GLENN EVANS
February 29, 2016
Page 234
62:11 67:18 72:4
72:7,9,13 128:17
129:1 185:16
pages 42:23 67:19
216:13
paid 8:24 155:7
pain 105:20 208:5
208:7
palles 112:15
114:13
paper 49:16
papers 125:7
paragraph 57:9
parameter 188:4
parameters 79:18
79:21 83:3
park 180:19
part 67:22 84:22
116:3 145:20
146:8 181:23
partial 200:21
partially 42:14,16
42:17,18,19,24
57:6,8,10,11,12
57:13 58:11 67:18
participant 21:22
participate 21:13
23:1 26:15,17
participated 80:21
particular 33:23
79:17 214:24
particulars 95:4
parties 217:23
parts 48:3
party 159:10
pass 76:16
P
passage 78:20
p 1:17 2:1,1 3:1,1
passed 202:16
3:12
pat 5:6 7:3 213:4
page 4:1,8 41:24
patient 102:20
42:13,14,15,17,17 patrick 2:4
42:18,19,20,20,22 patrickmorrissey...
45:8,9 46:10,15
2:6
46:22,23 55:19
patrol 141:5 145:8
57:4,8,14 58:2
147:9 212:2,3,9

45:18
orally 7:16
order 5:5 91:14
150:20 151:2,6,7
151:13,14 156:4
169:23 170:2
185:13 209:15
213:23
ordered 126:13
orders 150:9,9
151:9 186:1
187:24 188:1,2,11
188:11
org 2:14 3:7
organization 151:3
original 136:20
originally 35:19
43:9 44:20
outage 144:22
145:3
outcome 217:24
outlined 83:20
outside 11:13 48:22
125:21 170:23
206:7
outstanding 85:20
outweighed 181:19
overall 104:9 167:3
overly 78:19 80:18
152:15
overnight 146:16
146:19
overt 181:17
overview 29:8
oxymoron 14:2

212:12,15
patrolling 145:12
145:16
patrons 177:15
178:11
pay 155:2
paycheck 9:8,10,22
10:2
payroll 9:20
peggy 1:14 217:3
218:8
pending 7:6 8:2
13:8 75:15 122:11
209:8
people 28:17 52:23
53:6 84:20 110:1
153:15 171:12,16
181:22 184:21
perform 86:24
performance 83:19
performing 211:3
period 23:14,17,18
24:18 84:18 86:2
87:23 88:19 94:20
99:4 103:23
140:20,24 199:24
202:10,11
periodic 9:8
periodically 8:19
9:16 113:12
periods 27:4
perjured 137:8
perjury 70:7
permanent 171:23
permanently
180:22
person 77:16 83:7
85:2 105:13,13
152:21 180:5
184:17
personal 52:17,20
77:6,10,11 98:8
141:14,17,18
150:14 217:13
personally 63:13

63:17 83:8 92:15
149:8
personnel 36:13
53:17 85:20 87:2
87:5 140:2 149:19
209:15
persons 104:13,16
104:20 105:1,3
152:14
persuade 184:11
pertaining 1:12
ph 210:20
phone 114:20
126:19
phonetic 32:14
photo 120:11,14
206:12
photograph 143:15
143:15,17 184:20
193:19
photographed
109:7 184:18
203:8,19,24
208:16 211:6
photographing
206:12
photographs
194:10,14 195:5
195:16
physical 103:14,15
103:19,24 104:5,9
104:11 105:7
107:24 119:15,16
145:3 190:15
201:15,16 202:4,8
202:18,24 203:3,6
203:10,12 204:17
205:4,16,21 206:4
206:5,13,15,20,23
207:8,20 209:24
210:16,17
physically 25:17
47:4 166:8 167:3
167:4,5 201:18
physicians 140:1

TOOMEY REPORTING
312-853-0648

picture 126:6,18,18
pinchum 127:13
pipe 126:23
place 44:13 176:15
177:23 190:14,19
216:14 217:17
placed 137:9
190:22
plaintiff 1:4,10 2:8
130:12,14 131:1
133:13,18,19
216:4
plaintiffs 128:14
planning 56:16
play 109:16
plead 214:15
pleading 213:12,22
214:6,12
please 5:15 37:10
37:13 158:1 184:2
po 76:24 77:1
pocket 155:7
point 13:4 28:24
29:21 102:23
103:1,2,5,8
104:14,18 105:6
110:12 116:12
134:2 139:6 144:3
144:7 169:1,3
172:24 187:13
198:5 206:6
214:22 215:6
pointed 47:8
pointing 58:8
police 6:1 9:9 10:11
10:13,21,24 13:3
13:6 17:8,16,22
18:5 19:21 20:1,7
21:1,4,6,15 22:8
22:20 23:2 25:8,9
27:23 31:3 32:2,5
34:9 40:13,18,23
49:21 50:7 51:11
51:13,15 52:12,14
53:21 54:2 55:5

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 98 of 107 PageID #:1406

GLENN EVANS
February 29, 2016
Page 235
55:14,17 57:19
60:5,12,23 61:13
64:10 66:3,7 69:2
69:5,8 73:9,23
74:4 75:20 76:2
78:5,7 79:15
81:13 93:12,13
94:2 96:1,4,8 98:3
98:15 102:10,16
108:6,15 110:6
118:19 119:19
127:1 135:13
137:20 139:11,24
152:10 162:9
187:22 188:5
205:24,24 206:1
208:12 212:11
policies 78:21 98:2
policy 35:13 82:20
98:12 144:12,16
146:19 151:23
168:2
political 85:13
127:6,9,14
politicians 140:2
poor 49:3,9,21 50:7
50:13 51:11
portion 49:8
188:15 213:11,13
portions 42:11
poses 201:14,16
posing 194:21
position 26:22 29:7
51:8 75:24 93:8
93:11,18 153:20
154:1
positioned 182:6
positive 85:17
possible 56:7 59:24
60:2 61:20,23
77:20 87:20 88:9
90:13,18 94:18
106:5 118:23
132:1 145:11
164:17 173:8,16

175:8 180:14
182:21 200:13
207:17 210:22
possibly 29:18
31:12 57:22 88:23
89:8 99:7 136:16
143:22,24 164:3
215:9
post 126:8 141:21
141:23,24
posted 205:1
posterior 106:22
potential 86:19
powers 13:4,7
19:21
practices 35:13
precursor 97:11
predecessor 97:12
predicated 50:3
74:20 187:23
predicates 133:21
prefer 116:6
preparation 10:7
11:6,9
prepare 128:23
preparing 128:20
128:22
presence 119:19
179:14,18 180:18
205:24,24 206:1
211:15
present 28:13,16
28:23 154:16,24
164:20 175:17,21
175:23 176:23
179:21 182:12,14
182:16,20 193:15
208:12 210:7,19
presently 9:4,12,21
19:1,6,10,14,21
19:24 20:18,19
32:7,10 140:11
pressure 102:23,24
103:2,5,8 104:14
104:18 105:6

pretense 174:20
pretty 13:2 54:21
158:11 171:18
173:20,21 185:4
194:1 195:10
209:11
prevent 124:7
previous 33:2,7
39:13 170:17
213:23 217:6
previously 174:11
175:16
prieto 3:11
primarily 158:10
primary 212:9,10
print 42:24
prior 12:3 17:15
25:10,12 26:21,23
27:21 31:4,15
33:10,18 36:1,8
42:8 43:5 48:17
56:1 75:24 86:14
93:10 94:1 102:9
102:15 111:13
112:11 128:24
129:7 137:11
163:22,23,24
170:5,8,21 172:15
173:9 174:5,14
175:4 177:7,17
178:1,20 179:7,15
179:22 180:3,9
181:1 188:24
189:7,14 207:11
prisoner 146:14
prisoners 141:19
143:15,17 146:1
167:16
privilege 65:13
70:17,24 71:9,19
112:8
privileged 6:17,20
7:2 117:1
privileges 70:20,21
probably 34:10

35:7 66:11 95:12
116:19 129:14,18
196:1 201:7
209:13
problem 53:15
112:5 123:8 138:2
138:3
problematic 51:22
51:23 52:2 54:7
problems 24:5
52:12 54:2,5,6,16
158:7 162:18,22
163:14 166:19,23
176:3
procedure 1:11
185:7 187:23
188:4 211:11
procedures 60:23
78:21 82:20 84:11
proceeding 187:7
proceedings 217:15
process 27:20
44:16 47:23 78:12
78:13,17 80:19,21
82:9 113:15
136:18 164:12
184:21 189:24
199:20 200:2
203:22 207:19
processed 143:16
143:17 167:10
190:5
processing 143:11
146:14 158:7
162:14,19,22
163:15 166:19
167:19 190:21
206:17
produced 84:9 98:1
productivity 86:23
profanity 61:13,22
63:15
profession 54:8,10
prohibited 91:14
91:17,21 168:1

TOOMEY REPORTING
312-853-0648

prolonged 199:24
prolonging 115:8
115:15
promote 79:16
promoted 27:10
30:21 76:11,18,20
76:23,23 77:12,16
78:1,9 79:4,8 80:3
82:13 83:7,18
86:10
promotion 27:12
27:22 31:1 33:10
33:18 81:4 83:10
84:21 85:2 86:15
86:18,19
promotional 81:2
83:21
promotions 77:4
80:8,10
proper 60:23 75:14
137:23 138:5
properly 187:8
property 61:1
126:4,13
prostitution 171:1
171:9 181:1,2,4
181:15
protocol 32:20 33:8
183:14 184:7
185:3,5,6,22
186:1,19,23 187:3
187:21 189:21
190:4
protocols 32:19
provide 22:6 23:21
82:3 188:3,17
provided 22:4,7,12
43:10 156:6 206:1
proximity 204:23
psychiatrist 154:3
psychologist 154:2
psychotic 152:18
ptsd 152:19
public 25:8 71:13
71:15 94:5,7,13

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 99 of 107 PageID #:1407

GLENN EVANS
February 29, 2016
Page 236
94:21,24 95:7,21
95:23 96:7 131:5
132:19 133:3
138:18 169:23,24
171:19,21 209:14
216:22
punched 47:6
punishment 97:16
127:10
purpose 143:14
purposes 85:14
pursuant 1:11 5:5
179:5
pushed 119:8,21
put 97:2 119:5,10
199:22
putting 14:4

157:21 158:8,9
159:4,20,22
160:21 161:15
163:3,6,9 169:6
184:7 185:14,16
185:18,22 186:4
186:11,14,17
187:5,11 188:14
188:16,18 191:22
192:24 193:10
195:2,8 198:16,22
199:3,11,16,17
203:9 205:19
207:3 212:6 215:1
215:8
questioning 200:8
questions 7:15 17:1
23:4,8 39:6 40:14
Q
41:12,23 42:2
qpwblaw 3:16
56:17,21 62:15
qualities 79:13,17
112:20 114:5
queries 23:5 72:23
136:13 141:16
question 7:6,10,21
157:2,21 158:13
8:2 14:12 16:20
159:18 161:16,18
19:4 21:24 22:21
161:19,21 184:5
23:6 24:4 33:13
185:1,10,19
34:16 36:20 37:2
188:16 198:24
37:4,8,9 38:22
199:2 200:5 213:6
39:12,14,15 41:18
213:8,14,17
42:4 53:2 55:7
214:11,18,20,21
59:7 69:6 71:11
215:3
75:5 84:7,16
quick 194:16 195:1
86:16 88:2 91:9
196:8,13 199:21
97:8 104:2 113:6 quickly 200:2
113:9,13,18,22
quiet 38:2
114:1,3,7 117:3
quintairos 3:11
118:5,6 120:17
quite 52:6 53:12,13
122:11,20 123:4,6 quote 13:12 47:9
123:10 129:23
63:21
130:6,8,10 131:11
R
132:9,20 135:16
135:22,24 136:2
r 2:1,17 3:1 5:13
137:3,5,6,15,21
race 53:13
138:2,4,9,12
raise 34:18 37:11
142:11 155:24
37:14,24,24 38:1

38:7,15 158:24
59:24 60:6,7,11
raising 38:17,18
60:13,21 61:21,23
116:8
62:22,24 64:1,8
ran 126:22
64:14 65:8 66:14
range 25:4 147:5
66:16 68:18,22,24
rank 20:19,21 96:8
68:24 70:9,11
rate 9:4
75:23 82:9 83:1
read 43:20 58:12
88:1,3,8,10,21
62:23,23 67:23
89:5,6,10 90:12
123:14,16 130:7
90:14,19 91:6
136:19 188:15
92:11 93:3 94:19
216:11
95:3,5,24 96:14
ready 41:12 101:24
96:14,15,19,21
114:17
97:7 99:21 101:17
real 11:24 34:19
104:4 106:4 107:2
54:8,9 97:1 126:5
107:13 108:12,21
152:16,20
109:5 110:17,21
really 11:24 22:21
110:22 111:1,7
26:2 43:1 104:2
118:23 121:10,16
107:5 112:23
124:13 125:2,18
116:9 132:7
128:20,22 135:1,9
135:21 139:13
138:16 139:4
152:16 156:21
141:3 142:20
169:6 205:18
143:1,5 144:2,7
207:18
145:10 156:19,21
reask 59:6
157:15,17 161:12
reason 67:22 131:9
161:15,19,24
188:7 209:9
162:11,16 164:9
reasonably 61:3
164:16 165:3
62:16 74:9 125:21
166:9,14 167:8
reassigned 17:7
169:9 170:14,15
reassignment
171:6,10 172:3,6
17:16 18:12
172:13,14 173:7
recall 10:3,6 11:13
175:8,11,20 177:6
12:15 13:19 18:8
181:3,3 182:13,21
18:10,16 26:2,9
183:5 191:8,16
27:15 28:3 29:1
192:9 193:13
29:17,19,20 30:7
194:6 195:3,14,24
30:18,22,22 31:10
196:2,2,20 202:11
31:12 34:15 35:10
202:12,23 204:13
40:17 45:16 47:12
205:17,20 206:6
48:7,13,15 49:5
208:14 210:5,20
49:11,12 50:17
210:22,24 211:1
53:16 54:12 55:3 receive 9:8,11,15
55:10,24 56:4,5,8
9:20 24:6 87:15

TOOMEY REPORTING
312-853-0648

89:2 100:20,22
101:20
received 23:11
67:17 78:23 155:4
179:19
receiving 10:1 89:5
89:10 104:4
recipient 95:6
recognize 183:1,2
recollection 13:24
24:22 33:24 46:4
48:19,21,22 49:3
49:9 51:5 60:16
70:7 86:6 89:19
89:23 107:17
121:6 126:3,17
141:1 147:12
157:6,19 161:6,10
170:10,19 178:22
179:4 182:7
183:10 185:13
188:22 192:1
197:5,20 198:9
recollections 29:4
recommend 35:3,6
84:20
recommendation
23:12 24:3 40:3
78:5,9 79:7
recommended
27:17 34:6,23
35:10,20 36:16
43:10 44:20 45:17
77:16,18 78:1
record 5:16 15:12
38:20 39:11 59:8
71:22 112:22,24
113:3,16 114:8
115:18 116:22
118:5,7,9 119:5
119:10 123:15
131:5,13 132:19
133:3 144:17
171:20 213:3
215:7 217:14

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 100 of 107 PageID #:1408

GLENN EVANS
February 29, 2016
Page 237
recorded 30:5
recorder 30:3
recording 30:3
records 93:7 94:11
102:5 144:10
177:2 184:16
recovered 61:1
reduced 54:13,15
217:12
refer 93:8
referee 116:16,23
117:3
reference 108:10
referred 32:4
referring 77:10
109:24 200:13,14
201:4
reflect 43:9 44:19
55:20 72:10
144:10
reflects 60:10
72:14
refresh 11:17 29:22
31:13 40:21 53:4
60:16 164:18
185:13
refusing 183:15
184:9 185:24
regarding 18:2,9
20:23 21:11 22:9
22:19 29:14 31:1
33:16 36:3 52:6
52:14,17,20 53:6
53:17 69:3 70:13
75:14,18 79:20
81:2 82:20 87:23
89:20 90:5,13,24
91:3,10 104:5
113:22 135:12
137:7 138:18,22
139:5,10 150:10
158:1 164:21
168:21 191:12
regards 86:17,18
98:2 130:21

192:20
region 105:3
register 46:17
regularly 179:20
180:11
rein 171:19
reinstated 19:18
related 157:2
relating 10:22 11:1
24:1 40:8 63:5
66:7 94:22 103:23
150:20 151:11
154:6 156:24
relative 119:16
124:23 157:11
202:14 217:20,21
relatively 202:2
release 209:5
released 208:17
relevance 14:7,21
62:15 73:13 74:7
75:5 87:17 88:6
109:1,14 114:3,16
115:20 116:2,11
125:20 134:5,16
135:6,15 136:8
137:15 138:24
139:12
relevancy 47:15
114:6 117:20
relevant 15:2
114:22 115:21
117:21 118:10
188:10
relieved 13:3,6
relieving 184:14,16
remarked 68:15
remember 28:24
29:5 40:14 47:23
48:2,3 59:21 60:6
66:19 69:23 72:3
87:19 92:19
109:18 137:5
154:5 156:16
157:20 158:12

163:13,17 164:5
184:5,24 185:9
194:11 198:6
199:1 200:4,7
204:4
remind 68:6
renew 74:6 85:4
rennie 121:24
122:8,8 124:14,18
124:18,18
repeat 44:6,7 84:16
91:5 122:23 123:9
123:12,13 163:9
rephrase 31:22
97:8 129:22
142:10,13 183:23
184:2
report 8:18 18:21
19:1,6,10,11
24:16 34:4 43:2
44:11,23 45:19
46:16 49:7 64:4
69:10,13 98:23
145:1 209:19
210:2 211:18
reported 176:1
177:8 211:22,24
212:1 217:11
reporter 1:14 70:3
81:6 100:2 118:2
128:7 156:13
169:14,17 217:4
218:9
reporting 18:17,19
211:5
reports 10:11,12,13
10:14,21,24 11:2
11:4,8 12:1 53:8
59:18 60:15 69:10
69:11
represent 5:7 15:13
54:24 114:13
155:8
representation
55:2 64:11,13,15

66:18,21 67:5,6,8
represented 111:11
116:12
representing 15:10
37:18,19 113:8
request 20:17
27:10,12 34:3,4
79:15 80:2 82:2,8
82:11 83:17
requested 123:16
require 82:23
required 109:6
130:21
requires 24:16
requisite 155:3
reread 188:18
reserve 101:24
reserved 215:14
reserves 101:12,15
101:18,19
residence 89:21
residential 90:9
resisting 210:11,14
210:15
resources 80:18
respect 38:10 44:9
62:14 136:12
214:12
respond 22:1 43:21
74:13,15 137:3
192:4 198:16,22
198:23
responded 191:23
192:6 193:10
198:17
responding 163:3
response 7:19 33:3
33:7 36:23 37:3
39:13 53:15 72:24
73:2,4 130:10
149:24 151:14
154:3 192:23
193:6,20 198:21
209:19
responses 25:9

TOOMEY REPORTING
312-853-0648

26:4 74:21 133:9
161:9 188:22
198:18
responsibilities 6:9
8:13 21:21 25:6
26:10 135:12
141:7 149:16
responsible 212:3
responsive 186:6,8
186:14 187:10
rest 11:13 211:4
restate 14:3 16:20
137:2
restraint 104:15
result 59:22 95:16
110:20 127:22
retain 91:15 155:1
155:8
retaliatory 85:14
retired 140:11
review 10:7,16,18
10:21,24 11:3,8
21:14,22 22:5,10
22:19 23:2,13,15
23:21 24:2,8,10
24:14 25:2 26:16
26:18 40:3 42:9
43:3 57:16 58:1
83:2 93:7 94:11
129:1,7,9,10,17
133:3 151:13
154:11 155:14,23
156:1,3,7 173:17
175:3 177:1
188:23 189:19
reviewed 10:10,14
11:5 42:12 92:12
92:15 154:9,13
189:3,6,13
reviewing 129:16
reviews 32:17,22
ricky 132:6
ridiculous 137:2
rife 46:11 69:11,12
74:18 200:20

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 101 of 107 PageID #:1409

GLENN EVANS
February 29, 2016
Page 238
right 8:14 15:14
17:3 31:8 39:17
39:23 56:19 57:15
63:3 67:9 68:13
71:14 80:21 106:3
112:12 113:24
116:19 117:14,17
117:18,24 118:17
118:22 130:17
131:18 159:21
179:6 184:4
200:16 207:3
213:10,18 215:14
215:15
rights 2:10 3:3
70:16
ring 190:24 211:9
risk 191:2 201:20
rita 1:3 5:7 10:22
11:1 35:17 36:3,9
36:12,14 37:18
47:20 56:24
111:22 117:8
125:23 136:16
154:6 157:22
172:22 183:1
200:14 205:16
216:3
robert 32:14
rodgers 2:17 140:7
140:9,14,23 145:9
145:16 182:12,19
188:23 194:3,5
198:8,10 201:8
205:3 208:11
210:8
room 52:9 164:1
211:8
rooms 190:18,19
190:21,23 191:5
roslyn 157:23
roughly 27:6
routinely 49:22
rude 163:8
rule 15:11 16:7,13

16:14,16 57:15,19
207:23
58:5 59:11 61:24 screams 208:1
115:13,14,14
se 128:23 179:1
188:3
209:23
rules 1:11 8:1 15:9 search 90:13
57:17 64:10
167:21,22,24
running 47:15
168:2 176:20
56:20 62:14
193:2
searched 167:17
S
searches 167:24
s 2:1 3:1 4:6
second 34:17 42:15
safe 212:20
43:18 45:8,9
safety 25:8 65:14
72:13 110:2,7
138:19 168:6,8
122:18 147:2,3
saith 215:17
170:16,18 192:7
sake 188:20
207:3
salient 157:19
seconds 98:21
saw 183:7 191:20
section 59:10
saying 11:12 22:11
144:21
36:1,8 58:24
secure 190:14
100:8 157:5,14
secured 127:12
205:23 213:21,22
211:9
says 16:15 39:12,21 security 178:10,11
46:19 58:3,14
178:11 206:1
59:10 63:2
see 42:13 45:3,3,4,4
scene 61:1
45:8,9 46:9,19,24
schizophrenic
47:10 49:1 57:3,6
152:18
58:5,14,16,17
school 99:16,17,19
59:12,15,17 60:15
99:22 100:6 101:5
64:18 67:15 69:1
101:6
69:9 72:16 83:9
schumann 3:13
113:11 120:19
15:1,11 16:6,12
128:16,19 130:13
43:12,22 107:7
138:9,12 187:17
114:2,6 115:7,11
201:2 214:23
115:23 116:1
seeing 40:24
117:15,18 118:4
seeking 171:23
159:6,8,11,15
177:20,21,22,22
214:22
178:3,7,12 179:22
scope 75:5 116:9
179:24
125:21
seen 43:6 179:24
screamed 126:10
selfreport 180:15
198:19
selfvictimization
screaming 38:18
181:16
183:11 207:21,22 send 7:1 190:1

sent 6:23 40:4 81:1
190:6
sentiments 194:1
separated 190:18
190:19,19,20
sergeant 76:10,20
76:23 77:1,17
78:2,10 86:3,11
86:19 87:8,14
88:4,9 93:10,19
93:21 94:3,13,21
95:18,21,23
serve 101:9,11,14
101:18
served 21:10 111:9
111:12 119:3
124:22,24 125:4,7
132:4,13
service 20:21
126:10
services 127:12
145:4 177:20,21
178:12 181:22
set 128:13,14
185:24 218:1
settle 121:21,22,23
settled 107:16
121:5
settlement 119:9
127:20
settling 121:10
severity 157:12
shed 182:8,9
shelter 171:24
177:22,22 178:4,8
178:8 179:22
180:1 183:4,5
shes 175:15 201:18
shields 87:13
shoot 110:3,8
short 140:4 169:4
202:13 207:5
shorthand 1:14
217:4 218:9
shot 109:12 110:1,5

TOOMEY REPORTING
312-853-0648

110:12,13,17
shouldnt 38:12
show 40:20 161:20
200:16,24 215:13
showed 98:23
185:14
showing 41:8 62:9
128:12
sic 131:11 133:22
186:4
sick 63:22
side 99:20
signature 128:16
129:1 215:13
signed 129:24
161:7
significant 169:22
signing 128:24
silence 139:11,24
similarly 38:11
simmons 107:14
121:13,17 122:1,5
122:8,9,9 124:14
124:24 125:3,5,10
125:12,19 126:3
simple 201:24
simplify 22:1
sir 28:3 57:3 64:19
113:21 128:12
141:16 151:13
202:23
sit 53:18 92:11 93:6
169:9 182:10
sitting 182:8
situation 105:22
110:7 179:2
situational 105:12
105:21
sixth 72:4
skahill 88:23,23
skills 153:11
sleep 171:4 177:23
sleeping 180:1,5
slowing 118:8
smaller 192:10

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 102 of 107 PageID #:1410

GLENN EVANS
February 29, 2016
Page 239
smart 126:21
smoked 172:7
smoking 172:10,12
172:14
social 138:18
socializing 172:13
softwarebased
145:6
soliciting 181:10
solitary 181:7
somebody 78:1
80:2 81:3 83:4
173:22,24 174:1,2
183:14
somewhat 67:23
soon 182:1 200:12
sorry 10:23 21:2
38:5 43:23 53:13
71:5 86:8 91:5
93:9 94:24 97:12
97:20 102:13
107:7,9 110:24
118:2 120:24
124:19 130:1
131:21 144:14
146:7 203:5 204:9
205:8 208:23
sound 178:5
south 1:15 2:5 3:14
25:19,20,20 99:19
165:13,17
speak 15:24 38:14
84:10 98:13
speaking 15:10
67:5 137:18
151:22
speaks 44:23
159:13
special 150:9
specific 18:7,8
41:23 73:17 77:22
78:11 86:22 103:5
103:8 150:22
153:12,18 161:18
161:19 164:21

171:15,18 191:14
191:16 193:24
195:21,24
specifically 17:21
50:9 162:16
165:11 167:1,2
168:15,16 175:20
193:5
specifics 166:14
182:3
specified 217:17
speculation 82:5
84:3 147:15 148:7
148:17 202:19
spelling 88:17,18
spirit 188:8
spoke 196:17,18
square 165:24
ss 217:1
staff 169:4,11
201:17
stairwell 109:23
stale 47:16 56:22
61:4
stamped 58:22
stand 33:2,6 36:22
39:13,21 119:22
120:1,3 155:19
161:8 182:9
200:23
standard 72:21,21
72:22 92:22
173:21
standardized 72:24
73:2,4
standards 83:22
standing 151:2
181:5 194:5
197:11 204:24
star 57:10
start 42:2 65:12
72:8 187:11
starting 95:7
state 1:15 5:15 33:5
100:19 118:9

199:13 200:10
217:1,4
stated 8:11 121:19
127:5 158:5
203:20 217:19
statement 72:5,8
72:10,13,14,18,19
72:21,22 73:6
75:2 154:5,10,13
154:17 155:9,12
155:15,20,23
156:3,7,8,12,23
157:3,5,7,16,16
159:9,12,13,16
160:19 161:7,7
173:15,17 184:6
185:11,13,20
189:18,19 200:20
200:22,23
statements 73:8
155:18 158:12
161:24
states 1:1,12 73:20
82:20 216:1
static 105:19,19
stating 119:18
station 142:23
143:3,5 157:24
158:3 162:9
165:10 177:12
178:18 179:5
180:2,20,21
198:11
stationary 141:24
stations 142:22
status 40:7 140:12
155:2 214:4
stay 171:4
stayed 171:21
stenographically
217:11
stepped 182:11,15
182:18,23
stepping 111:14
steps 193:16

195:15,21,24
sticker 126:8
sticks 11:10
stipulate 8:4
stipulating 8:10
stop 10:1 112:4
168:3
stopped 160:3
174:16,22 175:4
175:24 176:24
177:7
storm 178:18
180:20
strained 169:10
street 2:12 3:5
145:11,14 170:24
174:16 176:24
177:14 181:6
190:7,8
streets 145:16
171:8 174:23
175:4 176:1
stretching 95:14
strike 12:6 20:18
20:18,23 79:24
89:11 129:22
146:8 172:21
210:8
striking 47:5
stringon 23:5
stripped 18:13
struck 47:5 108:23
structure 107:24
subject 46:17
subjects 47:8
submit 34:4 78:23
81:3 193:19
194:10,14 195:5
195:16 215:4
submitted 11:12
submitting 82:21
subordinate 149:18
175:7,10,12,13
subscribed 216:19
subsequently 46:5

TOOMEY REPORTING
312-853-0648

110:1 127:12
184:23 203:23
substance 174:18
176:2
substantive 181:18
sue 107:6 132:6
sued 110:22 111:1
118:16 127:19
suffered 176:8
suggestions 79:3
suicidal 174:2
suite 2:13 3:6
summary 46:16
97:15
summer 69:3 70:12
summertime 30:14
30:16
superintendent
12:21,24 17:15,20
18:11 27:22 28:2
28:10,11,14,21
29:14,24 31:1,16
83:6
superintendents
27:17 80:15
superior 22:24
supervise 149:9
supervised 149:11
supervisor 97:17
97:17
supervisors 80:17
supplement 133:8
supplies 144:20
supposed 91:23
117:16
sure 41:15 44:1,4,9
48:24 60:19 68:3
90:23 95:15 107:5
132:5 152:21
214:13,21
surrounding 13:20
surveillance 143:19
143:23 144:23
suspected 170:24
181:2,4

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 103 of 107 PageID #:1411

GLENN EVANS
February 29, 2016
Page 240
suspects 14:5,18
16:22 17:5
suspended 35:6,11
35:20 36:17 40:13
40:17,23 45:20
55:14,17,23 56:2
56:5 57:12 59:19
59:21 60:4 64:17
88:5,8 95:22
suspension 40:4
43:11 44:20 45:15
45:17 48:12 54:12
54:18 55:5,20
60:1,9,10 62:11
suspensions 60:11
sustain 97:5
sustained 23:16,22
41:10 46:19 58:4
96:18
sutton 2:17 146:22
147:10 148:4
156:17 157:23
158:10,10 162:2
162:17 163:2,11
163:18 164:6,13
164:24 166:13,22
168:5,23 172:15
172:21 182:1,16
189:17 194:8,12
195:3,14 196:19
197:2,10,22,24
201:6,8 204:16
205:20 206:3
208:10 210:7
suttons 147:13
189:10
switch 68:1,8,11
sworn 5:2,11 73:7
155:17 216:10,19
217:8
syd 87:12
system 81:13,16
T
t 2:16 4:6 5:13,13

tackled 126:24
tactical 209:18
take 7:20,23 8:1
24:9 29:7 41:10
41:13,19 42:5
45:15 70:7 76:11
76:22 77:1,12
78:22 83:13 85:16
85:17,22 110:11
113:18 122:20
123:1,20 126:6,10
129:12 140:3
164:23 165:1
166:1 177:13
180:18 196:7
207:2
taken 1:10,13 5:5
216:13 217:16
talk 50:11,16 52:10
52:13,23 112:17
122:18 124:4
158:23
talked 50:6 60:8
115:10 121:13
158:8 196:5
talking 31:24 53:9
53:11 55:11 71:4
91:17 111:21
112:4,17 119:1
153:4 163:21
165:22 177:23
178:14 202:9
214:10
talks 47:3 50:20
tape 30:3
taperecorded 53:8
53:9
targeting 152:22
tasered 106:18,20
121:20
task 84:19 86:23
tasked 97:14,16,17
taught 103:23
104:16,19,22,24
105:5

technical 145:4
technique 102:23
103:1,3,6 104:18
104:24 105:6
techniques 103:9
103:22 104:22
105:2,15
telephone 7:7
143:4,6
tell 10:10,13,15,17
11:5,7 12:11
18:11 21:21 25:3
26:8 27:4 28:18
28:22 29:5 32:13
33:8,19,22 35:1,9
38:15 49:24 56:1
73:1,3,4,7 78:13
78:16 80:6 87:8
88:15 96:2,15
100:14,16 101:22
103:22 105:15
133:17 134:1
135:23 155:17
158:1 161:11
162:2,6,18,21
163:12,19 164:14
166:7,22 167:6
168:5,10,15,16,24
170:12,17,19
172:22 174:15
182:13 193:22
194:8 197:23
198:4 205:1 208:4
208:6 210:9
telling 47:8 73:5
115:6 155:16
164:6 195:15
temporarily 146:24
temporary 149:3
ten 84:1,24 202:15
term 102:22,24
173:14
terminated 20:12
20:14 46:6
terms 87:5 112:7

145:12 172:10
205:23
territory 112:7
test 76:19 86:10,13
testified 5:11 86:9
93:21 125:11,15
testify 59:12
124:10,11 125:16
129:8 189:1,8
217:8
testifying 124:8
125:14
testimony 98:2
174:8 189:4,7,11
189:14 216:16
217:14
text 6:24 7:1 57:8
texted 6:22
texting 6:12
thanks 215:15
thats 6:17 9:17,18
14:2 16:4 18:15
20:21 21:24 22:21
24:4 26:3,7 32:23
33:13 39:4,14,16
39:22 40:19 44:17
45:2 48:3 50:5
53:2 54:11 57:6,9
57:13 59:16,17
63:4 69:6 70:6,9
72:7,22 73:3 77:2
83:22 84:22 85:10
86:16 93:24 95:14
96:7 104:1 106:8
108:5 109:23
112:18 113:8,9,13
115:2 116:21
117:5,7 121:15
122:7 124:17
131:9 133:9
137:22 150:21
152:14 154:3
156:14 158:24
159:19,22 160:2,8
160:11,11,17,21

TOOMEY REPORTING
312-853-0648

160:23,24 161:2,6
162:4 169:6
173:16,20 176:11
178:13 185:21
186:19 187:14,15
199:17 200:19,22
201:12 202:14
203:9 209:18
212:20 213:10,20
213:21,23 214:9
theres 7:6 11:24
16:14,16 23:17,18
31:18 32:9,12
35:15 46:21 48:2
58:3 63:20 65:11
69:19 78:11 91:12
91:22,24 104:22
122:5 131:9 132:5
142:17 152:3,3,4
152:16,20 201:10
theyre 47:16,17,17
80:8 91:23 119:22
168:1 185:23
theyve 54:9
thing 14:1 39:11
41:14,17 195:12
204:22
things 176:10
think 26:2 28:8
29:8 39:14,16,16
39:22 42:19 43:17
47:21 52:8 71:17
75:13 95:14 96:13
101:16 107:14
112:18 113:5,9
117:13 121:18
132:8 136:17
154:3 160:16,17
160:20 169:1
174:6,11 177:10
189:17 192:5
194:5 206:9,10
210:22 213:2
214:2,7 215:8
third 88:18 170:18

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 104 of 107 PageID #:1412

GLENN EVANS
February 29, 2016
Page 241
thomas 2:3,4 37:10
37:13,21 38:6,16
38:21 108:24
thought 52:11
115:9 213:7
thousands 50:17,18
50:19
threat 105:22
167:15 194:21
201:15,16 210:18
threaten 109:22
threatened 68:20
69:4 110:8
three 95:13 132:20
132:22 142:21
152:5 170:11
197:18,19
threw 106:8 178:6
throat 14:5
tiffany 2:12,14
time 18:24 23:14
23:17,18,20 24:12
24:15,18,20 27:4
34:8 44:8 45:14
49:12 55:10,13,16
60:4 65:21,22,23
66:2,6 69:16 70:1
78:20,22 80:10
86:2 87:7,12
94:12 101:10
107:19 108:10
113:12 124:11
129:12,15 131:6
137:19,19,20
144:16 145:14,14
154:9,21 157:6,16
166:11,13 169:21
169:22 170:12,14
170:16,18 171:2
176:15,21,23
177:4 180:17
181:9 184:14
196:2 197:24
199:24 202:10,11
202:13,13,16,17

203:13 206:16,17
211:19,20,20
216:14 217:17
timeframe 30:23
34:7 202:24
203:11 208:19
timely 24:23
times 11:18 29:15
31:8,14 34:11
35:8 40:12,17,22
52:15 53:7,20
54:1 56:2,6 65:1
73:22 77:24 78:3
80:1 82:22 92:9
92:10,12 95:5,11
95:12 110:17
132:20 134:13
135:1,3 170:8,11
171:4,11,21
177:10,11 178:2
178:23
tina 88:23
title 5:22 94:2
211:24
today 26:6 42:8
43:5 92:11 124:8
156:24 169:9
189:1,7,14 214:1
todays 10:8 11:6,9
told 20:3,5 22:24
54:22 126:7
154:23 174:12
195:4 196:1 213:7
213:16
totality 157:14
totally 117:6
tour 184:13,19
track 136:21
train 154:2
training 22:4,6,8
22:12,18,23 99:9
104:4 147:20
148:1,2,4,11,12
148:15 149:1,2,4
151:15 152:4,8

153:12,14,21
transcript 30:2
136:19 161:21
188:24 216:12,15
217:11
transferred 12:17
12:19,22,24 17:22
18:2,3
transformed 50:24
51:4
transport 102:21
transported 157:24
178:17
treat 153:22
treatment 178:16
trial 62:20 187:6
214:8,9,16
tried 109:21 110:11
164:12 186:22,24
187:2 193:18
194:9 199:20
trr 209:17,20,24
true 166:12 216:15
217:13
trunk 126:22
trust 74:21
truth 26:9 73:5,7
155:16,17 217:8
truthful 160:20
truthfully 124:8,10
124:11 125:14,16
try 184:11
trying 113:16
159:1 160:2,18
turn 187:9
twice 36:20 96:6
two 32:12 47:8
59:19 63:22 95:11
95:12 110:1 122:5
132:5,22 137:1
142:20,20 170:22
174:4 178:23
191:22 192:8
202:2
twoday 60:10

type 34:13 35:2
152:20 194:24
types 103:11
typewriting 217:12
typically 24:9
39:19 167:9,17
187:4

vacant 126:4,4
vague 29:3 86:16
152:15 192:14
204:8,18 205:6
vaguely 42:13 48:2
valid 70:24
varied 34:24 35:1
147:4 150:2
U
151:24 196:24
uncooperative
197:18
176:6 193:3
varies 25:3
underlying 47:19
variety 103:9 197:8
56:23 57:1 61:6
various 96:3
understand 19:3
116:21 144:19
26:5 55:6 114:22
153:16
116:17,24 135:21 vary 152:2
135:24 136:2
vehicle 126:16,22
159:2,21 183:19
175:9,11
186:13 213:19,20 vehicles 181:7
understanding
verbal 97:13 98:18
44:1 45:12 91:20
194:6
133:14 144:15
verbally 105:8
understands 113:7 verbiage 126:20
understood 8:3,9
verified 128:15
unfair 113:13
160:19
unfounded 90:4
verify 160:18
96:19 128:4
versus 133:22
unimpeded 91:24
viable 83:10
union 55:2 64:10
vicious 110:18
67:7,13 155:2,3
victimization
united 1:1,12 73:20
181:16
216:1
video 152:4
university 100:18
videotape 30:3
100:24 102:18,19 view 52:15
unlawfulness
violated 59:11
174:19,20
violation 35:4 58:5
untrue 13:15
violations 57:11
use 32:1 45:14
violence 169:23,24
81:15 104:7,15,23
170:3 209:14
105:1,2 173:14,19 voice 34:18 37:11
207:16
37:14,24 38:7,15
usually 142:11
38:18 158:24
184:10,11
volume 52:3
voluntarily 72:15
V
72:19

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 105 of 107 PageID #:1413

GLENN EVANS
February 29, 2016
Page 242
vs 1:5 216:5

146:23 147:1,2,3
149:11,14,15,17
W
149:21 150:5
wacker 3:14
165:6,8,20 166:2
wagon 178:16
172:20 184:15,16
wait 112:1
211:4
waiting 16:6,12
water 122:1 126:8
walk 166:2 182:9
watermarked
206:8,9,10
58:22 67:24
walked 182:5 202:7 way 11:24 54:22
202:16 206:6,17
56:10 76:19 97:2
walking 28:17
119:4 136:10,14
wall 190:24
138:7 187:12
want 7:20 15:24
192:11
39:10 41:13 42:1 ways 144:19
50:23 59:3,6 68:1 weapon 19:24 20:4
72:7 78:19 105:18
20:5
108:9 112:23
weapons 167:22
113:2 116:22
weather 171:5
117:2 123:20
week 150:1
131:13 138:5,6
went 18:18 27:20
143:16 155:22
63:7 98:21 99:19
160:9,15 163:4
100:13,14,17,17
184:22 187:12,14
109:22 126:16
188:17 198:20
158:4 208:21,24
199:5,18,21
western 1:15 2:5
201:10 204:7
101:1
209:22 214:13,17 weve 50:20 132:19
214:19,20,23
136:24 196:10
215:3
whatcha 46:11
wanted 124:2 126:6
102:2
126:8 160:24
whats 12:9 41:8
199:9 200:12
62:9 71:6 97:8
209:7
114:2,6 116:10
wants 123:14
147:22 148:14
ward 127:6,7,7,8
150:23 192:2,13
140:2
193:1,10
warrant 90:14
whereof 218:1
209:7
wholly 44:13 47:22
wasnt 164:12
whos 113:7
177:21 178:7
wife 65:4,19,20
179:24 186:8
66:5 71:12
209:6 213:8
wilfredo 2:17
waste 131:6
william 49:18
watch 69:19,20
williams 47:3 48:14

48:20 88:22 132:6
133:21
willibrord 100:1
willing 29:7 116:4
window 193:23
witness 4:1 5:1,10
6:15,19 7:11 8:6
11:22 14:15 15:17
16:5,16,19 17:3
19:5 28:7 33:1
34:19 36:21 38:3
41:16,21 42:5
43:19,23 45:1
48:1 51:17 52:19
55:8 58:10,17
61:9,16 62:21
65:7 67:11,16
70:4,5 71:1,5,20
71:23 73:16 74:13
74:16 75:7 76:6
77:9 78:18 81:8
82:7 84:10,15
85:7 87:18 88:7
98:10,22 99:12
100:4,7 107:9,10
109:2,9,19 111:16
112:2,5 115:1,2
115:16 120:18,24
122:17,22 123:1
123:11,17,22,24
124:4,17,21 126:1
129:13 131:8
132:10 134:10,19
135:8,20 136:1
138:9,13 139:3,20
139:22 141:13
142:12 147:16
148:10,19,23
150:15 151:21
153:2 156:2 157:4
161:5 163:7 164:2
169:16,18,20
174:10 183:21
184:1 185:2
186:16 187:20

192:16,19 195:9
195:20 202:22
204:9,12,21 205:8
205:12 212:8
217:7,7 218:1
woman 66:13
108:23 124:16
wonder 158:23
wont 39:2
wood 3:12
word 57:12
worded 185:21
words 126:19,20
work 5:20 31:3
86:23 102:12,14
140:13 142:22,23
143:3,5 145:19
146:21 198:10
worked 20:24 21:3
21:5 53:19 189:23
working 25:10,12
85:14 120:4,21
145:12 165:7
works 16:5
worth 213:18
wouldnt 138:15
142:8 155:6 177:5
213:17
wrench 126:23
wrestle 109:21
writing 78:6 82:12
117:12
written 20:6,8
76:14,16,22 77:1
78:8 80:2,12 83:5
152:3 156:13
wrong 93:20 192:2
193:10
wrote 100:5
wysinger 18:24
19:2
X
x 4:1,6 5:13

TOOMEY REPORTING
312-853-0648

Y
y 2:12
yeah 28:6 34:19
41:16 59:16 61:19
66:11 67:11 73:19
76:5 82:17 95:2
98:23 115:11
123:9,24 133:20
136:10 142:13
158:19 159:8,11
161:23 185:21
199:4 200:18
207:4 215:12
year 101:2,4,6,14
107:2
years 44:12 47:17
55:11 56:22 59:17
63:22 93:13 94:6
132:22 144:2,7
168:17 193:12
198:1,5 211:21
yelled 198:19
yelling 183:11
yep 124:5
youd 113:19
youll 22:1 23:6
84:16
youre 8:21 26:5
31:23 32:24 33:20
34:19 35:12 43:17
53:11 55:10 71:14
72:19 74:19 85:10
85:10 94:17
106:12 109:24
111:21 112:6
113:6,14 115:7
116:20 117:6
122:3 131:22
136:14 141:13
152:22 153:3
158:19,20 160:18
161:9 163:21
178:5 202:20
205:23 215:11

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 106 of 107 PageID #:1414

GLENN EVANS
February 29, 2016
Page 243
youve 11:18,19
40:12 96:3 105:15
123:3 132:23
133:2 138:10
153:6,7,10 213:5
214:14

1216 216:13
128 4:13
13 1:5 216:5
15 1:17 35:20 36:17
54:13
15day 40:4 48:12
54:18 55:5 60:9
Z
16 62:12 63:3
18 42:15
0
18th 42:15
00 147:6,7
19 72:10
03 93:22
1937 1:5 216:5
04 58:14 59:14
1980 101:8 102:6,8
06 93:23
102:15
084003813 218:10 1986 93:15 99:13
99:14 101:3 102:6
1
102:8,15 103:4,4
1 1:17 4:9 41:3,5,9
1989 101:16
43:8 44:19 46:16
1990 56:6
54:12 55:20 58:3
1991 58:15 59:14
60:8 67:19 119:15
59:23
181:14
1992 60:22 62:12
10 157:22 170:5,8
63:3
170:21 172:4
1993 68:19 69:3,8
173:9 174:5 175:5
70:12 72:11
177:7,17 178:1,20
108:13
179:16,23 180:3
1994 47:13 48:14
181:1 182:24
48:19 101:17
191:4 202:5
108:22
203:13 206:21
1995 55:21
210:4
1996 96:1
10150 1:15 2:5
1998 93:16 94:24
10th 149:13 150:3
1999 94:8,9
156:16 172:16
19th 127:7 140:2
174:14 179:7
180:9
2
11 12:10
2 4:10 56:12,14
111th 25:12 190:6
57:4 60:9 67:19
190:8
119:17 181:15
11th 12:12 17:7,22
190:2
18:4,5 21:8,11,12 20 47:17 59:17
21:20 22:4,12,14
177:7
22:16 23:10 25:1 2002 94:10
25:7,10 26:12
2003 86:7,7 94:1,9
108:22
2006 27:8 86:8,8

122:10 125:19
2007 107:4,8,9
2011 136:24 140:13
141:6 142:16
143:7,21 144:24
146:2,9,15,21
147:13,21 148:5
149:10,13 150:3,8
150:19 151:11,16
152:7 156:16
157:22 165:5
166:2 170:5,9,21
171:7 172:4,8,16
173:9 174:5,14
175:5 177:8,17
178:1,20 179:7,16
179:23 180:3,9
181:1 182:24
183:13 189:24
191:4 202:5
203:13 206:21
210:4
2012 26:1 27:9
30:11,14,16 111:5
2013 128:16 129:5
132:22 155:12
210:10
2014 6:8 8:17,18
10:5 12:16,18
26:2
2016 1:16 86:8
216:21 218:3
20something 55:11
21 210:20
211641 46:18
21st 127:7
22 44:12 185:17
201:1
233 3:14
2337900 2:6
24 56:22
25 59:17
25yearold 136:13
27 47:3 108:13
27th 48:14,19

29 1:16

60602 2:13 3:6
60606 3:15
3
60643 2:5
3 4:11 42:18 62:4,6 62 4:11
62:10 67:19
6630 72:7
181:17
67 4:12
30 2:12 3:5 45:4,7
6th 27:2,5 52:24
45:17,21 48:11
53:6,16,19 58:4
54:13 84:10
76:1,3 88:13,24
141:12 148:19
89:13,18 90:17,22
30day 43:10 44:20
91:2,8 96:6
31 42:21,22
107:21,23 140:17
312 2:14 3:7,15
141:7,20 142:15
37 117:16
142:18 143:8,20
390 185:16
144:9,16 145:7,18
393 201:1
145:22 146:2,5,9
3rd 18:3 25:15,16
146:15,17 149:14
25:23,24 26:11,15
149:20 150:5
26:21,23 69:13
157:24 158:2
96:6
162:8,10 165:4,10
165:11,16,21
4
167:7,18 177:19
4 4:12 42:19 66:23
178:3 179:15,22
67:2,18,19 68:12
180:4,9,14,16
68:15 72:5 75:17
183:6,14 185:5,6
147:6
189:21 190:5,13
41 4:9
190:16 191:20
202:8,17 203:14
5
205:5,13 210:3,12
5 4:13 67:19 128:6
128:9,13 130:8
7
5212 4:4
7 42:21 67:19 130:7
56 4:10
130:8 131:20,24
5660040 3:15
133:12 155:12
5848 56:10
185:16
5852 56:11
7030 25:19
5th 76:7 86:3 87:9
7040 25:20
87:11,14 88:5
70th 3:14
93:10,22 190:1,8 7100 25:19
7445106 3:7
6
7447684 2:14
6 57:15,19 58:5
773 2:6
59:11 67:19 84:10
78th 107:24
141:12 147:7
148:19
8

TOOMEY REPORTING
312-853-0648

 Case: 1:13-cv-01937 Document #: 182-6 Filed: 03/11/16 Page 107 of 107 PageID #:1415

GLENN EVANS
February 29, 2016
Page 244
8 57:5 61:24 67:19
67:19
86 21:6 98:16
103:13,13 104:6,6
8th 127:8
9
90 214:7
900 2:13 3:6
911 126:14
92 56:11 57:5
93 72:6 108:14
94 47:4
95 45:16
98 93:17 96:2 98:16
99 96:2 98:16
9th 129:4

TOOMEY REPORTING
312-853-0648