Return Date: No return date scheduled Hearing Date: 3/7/2019 9:30 AM - 9:30 AM Courtroom Number: 2305 Location: District 1 Court Cook County, IL FILED DATE: 11/7/2018 12:10 PM 2018CH13891 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION CHICAGO PUBLIC MEDIA, Plaintiff, v. COOK COUNTY OFFICE OF THE PRESIDENT, Defendant. ) ) ) ) ) ) ) ) ) ) FILED 11/7/2018 12:10 PM DOROTHY BROWN CIRCUIT CLERK COOK COUNTY, IL 2018CH13891 2018CH13891 COMPLAINT NOW COMES Plaintiff, CHICAGO PUBLIC MEDIA, by its undersigned attorneys, LOEVY & LOEVY, and brings this suit to overturn Defendant COOK COUNTY OFFICE OF THE PRESIDENT’s refusal, in willful violation of the Illinois Freedom of Information Act, to comply with CHICAGO PUBLIC MEDIA’s Freedom of Information Act requests for Cook County Commissioner Bridget Gainer’s county emails regarding her political action committee. In support of its Complaint, CHICAGO PUBLIC MEDIA states as follows: INTRODUCTION 1. Pursuant to the fundamental philosophy of the American constitutional form of government, it is the public policy of the State of Illinois that all persons are entitled to full and complete information regarding the affairs of government and the official acts and policies of those who represent them as public officials and public employees consistent with the terms of the Illinois Freedom of Information Act (“FOIA”). 5 ILCS 140/1. 2. Restraints on access to information, to the extent permitted by FOIA, are limited exceptions to the principle that the people of this state have a right to full disclosure of information relating to the decisions, policies, procedures, rules, standards, and other aspects of FILED DATE: 11/7/2018 12:10 PM 2018CH13891 government activity that affect the conduct of government and the lives of the people. 5 ILCS 140/1. 3. All public records of a public body are presumed to be open to inspection or copying. Any public body that asserts that a record is exempt from disclosure has the burden of proving by clear and convincing evidence that it is exempt. 5 ILCS 140/3. 4. Under FOIA Section 11(h), “except as to causes the court considers to be of greater importance, proceedings arising under [FOIA] shall take precedence on the docket over all other causes and be assigned for hearing and trial at the earliest practicable date and expedited in every way.” PARTIES 5. Plaintiff CHICAGO PUBLIC MEDIA (“CPM”) is the FOIA requester in this case. CHICAGO PUBLIC MEDIA serves the public interest by creating and delivering diverse, compelling content that informs, inspires, enriches and entertains. Through a broad range of media platforms—such as the nonprofit radio station WBEZ 91.5fm—it connects diverse audiences in its service area and beyond to one another. It helps them make a difference in our communities, our region, and our world. 6. Defendant COOK COUNTY OFFICE OF THE PRESIDENT (“CCOP”) is a public body located in Cook County, Illinois. BACKGROUND INFORMATION 7. Cause the Effect Chicago PAC is a registered political action committee with the Illinois State Board of Elections. A true and correct copy of the Statement of Organization is attached as Exhibit A. 8. Cook County Commissioner Bridget Gainer was the Chairman of Cause the Effect Chicago PAC. -2- FILED DATE: 11/7/2018 12:10 PM 2018CH13891 9. Katie Sabo, a former employee of the Cook County Board of Commissioners and aide to Gainer, was the Treasurer of Cause the Effect Chicago PAC. 10. Cause the Effect Chicago PAC was formerly known as “Off the Sidelines Chicago.” JULY 20, 2018 FOIA REQUEST 11. On July 20, 2018, CPM requested “any and all correspondences, written or electronic, that contain the key words ‘Cause the Effect’ or ‘Off the Sidelines’ and were sent by Cook County Commissioner Bridget Gainer or any of the following employees of the Cook County Board of Commissioners: Margaret Cox, Katie Sabo, Abin Kuriakose, Michaela Vargas, Marty Malone.” A true and correct copy of the request is attached as Exhibit B. 12. On July 31, 2018, CCOP responded to the FOIA request by asking for an extension to August 3, 2018, stating that the request was unduly burdensome, and asking CPM to agree to narrow the request. A true and correct copy of the response is attached as Exhibit C. 13. On August 2, 2018, CPM agreed to narrow the request to only search for records from January 1, 2015 to the present. 14. On August 3, 2018, CCOP told CPM that the County Information and Technology Department has identified approximately 88 records and that Commissioner Gainer has identified approximately 3,000 records. 15. On August 10, 2018, CCOP produced 88 responsive records subject to redactions based on FOIA Sections 7(1)(b), 7(1)(c), 2(c-5), and 7(1)(f). A true and correct copy of the response is attached as Exhibit D. 16. None of the 3,000 emails that Commissioner Gainer identified were not produced on August 10, and CCOP has not provided a proper denial of that portion of the request. -3- FILED DATE: 11/7/2018 12:10 PM 2018CH13891 AUGUST 1, 2018 FOIA REQUEST 17. On August 1, 2018, CPM requested “any and all correspondences written or electronic, between the Office of the President or its employees and Cook County Commissioner Bridget Gainer or her staff since July 19, 2018 regarding [Dan Mihalopoulos’s] Freedom of Information Act request to the Office of the President file on July 20, 2018.” A true and correct copy of the response is attached as Exhibit E. 18. On August 9, 2018, CCOP produced nine responsive email records subject to redactions based on FOIA Sections 7(1)(b), 7(1)(c), 2(c-5), 7(1)(a), and 7(1)(m). A true and correct copy of the response is attached as Exhibit F. COUNT I – JULY 20, 2018 FAILURE TO PRODUCE RECORDS 19. The above paragraphs are incorporated by reference. 20. CCOP is a public body under FOIA. 21. The records sought in CPM’s FOIA request are non-exempt public records of 22. CCOP violated FOIA by failing to produce all of the responsive records to CPM’s CCOP. FOIA request and by improperly redacting the records that were produced. COUNT II – JULY 20, 2018 WILLFUL AND INTENTIONAL VIOLATION OF FOIA 23. The above paragraphs are incorporated by reference. 24. CCOP is a public body under FOIA. 25. The records sought in CPM’s FOIA request are non-exempt public records of 26. CCOP willfully and intentionally, or otherwise in bad faith failed to comply with CCOP. FOIA. -4- FILED DATE: 11/7/2018 12:10 PM 2018CH13891 COUNT III – AUGUST 1, 2018 FAILURE TO PRODUCE RECORDS 27. The above paragraphs are incorporated by reference. 28. CCOP is a public body under FOIA. 29. The records sought in CPM’s FOIA request are non-exempt public records of 30. CCOP violated FOIA by improperly redacting the records that were produced. CCOP. COUNT IV – AUGUST 1, 2018 WILLFUL AND INTENTIONAL VIOLATION OF FOIA 31. The above paragraphs are incorporated by reference. 32. CCOP is a public body under FOIA. 33. The records sought in CPM’s FOIA request are non-exempt public records of 34. CCOP willfully and intentionally, or otherwise in bad faith failed to comply with CCOP. FOIA. WHEREFORE, CPM asks that the Court: i. in accordance with FOIA Section 11(f), afford this case precedence on the Court’s docket except as to causes the Court considers to be of greater importance, assign this case for hearing and trial at the earliest practicable date, and expedite this case in every way; ii. declare that CCOP has violated FOIA; iii. order CCOP to produce the requested records; iv. enjoin CCOP from withholding non-exempt public records under FOIA; v. order CCOP to pay civil penalties; vi. award Plaintiff reasonable attorneys’ fees and costs; -5- FILED DATE: 11/7/2018 12:10 PM 2018CH13891 vii. award such other relief the Court considers appropriate. RESPECTFULLY SUBMITTED, /s/ Matthew V. Topic ____________________________ Attorneys for Plaintiff CHICAGO PUBLIC MEDIA Matthew Topic Joshua Burday LOEVY & LOEVY 311 North Aberdeen, 3rd Floor Chicago, IL 60607 312-243-5900 foia@loevy.com Atty. No. 41295 -6- ULI *lH-Eldl? 18: 129 OFFICES . . 17 1191: STATEMENT OF PLEASE TYPEOR PRINTIN BLACK INK .1. FILED DATE: 11/7/201812z10 PM 2018CH1II3I89I1 Full name and oomplate mai?ng address of Political Committee: Cause the Effect Chicago PAC 9947 8. Damen Ave. Chicago. 606 13 POLITICAL COMMITTEE IDENTIFICATION No. E-MAIL ADDRESS: -. Z. I I CHECK HERE IF ADDRESS CHANGE OEE GUIDE TO CAMPAIGN FOR GUIDANCE. 2 MOUNT OF Fuuos AVAILABLE AS OF - CREATION DATE :80 NEW BE FILED 10 DAYS OF CREATION OR WITHIN 2 DAYS IF CREATED IMTHIN so OAvs BEFORE AN ELECTION.) 3. El mama!? (MUST EIE FILED WITHIN 10 DAYS OF OI-IANOEE. 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THIS FORM MAY BE REPRODUCEO PAGE 1 OF 2 Rom-d 7M2 Exhibit A FILED DATE: 11/7/201812:10 PM 2018CH13891 1121:1315} OFFICES 3123467999 PE COMMITTEE NAME: COMMITTEE IDENTIFICATION No.1 8. REQUIRED COMMITTEE OFFICERS. PosmON NAME MAILING ADDRESS. DAYTIME PHONE NUMBER. AND E-MAIL ADDRESS CHAIRMAN Bridgn Gamer 9947 3. Damn Am. Chicago. IL 80643 516-555-1490 TREASURER ?we 3753 N. Shel?eld Chicago. 606 13 516-355-1490 9_ POSITION. NAME 8. MAILING ADDRESS OF EACH CUSTODIAN OF THE BOOKS AND ACCOUNTS. POSITION NAME MAILING ADDRESS. DAYTIME PHONE NUMBER. AND E-MAIL ADDRESS Records Custodian Wuhan Ch?s?ensen 9947 5. Damn Ave- Chicago. IL 50343 515-655-1490 1 0 LIST OF ALL FINANCIAL INSTITUTIONS AND OTHER REPOSITDRIES OF THE COMMITTEE FUNDS. AMENDING. LIST ALL AM DATE.) NAME MAILING ADDRESS AND PHONE NUMBER Chase Bank 10 S. Oaarbom Chicago. IL 60603 312-732-1184 I 1 1 . DISPOSITION OF RESIDUAL FUNDS IN THE EVENT OF DISSOLUTION OR TERMINATION OF THE COMMITTEE: RETURN To CONTRIBUTORS IN AMOUNTS NOT To EXCEED THEIR INDIVIDUAL CONTRIBUTIONS. TRANSFER To ANOTHER POLITICAL COMMITTEE. TRANSFER TOA CHARITABLE IF MORE SPACE FOR INFORMATION IS REQUIRED. PLEASE ATTACH ADDITIONAL SHEETS. VERIFICATION. Wcommses ONLY . - .. .Im IEFORNEDFORTHEPURPOSEOFSUWNOOR ALLCONTWAND 0F REEu?poss DESCRIEEDIN ms MWZATIDHTHE ODLIHITTEE AO?E?umeenmmImm Fm ANTSOURCE. PROVIDEDTHAT THIS DOES NOT MAKE EXPENDITURES INSUPPORTOF FDR NONINARON FOR Elzc?rmm OR mm. A EAILUR av sI-uu. Tris IN WW OF THIS PRINTED AND WRITTEN SIGNATURE OF COMMITTEE CHAIRPERSON DATE VERIFICATION: INDEPENDENT Ega?? DEERE COMMITTEES ONLY THE EX EWTTEE THE EXTENSIVE mm MG INDEPENDENTEXPEN GTURESII EXPENUTURES OF Tram mum ORTHEHJRW FAWN THE INLEPE OR EXPENDITUREOON MAKE comnmumm mum PQJTICAI. PMWCOHWTTEE. MD FNLURITD BY THESE REOUREMENTSM BEEN THE MIHEE WOLATION 051MB ARNOLE PRINTED AND WRITTEN SIGNATURE OF COMMITTEE CHAIRPERSON DATE VERIFICATION: c: mm. EA MOON-RICE ATEIIENTOFOROAMZAW WHETESTATEIIENTIS MUTUACWIL Tq MARTICLEOOF THEELECTDN DO I a h) Octobem, 201T - r1 PRINTED WRIT-TENS RE DF CANDIDATE DATE THE ILLINOIS STATE BOARD OF ELECTIONS OUIRES THE DISCLOSURE OF THAT IS NECESSARY IF YOU QUALIFY A3 A COMMITTEE A5 OUTLINEO UNDER PUBLIC ACT 78-1133. MLLFUL FAEURE TO FILE OR WILLFUL FILING OF FALSE OR INCOMPLETE IN REQUIRED THIS ARTICLE SHALL CONSTITUTEABUGINESS OFFENSE SUBJECT TOA FINEOF UP TO 55m THIS FCRM IS IN COMPLIANCE WITH THE FORMS WWI-TENT ALL POLITICAL COMMITTEES RETURN TO: I DECLARE THAT THIS STATEMENT OF WWIIMLUM E25 M0 HA5 WED BY LIE AND. TO THE HIST OF STATE BOARD OF ELEcnoNs f?g? 2329 MACARTHUR BLVD 1m WRANDOLPH ST. STE 14- 100 SPRINGFIELD. IL 627044503 CHICAGQ IL. 506111-3232 1' fax: 217-557-5630 1 fax: 312-814-6485 a-md Wit PAGE 2 OF 2 FILED DATE: 11/7/201812:10 PM 2018CH13891 Dan Mihalopoulos From: Dan Mihalopoulos Sent: Friday, July 20, 2018 1:33 PM To: FOIA@cookcountyil.gov Cc: 'Frank Shuftan (Presidents Office)?; Subject: FOIA for county board correspondences Cook County Office of the President ATTN: Legal Department Laura Lechowicz Felicione Special Counsel and FOIA Officer 118 N. Clark Street, Room 537 Chicago, IL 60602 VIA Dear Ms. Lechowicz Felicione: This is a request for public information under the Illinois Freedom of information Act (the Please provide any and all correspondences, written or electronic, that contain the key words ?Cause the Effect? or ?Off the Sidelines? and were sent by Cook County Commissioner Bridget Gainer or any of the following employees of the Cook County Board of Commissioners: Margaret Cox Katie Sabo Abin Kuriakose Michaela Vargas Marty Malone We understand that the Act permits a public body to charge a reasonable copying fee not to exceed the actual cost of reproduction and not including the costs of any search or review of the records. Please provide us with an estimate of any charges that may be incurred in fulfilling this request. However, we request a waiver of all fees for this request. Disclosure of the requested information to us is in the public interest because it likely to contribute significantly to the public's understanding of the operations or activities of state government. I look forward to receiving your response within five business days, i.e. before the close of business on July 27, 2018, as required by the Act. Please confirm receipt of this request. Exhibit FILED DATE: 11/7/201812:10 PM 2018CH13891 If you have any questions, please contact me at dmihalopoulos?wbezorq or cell (312) 404-8670. Thank you in advance for your assistance. Sincerely, Dan Mihalopoulos Reporter, Government Politics WBEZ 91.5FM/Chicago Public Media FILED DATE: 11/7/201812:10 PM 2018CH13891 Dan Mihalopoulos From: Laura Lechowicz (Presidents Office) Sent: Tuesday, July 31, 2018 6:59 PM To: Dan Mihalopoulos Cc: Rachel Dailey (Presidents Office) Subject: FOIA #18-713 July 3 1, 2018 Dan Mihalopoulos WBEZ 91.5FM/Chicago Public Media Email: dmihalopoulos@wbez.org Dear Mr. Mihalopoulos: The Of?ce of the President of the Cook County Board of Commissioners is in receipt of your request for information under the Freedom of Information Act (the On Friday, July 20, 2018 you requested ?any and all correspondences, written or electronic, that contain the key words ?Cause the Effect? or ?Off the Sidelines? and were sent by Cook County Commissioner Bridget Gainer or any of the following employees of the Cook County Board of Commissioners: Margaret Cox Exhibit FILED DATE: 11/7/201812:10 PM 2018CH13891 Katie Sabo Abin Kuriakose Michaela Vargas Marty Malone? Pursuant to 5 ILCS 140/3 (e)(vii) we extended the deadline to respond to your request, up to and including Friday, August 3, 20 1 8. Please be advised that your request, as written, is unduly burdensome and compliance with your request could not be completed without interfering with the daily operations of Cook County government. In accordance with section 3(g) of the Act, I ask that you contact me in order to discuss a reasonable reduction of your request. In an effort to make this request more manageable, it is requested that you agree to a six (6) month time frame in which to search said records and further reduce the number of individuals listed in your request. I will be out of the of?ce on Wednesday, August 1, 2018 but will be available to confer and discuss narrowing this request on Thursday, August 2, 2018 between the hours of 10:00 am. and 12:30 pm. by phone. Per Section 3(g) of the Act, please let me know if you are available this Thursday to confer. Upon con?rmation, I will have Rachel Dailey schedule the call. Thank you in advance for your cooperation. Laura FILED DATE: 11/7/201812:10 PM 2018CH13891 Laura Lechowicz Felicione, Esq. Special Legal Counsel and FOIA Of?cer Of?ce of the President Cook County, Illinois 69 W. Washington, Suite 1415 Chicago, Illinois 60602 Of?ce Phone: (312) 603-6371 E-Mail: PRIVILEGE AND CONFIDENTIALITY NOTICE: This electronic mail message and any attached ?les contain information intended for the exclusive use of the individual or entity to Whom it is addressed and may contain information that is proprietary, privileged, con?dential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby noti?ed that any viewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Please notify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message without making any copies. FILED DATE: 11/7/201812:10 PM 2018CH13891 Dan Mihalopoulos From: Laura Lechowicz (Presidents Office) Sent: Friday, August 10, 2018 2:29 PM To: Dan Mihalopoulos Cc: Rachel Dailey (Presidents Office) Subject: FOIA 18-713 Partial Response - Email 1 of 3 Attachments: 18-713 Cook County Emails File One Disclosure with Redactions 8.10.18.pdf Email No. 1 of 3 with Attachments - FOIA Request 18-713 August 10, 2018 Dan Mihalopoulos WBEZ Email: dmihalopoulo?wbezorg Re: FOIA Request 18-713 Dear Mr. Mihalopoulos: The Office of the President of the Cook County Board of Commissioners is in receipt of your request for information under the Freedom of Information Act (the On Friday, July 20, 2018 you requested ?any and all correspondences, written or electronic, that contain the key words ?Cause the Effect? or ?Off the Sidelines? and were sent by Cook County Commissioner Bridget Gainer or any of the following employees of the Cook County Board of Commissioners: Margaret Cox Katie Sabo Abin Kuriakose Michaela Vargas Marty Malone? Pursuant to 5 ILCS we extended the deadline to respond to your request, up to and including Friday, August 3, 2018. On July 31, 2018 you were informed that your request was unduly burdensome and that compliance with your request could not be completed without interfering with the daily operations of Cook County government. In accordance with section 3(g) of the Act, we discussed by phone on August 2, 2018 narrowing the requested information. On August 2, 2018 you provided an initial narrow of your request by maintaining the substantive nature of your request but narrowing the time frame for records sent since January, 2015. Per our conversation on August, 3, 2018, we discussed two separate tracks of documents; documents that could be generated by the County?s Enterprise Technology Department and documents that were directly in the possession of the Commissioner's Office. We agreed by phone on August 3, 2018 that the County would work with the Commissioner's Office to begin to review the records identified by the County Information Technology Department for responsiveness and apply any necessary redactions; furthermore, you were informed on August 3rd that said County records would be tendered on or before August 10, 2018. 1 Exhibit FILED DATE: 11/7/201812:10 PM 2018CH13891 Attached are the County email records responsive to this request that could be generated by the County?s Enterprise Technology Department. Due to the size of the attachments the attachments will be separated into two emails. Please note the following: 0 Private E-mail addresses and private cell phones have been redacted pursuant to sections and 1(c) of the Act. 5 ILCS 5 ILCS and 5 ILCS Preliminary drafts, notes, recommendations, memoranda and other records in which opinions are expressed, or policies or actions are formulated have been redacted pursuant to sections of the Act. 5 ILCS The undersigned is responsible for this partial denial. You have a right to have the partial denial of your request reviewed by the Public Access Counselor (PAC) at the Office of the Illinois Attorney General. 5 ILCS You can file your Request for Review with the PAC by writing to: Public Access Counselor Office of the Attorney General 500 South 2nd Street Springfield, Illinois 62706 Fax: (217) 782?1396 E-mail: publicaccess@atg.state.il.us You also have the right to seek judicial review of your denial by filing a lawsuit in the State circuit court. 5 ILCS 140/11. If you choose to file a Request for Review with the PAC, you must do so within 60 calendar days of the date of this denial letter. 5 ILCS Please note that you must include a hard copy of your original FOIA request and this denial letter when filing a Request for Review with the PAC. As to the remainder of documents in the Commissioner?s possession, per our agreement on August 3, 2018, the County asked Commissioner Gainer?s Office to determine if the records in her possession could be further broken down by name and year so we could confer at a later date and determine how the request can be further narrowed and determine if a log could be easily printed that would provide the date, sender, recipient and subject of the communication; please note, if such a log can be generated, the County would have to review the log and determine if redactions were required. Commissioner Gainer?s Office has advised that they are working on a log and I anticipate being in touch with you next week regarding the status of such log. It is anticipated that we will confer again following receipt and review of the log. Thanks for your patience while we continue to work on responding to your request. Laura Lechowicz Felicione, Esq. Special Legal Counsel to the President Legal and Government Affairs Office of the President Cook County 5 P. i rte Chicago, IL 60602 (0) 312-603-0002 (Direct) 312-603-6371 (PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail transmission, including all attachments, is confidential information belonging to the sender and the intended recipient, may be protected by the attorney-client privilege or attorney work product privilege, and may constitute non-public pre-decisional FOIA exempt information. This 2 FILED DATE: 11/7/201812:10 PM 2018CH13891 information is ONLY for the intended recipient. If you are not the intended recipient, you are hereby notified that any unauthorized use, disclosure, distribution (electronic or otherwise), copying or the taking of any action in reliance on this information is strictly prohibited. If you have received this transmission in error, please immediately notify the sender of receipt of the e-mail and then destroy all copies (electronic or otherwise) of the transmission and attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege or any other legal exemption from disclosure.) FILED DATE: 11/7/2018 12:10 PM 2018CH13891 On Aug 1, 2018, at 7:12 PM, Dan Mihalopoulos wrote: Cook County Office of the President ATTN: Legal Department Laura Lechowicz Felicione Special Counsel and FOIA Officer 118 N. Clark Street, Room 537 Chicago, IL 60602 VIA Email:FOIA@cookcountyil.gov Dear Ms. Lechowicz Felicione: This is a request for public information under the Illinois Freedom of Information Act (the "Act"). Please provide any and all correspondences, written or electronic, between the Office of the President or its employees and Cook County Commissioner Bridget Gainer or her staff since July 19, 2018 regarding my Freedom of Information Act request to the Office of the President filed on July 20, 2018. We understand that the Act permits a public body to charge a reasonable copying fee not to exceed the actual cost of reproduction and not including the costs of any search or review of the records. Please provide us with an estimate of any charges that may be incurred in fulfilling this request. However, we request a waiver of all fees for this request. Disclosure of the requested information to us is in the public interest because it likely to contribute significantly to the public's understanding of the operations or activities of state government. I look forward to receiving your response within five business days, i.e. before the close of business on August 9, 2018, as required by the Act. Please confirm receipt of this request. Exhibit E If you have any questions, please contact me at dmihalopoulos@wbez.org or cell (312) 404-8670. FILED DATE: 11/7/2018 12:10 PM 2018CH13891 Thank you in advance for your assistance. Sincerely, Dan Mihalopoulos Reporter, Government & Politics WBEZ 91.5FM/Chicago Public Media Dan Mihalopoulos Reporter, Government & Poli cs T @dmihalopoulos Edmihalopoulos@wbez.org P 312.893.8581 C312.404.8670 WBEZ 91.5 Navy Pier 848 East Grand Avenue Chicago, Illinois 60611 FILED DATE: 11/7/201812:10 PM 2018CH13891 Dear Mr. Mihalopoulos: The Office of the President of the Cook County Board of Commissioners is in receipt of your request for information under the Freedom of Information Act (the On Thursday, August 2, 2018 we received your request for ?any and all correspondences, written or electronic, between the Office of the President or its employees and Cook County Commissioner Bridget Gainer or her staff since July 19, 2018 regarding my Freedom of Information Act request to the Office of the President filed on July 20, 2018.? Attached are records responsive to your request. Please note the following: 0 Private E-mail addresses have been redacted pursuant to sections and 1(c) of the Act. 5 ILCS 5 ILCS and ILCS - Attorney communications and work product have been redacted pursuant to section and of the Act which exempts information prohibited from disclosure under federal or State law and exempts from disclosure ?[c]ommunications between a public body and an attorney or auditor representing the public body that would not be subject to discovery in litigation, and materials prepared or compiled by or for a public body in anticipation of a criminal, civil or administrative proceeding upon the request of an attorney advising the public body.? 5 ILCS and 5 ILCS The undersigned is responsible for this partial denial. You have a right to have the denial of your request reviewed by the Public Access Counselor (PAC) at the Office of the Illinois Attorney General. 5 ILCS You can file your Request for Review with the PAC by writing to: Public Access Counselor Office of the Attorney General 500 South 2nd Street Springfield, Illinois 62706 Fax: (217) 782-1396 E-mail: You also have the right to seek judicial review of your denial by filing a lawsuit in the State circuit court. 5 ILCS 140/11. If you choose to file a Request for Review with the PAC, you must do so within 60 calendar days of the date of this denial letter. 5 ILCS Please note that you must include a hard copy of your original FOIA request and this denial letter when filing a Request for Review with the PAC. If you have any questions, or if there is anything else we can do for you, please do not hesitate to contact me. Laura Lechowicz Felicione, Esq. Special Legal Counsel to the President Legal and Government Affairs Office of the President Cook County 69 W. Washington Blvd., Suite 1415 Chicago, IL 60602 (0) 312-603-0002 (Direct) 312?603?6371 Exhibit